After a regulatory action has been completed, Executive Order 12866 requires agencies 

to identify the substantive changes between the draft submitted to Office of Information 

and Regulatory Affairs (OIRA) for review and the action subsequently announced, and to 

identify those changes made at the suggestion or recommendation of OIRA. The 

document below provides more information.
[6450-01-P]

DEPARTMENT OF ENERGY

10 CFR Part 431

[Docket Number EERE-2009-BT-STD-0018]

RIN: 1904-AC00

Energy Conservation Program: Energy Conservation Standards for Metal Halide 

Lamp Fixtures

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking (NOPR) and public meeting.

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended, 

prescribes energy conservation standards for various consumer products and certain 

commercial and industrial equipment, including metal halide lamp fixtures. EPCA also 

requires the U.S. Department of Energy (DOE) to determine whether more-stringent, 

amended standards would be technologically feasible and economically justified, and 

would save a significant amount of energy. In this notice, DOE proposes amended energy 

conservation standards for metal halide lamp fixtures. The notice also announces a public 

meeting to receive comments on these proposed standards and associated analyses and 

results.

1
DATES: DOE will hold a public meeting on [XX Day of week, Month, Day, Year], from 

9 a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. 

See section VIII, “Public Participation,” for webinar registration information, participant 

instructions, and information about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of 

proposed rulemaking (NOPR) before and after the public meeting, but no later than 

[INSERT DATE 75 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL 

REGISTER PUBLICATION]. See section, “VIII Public Participation,” for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, 

Forrestal Building, Room [XX NUMBER], 1000 Independence Avenue, SW., 

Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586–2945. 

Please note that foreign nationals visiting DOE Headquarters are subject to advance 

security screening procedures. Any foreign national wishing to participate in the meeting 

should advise DOE as soon as possible by contacting Ms. Edwards to initiate the 

necessary procedures. Please also note that those wishing to bring laptops into the 

Forrestal Building will be required to obtain a property pass. Visitors should avoid 

bringing laptops, or allow an extra 45 minutes. Persons can attend the public meeting via 

webinar. For more information, refer to the Public Participation section near the end of 

this notice. 

2
Any comments submitted must identify the NOPR for Energy Conservation 

Standards for metal halide lamp fixtures, and provide docket number EE-2009-BT-STD0018 and/or regulatory information number (RIN) 1904-AC00. Comments may be 

submitted using any of the following methods: 

1. Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for 

submitting comments. 

2. E-mail: MHLF-2009-STD-0018@ee.doe.gov. Include the docket number and/or 

RIN in the subject line of the message.

3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 

20585-0121. If possible, please submit all items on a CD. It is not necessary to 

include printed copies.

4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC, 20024. Telephone: (202) 586-2945. If possible, please submit 

all items on a CD, in which case it is not necessary to include printed copies.

Written comments regarding the burden-hour estimates or other aspects of the 

collection-of-information requirements contained in this proposed rule may be submitted 

to Office of Energy Efficiency and Renewable Energy through the methods listed above 

and by e-mail to Chad_S_Whiteman@omb.eop.gov.

3
For detailed instructions on submitting comments and additional information on 

the rulemaking process, see section VIII of this document (“Public Participation”).

Docket: The docket is available for review at www.regulations.gov, including 

Federal Register notices, framework documents, public meeting attendee lists and 

transcripts, comments, and other supporting documents/materials. All documents in the 

docket are listed in the www.regulations.gov index. However, not all documents listed in 

the index may be publicly available, such as information that is exempt from public 

disclosure. 

A link to the docket web page can be found at: 

www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/49. This 

web page will contain a link to the docket for this notice on the regulations.gov site. The 

regulations.gov web page will contain simple instructions on how to access all 

documents, including public comments, in the docket. See section VIII for further 

information on how to submit comments through www.regulations.gov. 

For further information on how to submit a comment, review other public 

comments and the docket, or participate in the public meeting, contact Ms. Brenda 

Edwards at (202) 586-2945 or by email: brenda.edwards@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT: 

4
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, 

SW., Washington, DC, 20585-0121. Telephone: (202) 287-1604. E-mail: 

lucy.debutts@ee.doe.gov.

Mr. Ari Altman, U.S. Department of Energy, Office of the General Counsel, GC71, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 

287-6307. E-mail: ari.altman@hq.doe.gov. 

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Summary of the Proposed Rule

A. Benefits and Costs to Customers

B. Impact on Manufacturers

C. National Benefits

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Metal Halide Lamp Fixtures

3. Compliance Date

III. Issues Affecting the Scope of This Rulemaking

A. Additional Metal Halide Lamp Fixtures for Which DOE is Proposing Standards

1. EISA 2007 Exempted Metal Halide Lamp Fixtures

a. Fixtures with Regulated-Lag Ballasts

b. Fixtures with 480 V Electronic Ballasts

c. Exempted 150 W Fixtures

2. Additional Rated Lamp Wattages

3. General Lighting

4. Summary

B. Alternative Approaches to Energy Conservation Standards: System Approaches

1. Lamp-Ballast System

2. Fixtures Systems – Lamp, Ballast, Optics, and Enclosure

3. California Title 20 Approach

C. Combined Rulemakings

D. Standby Mode and Off Mode Energy Consumption Standards

5
IV. General Discussion

A. Test Procedures

1. Current Test Procedures

2. Test Input Voltage

a. Average of Tested Efficiency at all Possible Voltages

b. Posting the Highest and Lowest Efficiencies

c. Test at Single Manufacturer-Declared Voltage

d. Test at Highest-Rated Voltage

e. Test on Input Voltage Based on Wattage and Available Voltages

3. Testing Electronic Ballasts

4. Rounding Requirements

B. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

C. Energy Savings

1. Determination of Savings

2. Significance of Savings

D. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Customers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance of Products

e. Impact of Any Lessening of Competition

f. Need for National Energy Conservation

g. Other Factors

2. Rebuttable Presumption

V. Methodology and Discussion

A. Market and Technology Assessment

1. General

2. Equipment Classes

a. Input Voltage

b. Fixture Application

c. Electronic Configuration and Circuit Type

d. Lamp Wattage

e. Number of Lamps

f. Starting Method

g. Conclusions

B. Screening Analysis

C. Engineering Analysis

1. Approach

2. Representative Equipment Classes

3. Representative Wattages

4. Representative Fixture Types

5. Ballast Efficiency Testing

6. Input Power Representations

6
7. Baseline Ballast Models

a. 70 W Baseline Ballast

b. 150 W Baseline Ballast

c. 1000 W Baseline Ballast

8. Selection of More Efficient Units

a. Higher-Efficiency Magnetic Ballasts

b. Electronic Ballasts

9. Efficiency Levels

10. Design Standard 

11. Scaling to Equipment Classes Not Analyzed

12. Manufacturer Selling Prices

a. Manufacturer Production Costs

b. Incremental Costs for Electronically Ballasted Fixtures

c. Manufacturer Markups

D. Markups to Determine Equipment Price

1. Distribution Channels

2. Estimation of Markups

3. Summary of Markups

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analysis

1. Equipment Cost

2. Installation Cost

3. Annual Energy Use

4. Energy Prices

5. Energy Price Projections

6. Replacement Costs

7. Equipment Lifetime

8. Discount Rates

9. Analysis Period

10. Fixture Purchasing Events

G. National Impact Analysis–National Energy Savings and Net Present Value 

Analysis

1. Shipments

a. Historical Shipments

b. Fixture Stock Projections

c. Base Case Shipment Scenarios

d. Standards Case Efficiency Scenarios

2. Site-to-Source Energy Conversion

H. Customer Subgroup Analysis

I. Manufacturer Impact Analysis

1. Overview

2. GRIM Analysis and Key Inputs

a. Manufacturer Production Costs

b. Base Case Shipment Projections

c. Standards Case Shipment Projections

d. Markup Scenarios

7
e. Product and Capital Conversion Costs

3. Discussion of Comments

a. Compliance Period

b. Opportunity Cost of Investments

c. Impact on Competition

4. Manufacturer Interviews

a. Ability to Recoup Investments

b. Efficiency Metric Used

c. Maintenance of 150 W Exemption

J. Employment Impact Analysis

K. Utility Impact Analysis

L. Emissions Analysis

M. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

VI. Analytical Results

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Customers

a. Life-Cycle Cost and Payback Period

b. Customer Subgroup Analysis

c. Rebuttable Presumption Payback

2. Economic Impacts on Manufacturers

a. Industry Cash-Flow Analysis Results

b. Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Subgroups of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Significance of Energy Savings

b. Net Present Value of Customer Costs and Benefits

c. Impacts on Employment

4. Impact on Utility or Performance of Equipment

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

C. Proposed Standards

1. Trial Standard Level 5

2. Trial Standard Level 4

3. Trial Standard Level 3

D. Backsliding

VII. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

8
1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

b. Manufacturer Participation

c. Metal Halide Ballast and Fixture Industry Structure

d. Comparison Between Large and Small Entities

2. Description and Estimate of Compliance Requirements

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

4. Significant Alternatives to the Proposed Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VIII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements For Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

IX. Approval of the Office of the Secretary

PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

I. Summary of the Proposed Rule 

Title III, Part B1 of the Energy Policy and Conservation Act of 1975 (EPCA or 

the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles. Pursuant to 

EPCA, any new or amended energy conservation standard that the U.S. Department of 

Energy (DOE) prescribes for certain products, such as metal halide lamp fixtures 

(MHLFs or “fixtures”), shall be designed to achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 

1 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

9

 
6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant 

conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other 

statutory provisions discussed in this notice, DOE proposes amended energy conservation 

standards for metal halide lamp fixtures. The proposed standards, which are the minimum 

allowable ballast efficiencyefficiencies2 based on fixture location, ballast type, and rated 

lamp wattage, are shown in Table I.1. These proposed standards, if adopted, would apply 

to all products listed in and manufactured in, or imported into, the United States on or 

after January 1, 2015. (42 U.S.C. 6295(hh)(2)(B)).

Table I.1 Proposed Energy Conservation Standards for Metal Halide Lamp 

Fixtures

Equipment 

Classes

Rated Lamp 

Wattage 

Indoor/ 

Outdoor***

Test Input 

Voltage†

Minimum Standard Equation

%

1 ≥50 W and 

≤100 W Indoor 480 V 0.99499.4/(1+2.5∗P^(-0.55)) ‡

2 ≥50 W and 

≤100 W Indoor All others 1100/(1+2.5∗P^(-0.55))

3 ≥50 W and 

≤100 W Outdoor 480 V 0.99499.4/(1+2.5∗P^(-0.55))

4 ≥50 W and 

≤100 W Outdoor All others 1100/(1+2.5∗P^(-0.55))

5 >100 W and 

<150 W* Indoor 480 V 0.99499.4/(1+2.50.36∗P^(-

0.5530))

6 >100 W and 

<150 W* Indoor All others 1100/(1+0.636∗P^(-0.3430))

7 >100 W and 

<150 W* Outdoor 480 V 0.99499.4/(1+2.50.36∗P^(-

0.5530))

8 >100 W and 

<150 W* Outdoor All others 1100/(1+0.636∗P^(-0.3430))

9 ≥150 W** and 

≤250 W Indoor 480 V

No proposed amendment to 

EISA 2007For ≥150 W and 

≤200 W: 88.0

For >200 W and ≤250 W:

6.0*10^(-2)*P + 76.0

2 DOE is proposing to continue using a ballast efficiency metric for regulation of metal halide lamp 

fixtures, rather than a system or other approach. See section III.B for further discussion.

10

 
10 ≥150 W** and 

≤250 W Indoor All others

No proposed amendment to 

EISA 2007For ≥150 W and 

≤200 W: 88.0

For >200 W and ≤250 W:

7.0*10^(-2)*P + 74.0

11 ≥150 W** and 

≤250 W Outdoor 480 V

No proposed amendment to 

EISA 2007For ≥150 W and 

≤200 W: 88.0

For >200 W and ≤250 W:

6.0*10^(-2)*P + 76.0

12 ≥150 W** and 

≤250 W Outdoor All others

No proposed amendment to 

EISA 2007For ≥150 W and 

≤200 W: 88.0

For >200 W and ≤250 W:

7.0*10^(-2)*P + 74.0

13 >250 W and 

≤500 W Indoor 480 V No proposed amendment to 

EISA 200791.0

14 >250 W and 

≤500 W Indoor All others No proposed amendment to 

EISA 200791.5

15 >250 W and 

≤500 W Outdoor 480 V No proposed amendment to 

EISA 200791.0

16 >250 W and 

≤500 W Outdoor All others 91.5No proposed amendment 

to EISA 2007

17 >500 W and 

≤2000 W Indoor 480 V

For >500 W to <1000 W:

0.994∗(3.2∗10^(-53)∗P + 089.9)

For ≥1000 W to ≤2000 W: 

91.9%92.5 and may not utilize a 

probe-start ballast

18 >500 W and 

≤2000 W Indoor All others

For >500 W to <1000 W:

3.2∗10^(-53)∗P + 089.9

For ≥1000 W to ≤2000 W: 

92.5%93.1 and may not utilize a 

probe-start ballast

19 >500 W and 

≤2000 W Outdoor 480 V

For >500 W to <1000 W:

0.994∗(3.2∗10^(-53)∗P + 089.9)

For ≥1000 W to ≤2000 W: 

91.9%92.5 and may not utilize a 

probe-start ballast

20 >500 W and 

≤2000 W Outdoor All others

For >500 W to <1000 W:

3.2∗10^(-53)∗P + 089.9

For ≥1000 W to ≤2000 W: 

92.5%93.1 and may not utilize a 

probe-start ballast

11
*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that are also; rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A)); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by Underwriters Laboratories (UL) 1029–2001. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that are also; rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A)); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

***DOE’s proposed definitions for “indoor” and “outdoor” metal halide lamp fixtures are described in section V.A.2.

†Input voltage for testing would be specified by the test procedureprocedures. Ballasts rated to operate lamps less than 150 W 

would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at 

either of these voltages would be tested at the highest voltage for which the ballast is designed to operate.

‡P is defined as the rated wattage of the lamp that the fixture is designed to operate.

A. Benefits and Costs to ConsumersCustomers

Table I.2 presents DOE’s evaluation of the economic effects of the proposed 

standards on consumerscustomers of metal halide lamp fixtures, as measured by the 

average life-cycle cost (LCC) savings and the median payback period (PBP). The average 

LCC savings are positive for a majority of users for all equipment classes. For example, 

the estimated average LCC savings are approximately $83 and $4930 for fixtures 

operating a 150-400 W metal halide (MH) lamp in indoor and outdoor applications.

Table I.2 Impacts of Proposed Standards on Consumers of Metal Halide Lamp 

FixturesFixture Customers

Equipment Class Average LCC Savings

20102012$

Median Payback Period 

years

70 W (indoor, magnetic baseline) 23.0538.41 4.542

70 W (outdoor, magnetic 

baseline) 24.3046.44 4.874

150 W (indoor) 83.4710.14 3.164.7

150 W (outdoor) 48.96112.51 9.4010.5

250 W (indoor) *13.12 *11.8

250 W (outdoor) *13.75 *14.0

400 W (indoor) *28.23 *10.5

400 W (outdoor) *30.47 *12.3

1000 W (indoor) 273.58502.21 2.650

1000 W (outdoor) 229.46409.02 3.260

* Indicates equipment class where TSL 3 is represented by the baseline fixture.

12
B. Impact on Manufacturers

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the base year through the end of the analysis period (20152013 to 

20442045). Using a real discount rate of 8.9 percent, DOE estimates that the INPV for 

manufacturers of metal halide ballasts ranges from $235 million77 million in the low 

shipment-preservation of operating profit markup scenario to $252127 million in 

2010$.the high shipment-flat markup scenario in 2012$. Under the proposed standards, 

DOE expects ballast manufacturers to lose up to 4.925.0 percent of their INPV, which is 

approximately $11.625.9 million, in the low shipment,-preservation of operating profit 

markup scenario. In the high shipment-flat markup scenario, DOE expects manufacturers 

to increase their INPV up to 3.7 percent, which is approximately $4.5 million. Using a 

real discount rate of 9.5 percent, DOE estimates that the INPV for manufacturers of metal 

halide lamp fixtures ranges from $544 million523 million in the low shipmentpreservation of operating profit markup scenario to $616695 million in 2010$.the high 

shipment-flat markup scenario in 2012$. Under the proposed standards, DOE expects 

fixture manufacturers to lose up to 3.2.0 percent of their INPV, which is approximately 

$17.3 million, in the low shipment-preservation of operating profit markup scenario. In 

the high shipment-flat markup scenario, DOE expects manufacturers to increase their 

INPV up to 10.3 percent, which is approximately $64.8 million. Additionally, based on 

DOE’s interviews with the manufacturers of metal halide lamp fixtures, DOE does not 

expect any plant closings or significant loss of employment.

Comment [AGA1]: Change requested by OIRA.

Comment [AGA2]: Change requested by OIRA.

Comment [AGA3]: Change requested by OIRA.

Comment [AGA4]: Change requested by OIRA.

Comment [AGA5]: Change requested by OIRA.

Comment [AGA6]: Change requested by OIRA.

13
C. National Benefits

DOE’s analyses indicate that the proposed standards would save a significant 

amount of energy over 30 years (2015–2044)―an estimated 0.24–0.28 quadrillion British 

thermal units (quads) of cumulative energy for metal halide lamp fixtures. This amount is 

equivalent to the annual energy use of approximately 1 million U.S. homes. In addition, 

DOE expects the energy savings from the proposed standards to eliminate the need for 

approximately 0.25–0.34 gigawatts (GW) of generating capacity by 2044.. The lifetime 

savings for metal halide lamp fixtures purchased in a 30-year period (2016–2045) amount 

to 0.80–1.1 quads. 

The cumulative national net present value (NPV) of total consumercustomer costs 

and savings of the proposed standards in 20102012$ ranges from $0.795 billion (at a 7-

percent discount rate) to $3.2.1 billion (at a 3-percent discount rate) for metal halide lamp 

fixtures. This NPV expresses the estimated total value of future operating-cost savings 

minus the estimated increased equipment costs for equipment purchased in 2015–

20442016–2045, discounted to 20112013. 

In addition, the proposed standards would have significant environmental 

benefits. The energy saved in the form of electricitysavings would result in cumulative 

greenhouse gas emission reductions of 30–3549–65 million metric tons (Mt)3 of carbon 

dioxide (CO2) in 2015–2044. During this period, the proposed standards would result in 

emissions reductions of 7–9), 214–289 thousand tons of methane (CH4), 0.89–3.0 

3 A metric ton is equivalent to 1.1 short tons. Results for CH4, SO2, NOX and Hg are presented in short tons.

Comment [AGA7]: Deleted at the request of 

OIRA.

14

 
thousand tons of nitrous oxide (N2O), 65–87 thousand tons of sulfur dioxide (SO2), 66–

90 thousand tons of nitrogen oxides (NOX)), and 0.3811–0.4215 tons of mercury (Hg).4

DOE estimates the net present monetary value of the CO2 emissions reduction is between 

$0.1 and $1.68 billion, expressed in 2010$ and discounted to 2011. DOE also estimates 

the net present monetary value of the NOX emissions reduction, expressed in 2010$ and 

discounted to 2011, is approximately $6 million at a 7-percent discount rate, and $11 

million at a 3-percent discount rate.5, 6

The value of the CO2 emissions reductions is calculated using a range of values 

per metric ton of CO2 (otherwise known as the Social Cost of Carbon, or SCC) developed 

by a recent interagency process. The derivation of the SCC values is discussed in section 

V.M.1. DOE estimates the net present monetary value of the CO2 emissions reduction is 

between $0.33 and $4.7 billion, expressed in 2012$ and discounted to 2013. DOE also 

estimates the net present monetary value of the NOx emissions reduction, expressed in 

4 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook 

(AEO) 2013 Reference case forecast. This forecast accounts for regulatory emissions reductions through 

2010, including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not the Clean Air 

Mercury Rule (CAMR, 70 FR 28606 (May 18, 2005)). Subsequent, which generally represents current 

legislation and environmental regulations, including the recently finalized Cross-State Air Pollution rule 

(issued on July 6, 2011), do not appear in the forecast at this time for which implementing regulations were 

available as of December 31, 2012. 5 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating 

the potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its 

rulemakings.

6 DOE also estimated CO2 and CO2 equivalent (CO2eq) emissions that occur by 2030 (CO2eq includes 

greenhouse gases such as CH4 and N2O). The estimated emissions reductions by 2030 are 15–17 million 

metric tons CO2, 1,471–1,627 thousand tons CO2eq for CH4, and 63–70 thousand tons CO2eq for N2O.

Comment [AGA8]: Revised at the request of 

OIRA

Comment [AGA9]: Added at the request of 

OIRA.

15

 
2012$ and discounted to 2013, is $45 million at a 7-percent discount rate, and $91

million at a 3-percent discount rate.7

Table I.3 summarizes the national economic costs and benefits and costs of 

expected to result from today’s proposed standards, for metal halide lamp fixtures.

Table I.3products Summary of National Economic Benefits and Costs of Metal 

Halide Lamp Fixture Energy Conservation Standards (Primary (Low Shipments) 

Estimate)

Category Present Value

million 2012$

Discount 

Rate

Benefits

Operating Cost Savings 1,848 7%

 3,748 3%

CO2 Reduction Monetized Value 

($12.9/t case)* 333 5%

CO2 Reduction Monetized Value 

($40.8/t case)* 1,532 3%

CO2 Reduction Monetized Value

($62.2/t case)* 2,436 2.5%

CO2 Reduction Monetized Value 

(at $117 /t case)* 4,689 3%

NOx Reduction Monetized Value 

(at $2,639/ton)**

 45 7%

 91 3%

Total Benefits† 3,424 7%

 5,371 3%

Costs

Incremental Installed Costs 897 7%

 1,294 3%

Net Benefits

Including CO2 and NOx Reduction 

Monetized Value

 2,528 7%

 4,076 3%

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets 

of values are based on the average SCC from the integrated assessment models, at discount rates of 

2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all 

three models at a 3-percent discount rate, is included to represent higher-than-expected impacts 

from temperature change further out in the tails of the SCC distribution. The values in parentheses 

represent the SCC in 2015. The SCC time series used by DOE incorporate an escalation factor.

** The value represents the average of the low and high NOX values used in DOE’s analysis.

† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to 

average SCC value with 3-percent discount rate.

7 DOE has decided to await further guidance regarding consistent valuation and reporting of Hg emissions 

before it monetizes Hg in its rulemakings.

Comment [AGA10]: Added at the request of 

OIRA.

16

 
The benefits and costs of today’s proposed standards, for equipment sold in 2015–

2044between 2016 and 2045, can also be expressed in terms of annualized values. The 

annualized monetary values are the sum of (1) the annualized national economic value of 

the benefits from consumercustomer operation of productsequipment that meetmeets the 

proposed standards (consisting primarily of operating cost savings from using less 

energy, minus increases in equipment purchase and installation costs, which is another 

way of representing consumercustomer NPV), and (2) the annualized monetary value of 

the benefits of emissionemissions reductions, including CO2 emissionemissions

reductions.8 The value of the CO2 reductions, otherwise known as the Social Cost of 

Carbon (SCC), is calculated using a range of values per metric ton of CO2 developed by a 

recent interagency process. The derivation of the SCC values is discussed in section .

Although combining the values of operating savings and CO2 emissionemissions

reductions provides a useful perspective, two issues should be considered. First, the 

national operating savings are domestic U.S. consumercustomer monetary savings that 

occur as a result of market transactions, while the value of CO2 emissions reductions is 

based on a global value. Second, the assessments of operating cost savings and CO2

emissions savings are performed with different methods that use different time frames for 

8 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total 

customer costs and savings, for the time-series of costs and benefits using discount rates of 3 and 7 percent 

for all costs and benefits except for the value of CO2 emissions reductions. For the latter, DOE used a range 

of discount rates, as shown in Table I.4 The process that DOE used to convert the time-series of costs and 

benefits into annualized values is explained in section of this notice.”. From the present value, DOE then 

calculated the fixed annual payment over a 30-year period (2016 through 2045) that yields the same present 

value. The fixed annual payment is the annualized value. Although DOE calculated annualized values, this 

does not imply that the time-series of costs and benefits from which the annualized values were determined 

is a steady stream of payments.

17

 
analysis. The national operating cost savings is measured for the lifetime of metal halide 

lamp fixtures shipped in 2015–2044.between 2016 and 2045. The SCC values, on the 

other hand, reflect the present value of some future climate-related impacts resulting from 

the emission of 1 ton of CO2 in each year. These impacts will continue well beyond 

21002045.

shows theEstimates of annualized values for today’s benefits and costs of the 

proposed standards. (All monetary values below are expressedshown in Table I.42010$.).

The results under the primary estimate are as follows. (All monetary values below are 

expressed in 2012$.) Using a 7-percent discount rate for benefits and costs other than 

CO2 reductionemissions reductions, for which DOE used a 3-percent discount rate along 

with the SCC series corresponding to a value of $22.340.8/ton in 2010,2012$, the cost of 

the standards proposed in today’s rule is $2868.0 million per year in increased equipment 

costs, while the annualized benefits are $81139 million per year in reduced equipment 

operating costs, $3176 million in CO2 emissions reductions, and $0.63.4 million in 

reduced NOX emissions. In this case, the net benefit amounts to $85151 million per year. 

Using a 3-percent discount rate for all benefits and costs and the SCC series 

corresponding to a value of $22.340.8/ton in 2010,2012$, the cost of the standards 

proposed in today’s rule is $2764 million per year in increased equipment costs, while the 

benefits are $104186 million per year in reduced operating costs, $3176 million in CO2

emissions reductions, and $0.74.5 million in reduced NOX emissions. In this case, the net 

benefit amounts to $109202 million per year.

18
Table I.4 Annualized Benefits and Costs of Proposed Standards for Metal Halide 

Lamp Fixtures

Discount 

Rate

Primary (Low

Shipments)

Estimate*

Low 

Estimate* High Estimate*

Monetized Values

million 20102012$/year

Benefits

Operating Cost 

Savings

7% 81139 76169 87

3% 104186 96240 113

CO2 Reduction at 

$4Monetized Value 

($12.9/t** case)**

5% 821 826

7

CO2 Reduction at 

$22.3Monetized 

Value ($40.8/t**

case)**

3% 3176 3399

29

CO2 Reduction at 

$36.5Monetized 

Value ($62.2/t**

case)**

2.5% 49114 53149

45

CO2 Reduction at 

$67.6Monetized 

Value $117/t**

case)**

3% 94232 102303

87

NOX Reduction 

Monetized Value (at 

$2,537/t**639/ton)*

*

7% 0.63.36 0.64.06 0.5

3% 0.74.49 0.65.76

0.7

Total (Operating 

Cost Savings, CO2

Reduction and NOx

Reduction)†Total 

Benefits†

7% plus 

CO2 range

90163 to 176375 85200 to 

178476

95 to 174

7% 113218 110272 116

3% 136266 130344 142

3% plus 

CO2 range

113211 to 199422 105272 to 

198548

121 to 201

Costs

Incremental 

Equipment Costs

7% 2868 2681 30

3% 2764 2580 30

Net Benefits/Costs

Total (Operating 

Cost Savings, CO2

Reduction and NOx

Reduction, minus 

7% plus 

CO2 range

6296 to 149307 59119 to 

153396

65 to 144

7% 85151 84192 86

3% 109202 105264 112

Comment [AGA11]: Added at the request of 

OIRA

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

19
Incremental 

Equipment 

Costs)†Total†

3% plus 

CO2 range

86147 to 172358 80192 to 

174468

91 to 170

* This table presents the annualized costs and benefits associated with fixtures shipped in 2016 and 2045. These results 

include benefits to customers which accrue after 2045 from the fixtures purchased in 2016 to 2045. Costs incurred by 

manufacturers, some of which may be incurred prior to 2016 in preparation for the rule, are not directly included, but are 

indirectly included as part of incremental equipment costs. The Low (Primary, Low,) and High Estimates utilize forecasts of 

energy prices and housing starts from the AEO2011from the Energy Information Administration’s 2012 Annual 

Energy Outlook (AEO2013) from the AEO2013 Reference case, with the Low and High Estimates based on 

forecastedprojected fixture shipments in the Low Shipments, Roll-up and High Shipments, Roll-up scenarios, respectively. 

In addition, all estimates use incremental equipment costs that reflect a declining trend for equipment prices, using AEO price 

trends (deflators). The derivation and application of price trends for equipment prices is explained in section V.F.

** The CO2 interagency group selected four sets of SCC values represent global monetized for use in regulatory 

analyses. Three sets of values (in 2010$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values are based on the average SCC from the three integrated assessment models, at discount rates of 

$4.9, $22.2.5, 3, and $36.5 per ton are the averages of SCC distributions calculated using 5 -percent, 3-

percent, and 2.5-percent discount rates, respectively. The value of $67.6 per ton. The fourth set, which

represents the 95th percentile SCC estimate across all three models at a 3-percent discount rate, is included to represent 

higher-than-expected impacts from temperature change further out in the tails of the SCC distribution calculated using a 

3-percent discount rate.. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an 

escalation factor. The value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis.

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC value 

calculated at awith 3-percent discount rate, which is $22.3/ton in 2010 (in 2010$).. In the rows labeled as “7% 

plus CO2 range” and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount rate, 

and those values are added to the full range of CO2 values.

DOE has tentatively concluded that the proposed standards represent the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in the significant conservation of energy. DOE 

further notes that equipment achieving these standard levels are already commercially 

available for at least some, if not most, equipment classes covered by today’s proposal. 

Based on the analyses described above, DOE has tentatively concluded that the benefits 

of the proposed standards to the nation (energy savings, positive NPV of 

consumercustomer benefits, consumercustomer LCC savings, and emissionemissions

reductions) would outweigh the burdens (loss of INPV for manufacturers and LCC 

increases for some consumerscustomers).

DOE also considered more-stringent fixture energy efficiency-use levels as trial 

standard levels, (TSLs), and is still considering them in this rulemaking. DOE has 

20
tentatively concluded, however, that the potential burdens of the more-stringent energyuse levels would outweigh the projected benefits. Based on its consideration of the public 

comments DOE receives in response to this notice and related information collected and 

analyzed during the course of this rulemaking effort, DOE may adopt energy-use levels 

that are either higher or lower than the proposed standards, or some combination of 

level(s) that incorporate the proposed standards in part.

II. Introduction 

The following section discusses the statutory authority underlying today’s 

proposal, as well as some of the historical background related to the establishment of 

standards for metal halide lamp fixtures.

A. Authority

Title III, Part B of EPCA established the Energy Conservation Program for 

Consumer Products Other Than Automobiles,9 a program covering most major household 

appliances (collectively referred to as “covered products”). Amendments to EPCA have 

given DOE the authority to regulate the energy efficiency of several additional kinds of 

equipment, including certain metal halide lamp fixtures, which are the subject of this 

rulemaking. (42 U.S.C. 6292(a)(19)) EPCA, as amended by the Energy Independence 

and Security Act of 2007 (EISA 2007) prescribes energy conservation standards for these 

products (42 U.S.C. 6295(hh)(1)), and directs DOE to conduct a rulemaking to determine 

whether to amend these standards. (42 U.S.C. 6295(hh)(2)(A)) (DOE notes that under 42 

9 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

21

 
U.S.C. 6295(hh)(3)(A), the agency must review its already established energy 

conservation standards for metal halide lamp fixtures. Under this requirement, the next 

review that DOE would need to conduct must occur no later than January 1, 2019.)

Pursuant to EPCA, DOE’s energy conservation program for covered products 

consists of four parts: (1) testing; (2) labeling; (3) the establishment of Federal energy 

conservation standards; and (4) certification and enforcement procedures. DOE The 

Federal Trade Commission (FTC) is primarily responsible for labeling products such as 

metal halide lamp fixtures, and DOE implements the remainder of the program. Subject 

to certain criteria and conditions, DOE is required to develop test procedures to measure 

the energy efficiency, energy use, or estimated annual operating cost of each covered 

product. (42 U.S.C. 6293) Manufacturers of covered products must use the prescribed 

DOE test procedureprocedures as the basis for certifying to DOE that their products 

comply with the applicable energy conservation standards adopted under EPCA and 

when making representations to the public regarding the energy use or efficiency of those 

products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures 

to determine whether the products comply with standards adopted pursuant to EPCA. The 

DOE test procedures for metal halide lamp fixtures currently appear at title 10 of the 

Code of Federal Regulations (CFR) sections 431.323 and 431.324. 

As indicated above, DOE must follow specific statutory criteria for prescribing 

amended standards for covered products as found. As indicated above, any amended 

standard for a covered product must be designed to achieve the maximum improvement

22
in energy efficiency that is technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A).)) Furthermore, DOE may not adopt any standard that would not 

result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE 

may not prescribe a standard: (1) for certain products, including metal halide lamp 

fixtures, if no test procedure hasprocedures have been established for the product, or (2) 

if DOE determines by rule that the proposed standard is not technologically feasible or 

economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed 

standard is economically justified, DOE must determine whether the benefits of the 

standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this 

determination after receiving comments on the proposed standard, and by considering, to 

the greatest extent practicable, the following seven factors:

1. The economic impact of the standard on manufacturers and consumers of the 

products subject to the standard;

2. The savings in operating costs throughout the estimated average life of the 

covered products in the type (or class) compared to any increase in the price, 

initial charges, or maintenance expenses for the covered products that are 

likely to result from the imposition of the standard; 

3. The total projected amount of energy, or as applicable, water, savings likely 

to result directly from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered products likely 

to result from the imposition of the standard;

23
5. The impact of any lessening of competition, as determined in writing by the 

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

6. The need for national energy and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII))

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any amended standard that 

either increases the maximum allowable energy use or decreases the minimum required 

energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may 

not prescribe an amended or new standard if interested persons have established by a 

preponderance of evidence that the standard is likely to result in the unavailability in the 

United States of any covered product type (or class) of performance characteristics 

(including reliability), features, sizes, capacities, and volumes that are substantially the 

same as those generally available in the United States. (42 U.S.C. 6295(o)(4))

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the consumer 

will receive as a result of the standard, as calculated under the applicable test procedures.

See 42 U.S.C. 6295(o)(2)(B)(iii).

24
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a 

standard for a type or class of covered product that has two or more subcategories. DOE 

must specify a different standard level than that which applies generally to such type or 

class of products for any group of covered products that have the same function or 

intended use if DOE determines that products within such group (A) consume a different 

kind of energy from that consumed by other covered products within such type (or class); 

or (B) have a capacity or other performance-related feature which other products within 

such type (or class) do not have and such feature justifies a higher or lower standard. In 

determining whether a performance-related feature justifies a different standard for a 

group of products, DOE must consider such factors as the utility to the consumer of the 

feature and other factors DOE deems appropriate. (42 U.S.C. 6294(q)(1)) Any rule 

prescribing such a standard must include an explanation of the basis on which such a 

higher or lower level was established. (42 U.S.C. 6295(q)(2))

Federal energy conservation requirements generally supersede state laws or 

regulations concerning energy conservation testing, labeling, standards, and enforcement. 

(42 U.S.C. 6297(a)–(c)) DOE may, however, grant waivers of Federal preemption for 

particular state laws or regulations, in accordance with the procedures and other 

provisions set forth under 42 U.S.C. 6297(d)).

Finally, pursuant to the amendments contained in section 310(3) of EISA 2007, 

any final rule for new or amended energy conservation standards promulgated after July 

1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 

25
6295(gg)(3)) When DOE adopts a standard for a covered product after that date, it must, 

if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), 

incorporate standby mode and off mode energy use into the standard, or, if that is not 

feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 

6295(gg)(3)(A)-(B)) DOE’s current test procedures and standards for metal halide lamp 

fixtures address standby mode and off mode energy use. However, in this rulemaking, 

DOE only addresses active mode energy consumption as standby and off mode energy 

use are not applicable to the proposed scope of coverage.

DOE has also reviewed this regulation pursuant to Executive Order (E.O.) 13563, 

issued on January 18, 2011. 76 FR 3281, (Jan. 21, 2011). EO 13563 is supplemental to 

and explicitly reaffirms the principles, structures, and definitions governing regulatory 

review established in E.O. 12866. To the extent permitted by law, agencies are required 

by E.O. 13563 to: (1) propose or adopt a regulation only upon a reasoned determination 

that its benefits justify its costs (recognizing that some benefits and costs are difficult to 

quantify); (2) tailor regulations to impose the least burden on society, consistent with 

obtaining regulatory objectives, taking into account, among other things, and to the extent 

practicable, the costs of cumulative regulations; (3) select, in choosing among alternative 

regulatory approaches, those approaches that maximize net benefits (including potential 

economic, environmental, public health and safety, and other advantages; distributive 

impacts; and equity); (4) to the extent feasible, specify performance objectives, rather 

than specifying the behavior or manner of compliance that regulated entities must adopt; 

and (5) identify and assess available alternatives to direct regulation, including providing 

26
economic incentives to encourage the desired behavior, such as user fees or marketable 

permits, or providing information upon which choices can be made by the public.

DOE emphasizes as well that E.O. 13563 requires agencies “to use the best 

available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible.” In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include “identifying changing future 

compliance costs that might result from technological innovation or anticipated 

behavioral changes.” For the reasons stated in the preamble, DOE believes that today’s 

NOPR is consistent with these principles, including the requirement that, to the extent 

permitted by law, benefits justify costs and that net benefits are maximized. Consistent 

with EO 13563, and the range of impacts analyzed in this rulemaking, the energy 

efficiency standard proposed herein by DOE achieves maximum net benefits.

B. Background

1. Current Standards

EISA 2007 prescribed the current energy conservation standards for metal halide 

lamp fixtures manufactured on or after January 1, 2009. (42 U.S.C. 6295(hh)(1)) The 

current standards are set forth in Table II.1. EISA 2007 excludes fixtures from the 

standards summarized in that include : fixtures with regulated-lag ballasts, fixtures with 

electronic ballasts that operate at 480 volts (V); and fixtures that (1) are rated only for 

150 W lamps; (2) are rated for use in wet locations; and (3) contain a ballast that is rated 

to operate at ambient air temperatures higher than 50 °C.

27
Table II.1 Federal Energy Efficiency Standards for Metal Halide Lamp Fixtures*

Ballast Type Operated Lamp Rated Wattage 

Range Minimum Ballast Efficiency

Pulse-start ≥150 and ≤500 W 88%

Magnetic Probe-start ≥150 and ≤500 W 94%

Nonpulse-start Electronic ≥150 and ≤250 W 90%

Nonpulse-start Electronic ≥250 and ≤500 W 92%

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

2. History of Standards Rulemaking for Metal Halide Lamp Fixtures

DOE is conducting this rulemaking to review and consider amendments to the 

energy conservation standards in effect for metal halide lamp fixtures, as required under 

42 U.S.C. 6295(hh)(2) and (4). On December 30, 2009, DOE published a notice 

announcing the availability of the framework document, “Energy Conservation Standards 

Rulemaking Framework Document for Metal Halide Lamp Fixtures,” and a public 

meeting to discuss the proposed analytical framework for the rulemaking. 74 FR 69036.

DOE also posted the framework document on its website; this document is available at 

www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/49. The 

framework document described the procedural and analytical approaches that DOE 

anticipated using to evaluate energy conservation standards for metal halide lamp 

fixtures, and identified various issues to be resolved in conducting this rulemaking.

DOE held a public meeting on January 26, 2010, during which it presented the 

contents of the framework document, described the analyses it planned to conduct during 

the rulemaking, sought comments from interested parties on these subjects, and in 

general, sought to inform interested parties about, and facilitate their involvement in, the 

rulemaking. At the meeting and during the period for commenting on the framework 

28
document, DOE received comments that helped identify and resolve issues involved in 

this rulemaking.

DOE then gathered additional information and performed preliminary analyses to 

help develop potential energy conservation standards for metal halide lamp fixtures. On 

April 1, 2011, DOE published in the Federal Register an announcement (the April 2011 

notice) of the availability of the preliminary technical support document (the preliminary 

TSD) and of another public meeting to discuss and receive comments on the following 

matters: (1) the productequipment classes DOE planned to analyze; (2) the analytical 

framework, models, and tools that DOE was using to evaluate standards; (3) the results of 

the preliminary analyses performed by DOE; and (4) potential standard levels that DOE 

could consider. 76 FR 1812 (April 1, 2011). In the April 2011 notice, DOE requested 

comment on issues that would affect energy conservation standards for metal halide lamp 

fixtures or that DOE should address in this notice of proposed rulemaking (NOPR). The 

preliminary TSD is available at 

www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/49. 

The preliminary TSD summarized the activities DOE undertook in developing 

standards for metal halide lamp fixtures, and discussed the comments DOE received in 

response to the framework document. It also described the analytical framework that 

DOE uses in this rulemaking, including a description of the methodology, the analytical 

tools, and the relationships among the various analyses that are part of the rulemaking. 

The preliminary TSD presented and described in detail each analysis DOE performed up 

29
to that point, including descriptions of inputs, sources, methodologies, and results. These 

analyses were as follows: 

• A market and technology assessment set the scope of this rulemaking, 

identified the potential productequipment classes for metal halide lamp 

fixtures, characterized the markets for these productsthis equipment, and 

reviewed techniques and approaches for improving their efficiency;

• A screening analysis reviewed technology options to improve the efficiency of 

metal halide lamp fixtures, and weighed these options against DOE’s four 

prescribed screening criteria;

• An engineering analysis estimated the manufacturer selling prices (MSPs) 

associated with more energy-efficient metal halide lamp fixtures; 

• An energy-use analysis estimated the annual energy use of metal halide lamp 

fixtures;

• A markups analysis converted estimated MSPs derived from the engineering 

analysis to consumercustomer prices;

• A life-cycle cost (LCC) analysis calculated, for individual 

consumerscustomers, the discounted savings in operating costs throughout the 

estimated average life of the equipment compared to any increase in installed 

costs likely to result directly from the imposition of a given standard;

• A payback period (PBP) analysis estimated the amount of time it would take 

individual consumerscustomers to recover the higher purchase expense of 

more energy-efficient products through lower operating costs;

30
• A shipments analysis estimated shipments of metal halide lamp fixtures over 

the time period examined in the analysis. This was then used in the national 

impact analysis (NIA); 

• A national impact analysis assessed the national energy savings, and the 

national net present value of total consumercustomer costs and savings,

expected to result from specific, potential energy conservation standards for 

metal halide lamp fixtures; and

• A preliminary manufacturer impact analysis (MIA) began evaluating the 

effects on manufacturers of amended efficiency standards. 

The public meeting announced in the April 2011 notice took place on April 18, 

2011 (April 2011 public meeting). At this meeting, DOE presented the methodologies 

and results of the analyses set forth in the preliminary TSD. Interested parties discussed 

the following major issues at the public meeting: (1) alternative approaches to 

performance requirements and the various related efficiency metrics; (2) the possibility of 

including design standards; (3) amendments to the test procedures for metal halide

ballasts to account for multiple input voltages; (4) the cost and feasibility of utilizing

electronic ballasts in metal halide lamp fixtures; (5) equipment class divisions; (6) overall 

pricing methodology; (7) lamp lifetimes; (8) cumulative regulatory burden; (9) 

shipments; and (10) the possibility of merging the metal halide lamp fixture and the highintensity discharge (HID) lamp rulemakings. This NOPR responds to the issues raised in 

the comments received since publication of the April 2011 notice, including those 

received at the April 2011 public meeting.

31
3. Compliance Date

EPCA, as amended by EISA 2007, contains guidelines for the compliance date of 

the standards amended by this rulemaking. EPCA requires DOE to determine whether to 

amend the standards in effect for metal halide lamp fixtures and whether any amended 

standards should apply to additional metal halide lamp fixtures. The Secretary was 

directed to publish a final rule no later than January 1, 2012 to determine whether the 

energy conservation standards established by EISA 2007 for metal halide lamp fixtures

should be amended, with any amendment applicable to products manufactured on or 

three years following publication of a final rule.after January 1, 2015. (42 U.S.C. 

6295(hh)(2)(B))

III. Issues Affecting the Scope of This Rulemaking

A. Additional Metal Halide Lamp Fixtures for Which DOE is Proposing Standards

As noted in section II.B.1, the existing energy conservation standards for metal 

halide lamp fixtures are established in EPCA through amendments made by EISA 2007. 

(42 U.S.C. 6295(hh)(1)(A)) EISA 2007 prescribed energy conservation standards for 

metal halide lamp fixtures by setting minimum ballast efficiency requirements for new 

fixtures (fixtures manufactured after January 1, 2009. Currently, coverage is limited to 

certain rated wattages of lamps used in metal halide lamp fixtures (150 W to 500 W). 

Such fixtures must be equipped with a ballast that has a designated starting method 

(pulse-start or probe-start) and electronic configuration (magnetic or electronic). 

However, the statute excludes from coverage metal halide lamp fixtures with regulated32
lag ballasts,

10 electronic ballasts that operate at 480 V, and fixtures that: (1) are rated only 

for 150 W lamps, (2) are rated for use in wet locations,11 and (3) contain a ballast that is 

rated to operate at ambient air temperatures greater than 50 °C.12 (42 U.S.C. 

6295(hh)(1)(A))

In the preliminary TSD, DOE requested comment from interested parties on the 

scope of energy conservation standards rulemaking for metal halide lamp fixtures. DOE 

received several comments related to expanding the scope to include fixtures exempted 

by EISA 2007, fixtures designed to be operated with additional rated lamp wattages, and 

the definition of a general lighting application.

1. EISA 2007 Exempted Metal Halide Lamp Fixtures

DOE considered expanding its energy conservation standards to cover metal 

halide lamp fixtures exempted by EISA 2007, including fixtures with regulated-lag 

ballasts; electronic ballasts that operate at 480 V; and ballasts that are rated only for (1) 

use with 150 W lamps, (2) use in wet locations, and (3) operation in ambient air 

temperatures higher than 50 °C. (42 U.S.C. 6295(hh)(1)(B)) 

10 ‘Regulated lag ballast’ means ballasts designed to withstand significant line voltage variation with 

minimum wattage variation to the lamp. 

11 Specifications for “wet locations” are from the National Electrical Code 2002, section 410.4(A). 12 Specifications for ballasts that operate at ambient air temperatures above 50 °C are found in UL 1029-

2001.

33

 
a. Fixtures with Regulated-Lag Ballasts

In the preliminary analysis, DOE tentatively decided to continue the exemption 

for regulated-lag ballasts. Through information gathered in manufacturer interviews and 

market research, DOE determined that regulated-lag ballasts are mainly used for specialty 

applications where line voltage variation is large. Regulated-lag ballasts are designed to 

withstand significant line voltage variation with minimum wattage variation to the lamp,

which results in an efficiency penalty compared to ballasts whose output changes more 

significantly with line voltage variation. To be able to withstand large variations, 

regulated-lag ballasts are currently designed to be significantly larger than standard 

ballasts, and as a result exhibit poor efficiency. According to manufacturers and market 

research, EISA 2007’s exemption did not lead to a significant market shift to regulatedlag ballasts.

The Appliance Standard Awareness Project (ASAP) encouraged DOE to consider 

coverage for regulated-lag ballasts. While ASAP stated that they understood that 

regulated-lag ballasts may be inherently less efficient, they suggested a separate 

equipment class with a lower standard might be more appropriate than no standard. They 

also stated that little information about the market for regulated-lag ballasts is available. 

(ASAP, Public Meeting Transcript, No. 33 at p. 24)13 DOE conducted additional research 

on regulated-lag ballasts and found none of these products available in major 

13 A notation in the form ‘‘ASAP, Public Meeting Transcript, No. 33 at p. 24’’ identifies a comment that 

DOE has received and included in the docket of this rulemaking. This particular notation refers to a 

comment: (1) submitted by ASAP during the public meeting on April 18, 2011; (2) in the transcript of that 

public meeting, document number 33 in the docket of this rulemaking; and (3) appearing on page 24 of the 

transcript.

34

 
manufacturers’ catalogs. DOE assumed that absence from catalogs indicates a very small 

market share, and concluded that there was no potential for significant energy savings 

through inclusion of these products in the scope of coverage. In addition, DOE continues 

to agree with the preliminary analysis that the size and weight of regulated-lag ballasts 

prohibit their use as substitutes in traditional applications. For the NOPR, DOE proposes 

to continue exempting from energy conservation standards fixtures that include 

regulated-lag ballasts and requests comment on this proposal.

b. Fixtures with 480 V Electronic Ballasts

In the preliminary analysis, DOE also considered continuing the exemption of 480 

V electronic ballasts based on their unavailability in the market. In its comments, 

Empower Electronics disagreed with the exemption, stating that 347 V and 480 V

electronic ballasts for metal halide lamps are now feasible, and suggested that regulations 

could help the maturation of these technologies. (Empower Electronics, No. 36 at pp. 3-

4)14 Following additional research for the NOPR, DOE did identify one manufacturer of 

480 V electronic ballasts, but determined that these ballasts have a very small market 

share based on their limited availability from distributors and only being manufactured by 

one company. Therefore, DOE concluded that there is no potential for significant energy 

savings and proposes to continue exempting fixtures that use 480 V electronic ballasts 

until DOE has an opportunity to analyze commercially available products. DOE requests 

comment on this proposal.

14 A notation in the form “Empower Electronics, No. 36 at pp. 3-4” identifies a written comment that DOE 

has received and included in the docket of this rulemaking. This particular notation refers to a comment: (1) 

submitted by Empower Electronics; (2) in document number 36 of the docket,; and (3) on pages 3 to 4 of 

that document.

Comment [AGA12]: Added at the request of 

OIRA.

35

 
c. Exempted 150 W Fixtures

In the preliminary analysis, DOE considered eliminating the current exemption 

for 150 W outdoor fixtures rated for wet and hot locations because these products could 

be made more efficient and have the potential for significant energy savings. Shipments

for these exempted 150 W fixtures increased in response to the EISA 2007 regulations (a 

shift from 175 W fixtures), further increasing the potential energy savings for regulations 

targeted at this product type. In addition, DOE found that many fixtures commonly used 

indoors (high- and low-bay fixtures for high-ceiling buildings) meet the high-temperature 

requirements and have the option of being rated for wet locations. DOE preliminarily 

concluded that some fixtures used indoors were using the exemption designed for outdoor 

fixtures, negating possible energy savings for indoor 150 W fixtures. DOE requested 

comment on the impact of eliminating the exemption for 150 W outdoor fixtures rated for 

wet and high-temperature locations.

The National Electrical Manufacturers Association (NEMA), Philips Lighting 

Electronics (Philips), and Georgia Power commented that the wet-location and hightemperature outdoor 150 W fixture exemption was created in part to move the market 

from the popular 175 W ballast to the 150 W ballast, and lead to energy savings through a 

wattage reduction, and therefore does not constitute a loophole. (NEMA, No. 34 at p. 4; 

Philips, Public Meeting Transcript, No. 33 at pp. 24-25; Georgia Power, No. 28 at p. 1) 

NEMA stated that this exemption is critical for outdoor lighting ballasts because 150 W 

magnetic ballasts cannot meet the 88 percent EISA 2007 requirement. NEMA contended 

36
that the power savings realized by shifting from 175 W lamps to 150 W lamps, and the 

risk that the market would migrate back to 175 W without the exemption, far outweigh 

any additional savings generated by requiring that 150 W ballasts meet a ballast 

efficiency requirement. (NEMA, No. 34 at p. 4) DOE disagrees with NEMA that the 

removal of the exemption will result in a shift to 175 W fixtures. DOE is not required to 

set the standard for 150 W fixtures at or above the 88 percent minimum set by EISA

2007. Because these ballastsfixtures were not previously covered, setting a less stringent 

standard than 88 percent would not constitute backsliding and has the potential to save 

significant energy. DOE would analyze efficiency levels for 150 W fixtures according to 

the same criteria it uses for all other wattages. Section V.C.9 describes the efficiency 

levels under consideration in the NOPR for 150 W fixtures.

Northwest Energy Efficiency Alliance (NEEA) commented that there is no reason 

to continue the exclusion for fixtures rated for wet locations and ambient temperatures 

higher than 50 ̊C. If electronic ballasts with their higher efficiencies cannot be utilized in 

these fixtures, NEEA suggested placing them in a separate class for standards purposes 

rather than excluding them from coverage. (NEEA, No. 31 at pp. 1, 3) ASAP and, in a 

joint comment, Pacific Gas and Electric Company, San Diego Gas & Electric, Southern 

California Gas Company, and Southern California Edison (hereafter the “California 

Investor-Owned Utilities” [CA IOUs]) also supported the coverage of 150 W 

ballastsfixtures because the exemption may have become a loophole. (ASAP, Public

Meeting Transcript, No. 33 at p. 23; CA IOUs, No. 32 at p. 1) 

37
DOE agrees that these 150 W ballasts should be covered by this rulemaking and 

notes that the criteria for the scope of coverage for this rulemaking is defined as 

technology which is technologically feasible, economically justified, and has the potential 

for significant energy savings. Because a range of ballast efficiencies exist or are 

achievable in commercially available ballasts, DOE believes that improving the 

efficiencies of ballasts in 150 W fixtures in wet locations and high ambient temperatures 

is technologically feasible. DOE’s analysis indicates that removing the wet-location and 

high-ambient-temperature 150 W fixture exemption has the potential for energy savings 

and is economically justified. Therefore, in this NOPR, DOE proposes to remove the 

exemption for fixtures that are rated only for use with 150 W lamps, wet environments, 

and in ambient temperatures greater than 50 ̊C and include these fixtures in the scope of 

coverage. DOE requests comment on this proposal.

2. Additional Rated Lamp Wattages

During the preliminary analysis, DOE considered expanding its coverage of 

energy conservation standards to include metal halide lamp fixtures that operate lamps 

rated from 50 W to 150 W and fixtures that operate lamps rated greater than 500 W. 

DOE’s review of ballast manufacturer catalogs (an indication of product availability) 

showed many types of metal halide ballasts for fixtures operating lamps rated outside the 

currently regulated wattage range. The catalogs showed that approximately 30 percent

(by number of products, not by market share) of available metal halide ballasts are 

designed for lamps rated less than 150 W and approximately 13 percent of available 

metal halide ballasts are designed for lamps rated greater than 500 W. Due to the number 

38
of ballasts outside of the existing scope of coverage, DOE believed that there was

potential for significant energy savings and considered including fixtures designed to 

operate lamps with rated wattage ≥50 W in the analysis. DOE received comment on 

expanding the scope to fixtures that operate lamps rated from 50 W to 150 W and fixtures 

that operate lamps rated greater than 500 W.

In response to request for comment in the preliminary TSD, NEMA suggested 

that there is little energy savings to be realized by regulating ballastsfixtures for the 50 W 

to 150 W range due to their low energy usage and the movement of the market to the 

greater than 150 W power range. (NEMA, Public Meeting Transcript, No. 34 at p. 13) 

ASAP, NEEA, the CA IOUs, Empower Electronics, and Progress Energy Carolinas 

supported the expansion of scope to the greater than 50 W and less than 150 W range 

discussed in the preliminary TSD. (ASAP, Public Meeting Transcript, No. 33 at p. 23; 

NEEA, No. 31 at p. 1; CA IOUs, No. 32 at p. 1; Empower Electronics, No. 36 at p. 3; 

Progress Energy Carolinas, No. 24 at p. 2) DOE conducted testing within the 50 W to 

150 W range and identified varying efficiencies within a single wattage, which suggests 

that standards to improve the least-efficient ballasts are technologically feasible.

Furthermore, as discussed in section VI.B.3, DOE determined that standards for this 

wattage range have the potential for significant energy savings. Therefore, DOE proposes 

to include fixtures designed to operate lamps rated ≥50 W and <150 W.

DOE also received comment on the greater than 500 W equipment class. Georgia 

Power stated that regulating high wattages (such as 1000 W and 1500 W) would save 

39
little energy at significant cost. (Georgia Power, No. 28 at p. 2) ASAP, NEEA, the CA 

IOUs, Empower Electronics, and Progress Energy Carolinas, however, agreed with 

DOE’s preliminary findings and supported the expansion of scope to the >500 W range 

discussed in the preliminary TSD. (ASAP, Public Meeting Transcript, No. 33 at p. 23; 

NEEA, No. 31 at p. 1; CA IOUs, No. 32 at p. 1; Empower Electronics, No. 36 at p. 3; 

Progress Energy Carolinas, No. 24 at p. 2) In terms of technological feasibility, NEMA 

stated that the ballasts included in high-wattage fixtures are already up to 92 percent 

efficient. NEMA took the position that because this efficiency is comparable to the 

efficiencies of lower-wattage equipment with the highest-grade components, it would be 

difficult, if not impossible, to define energy efficiency requirements that would result in 

appreciable savings. Still, NEMA supported DOE’s determination that ballasts greater 

than 500 W were within the scope of DOE’s authority for preclusion of “state-by-state” 

rulemaking through preemption (NEMA, No. 34 at p. 3) In terms of potential for 

significant energy savings, NEMA noted that market estimates for greater-than-500-W 

ballasts are on the order of 15 percent, while the total energy use for equipment in this 

power range is estimated to be as high as 40 percent of the total of installed metal halide 

lamp fixtures. Id. 

DOE agrees that the greater-than-500-W ballasts have higher efficiencies than the 

lower-wattage productsequipment. However, based on test data, DOE still found a range 

of efficiencies present in commercially available ballasts, indicating technological 

feasibility. DOE also verified NEMA’s comment that these high-wattage products have 

fewer shipments than the lower-wattage products included in this rulemaking, but they 

40
consume more energy per installation. DOE’s analysis indicates that regulation of these 

higher wattages could be economically justified and has the potential for significant 

energy savings. Finally, based on review of product catalogs, DOE determined that 

fixtures rated for use with lamps rated for wattages greater than 2000 W served smallmarket-share applications like graphic arts, ultraviolet curing, and scanners. Therefore, 

DOE proposes not to include fixtures rated for wattages greater than 2000 W in this 

rulemaking. In summary, because DOE finds economic justification and potential energy 

savings in regulating ballasts greater than 500 W and less than or equal to 2000 W, DOE 

proposes that these ballastsfixtures be included in the scope of this rulemaking. DOE 

requests comment on this proposal.

3. General Lighting

EISA 2007 defines the scope of this rulemaking as applying to fixtures used in 

general lighting applications. (42 U.S.C. 6291(64)) In section 2 of 10 CFR Part 430, 

Subpart A, a general lighting application is defined as lighting that provides an interior or 

exterior area with overall illumination. DOE is proposing to add this definition to 10 CFR 

Part 431.2,15 the section of the CFR that relates to commercial and industrial equipment. 

DOE applies this definition to determine which lighting applications DOE has the 

authority to cover.

15 The general lighting application definition prescribed by EISA 2007 was previously incorporated into the 

consumer products section (10 CFR Part 430), but has not yet been added to the commercial and industrial 

equipment section (10 CFR Part 431).

41

 
NEMA and OSRAM SYLVANIA (OSI) recommended capping the greater-than500 W class at 1000 W because 1000 W is the highest wattage used for general lighting 

applications, arguing that DOE does not have authority to consider higher wattages. 

(NEMA, No. 34 at pp. 13-14; OSI, No. 27 at p. 4) OSI also commented that metal halide 

systems are also used in specialty applications such as stage, theater, television, film, 

solar simulation, airfield, medical/surgical, microscope, endoscope, video projection, 

display, treatment of skin disorders, sports, and automotive. OSI recommended that these 

specialized applications be excluded from this rulemaking. (OSI, No. 27 at p. 7) 

DOE’s research indicated that there are a number of fixtures available for general 

lighting applications above 1000 W. The primary application of such fixtures is outdoor 

sports lighting, which commonly uses metal halide ballasts of 1000 W to 2000 W. 

Because sports lighting provides overall illumination to an exterior area (playing field 

and stadium), DOE believes sports lighting does meet the definition of a general lighting 

application. While DOE agrees that some special applications listed by OSI do not fit 

under the covered general illumination definition, others, such as sports and airfield 

lighting, do provide general illumination to an exterior area and are covered by this 

rulemaking. DOE requests comment on this proposal.

4. Summary

DOE proposes to include metal halide lamp fixtures designed to operate ballasts 

rated from 50 W to 2000 W and for use in general lighting applications in the scope of 

coverage. EISA 2007 exempted specific metal halide lamp fixtures from regulation. 

42
These included (a) fixtures that include regulated-lag ballasts, (b) fixtures that include 

480 V electronic metal halide ballasts, and (c) fixtures that include lamps rated at 150 W 

with ballasts that (1) are rated for use in wet locations and (2) contain a ballast that is 

rated to operate at ambient air temperatures greater than 50 °C. In this rulemaking, DOE 

proposes to continue the exemption for the first two categories (regulated-lag ballasts and 

480 V electronic ballasts) but not for the third, certain 150 W fixtures. DOE finds that 

regulating these 150 W ballasts could provide considerable potential energy savings and 

would be economically justifiable. As such, DOE proposes that the 150 W ballasts rated 

for use in wet locations and containing a ballast that is rated to operate at ambient air 

temperatures greater than 50 °

C be covered in this rulemaking.

DOE also finds that there is economic justification and considerable potential 

energy savings for regulating metal halide ballasts rated from 50 W to 2000 W. DOE will 

continue to use the definition of general lighting applications in 10 CFR Part 430, 

Subpart A, 430.2 to specify which lighting applications are subject to regulation. 

B. Alternative Approaches to Energy Conservation Standards: System Approaches 

EISA 2007 requires DOE to set standards for metal halide lamp fixtures. (42 

U.S.C 6295(hh)(2)) As previously stated, although metal halide lamp fixtures usually 

comprise a metal halide lamp, a metal halide ballast, and other fixture components, 

EPCA established MHLF energy conservation standards by setting minimum efficiency 

requirements for only the ballast. For the preliminary analysis, DOE considered three 

system approaches as alternatives to regulating only ballast efficiency. The first was a 

43
lamp and ballast system approach in which the lamp and ballast would be rated together 

in terms of lumens per lamp-ballast system watts. The second was a whole fixture system 

approach in which the ballast, lamp, and optics/enclosure would all be rated together in 

terms of a fixture-level metric such as Fitted Target Efficacy (FTE) or Target Efficacy 

Rating (TER). The third was an approach similar to California Title 20, which allowed 

for multiple compliance pathways utilizing a combination of design standards, ballast 

efficiency standards, and lamp wattage requirements. DOE received several comments on 

these three system approaches.

In general, interested parties recognized the potential value for system approaches 

over a ballast efficiency approach, but also noted several limitations related to each 

possible approach. NEEA supported systems approaches to rating equipment, but did not 

find any of the three specific approaches discussed in the preliminary analysis to be 

practicable to implement. (NEEA, No. 31 at p. 2) Philips stated that, generally, NEMA 

considers the system approach to be the preferred approach for any rulemaking. (Philips, 

Public Meeting Transcript, No. 33 at p. 32) Philips noted that a system approach is an 

extremely complex issue and pointed out that there are other metrics beyond those that

DOE listed as under consideration. (Philips, Public Meeting Transcript, No. 33 at pp. 36-

37) DOE found that the three system approaches considered in the preliminary TSD have 

the theoretical potential of saving more energy than the current ballast-only approach, but 

also have many practical limitations. DOE weighed the benefits and drawbacks of each 

system approach, but for this rulemaking, DOE proposes a ballast-efficiency approach 

consistent with the current EISA 2007 regulations. DOE discusses each of the system 

approaches in the following sections. DOE also discusses the possibility of a coordinated

44
metal halide lamp fixture and high-intensity discharge lamp rulemaking in section III.C

as an additional approach to considering all aspects of the metal halide lighting system 

when considering energy conservation standards.

1. Lamp-Ballast System

In the lamp-ballast system approach, metal halide lamp fixtures would be 

regulated on the basis of a lumens-per-watt metric that assesses the performance of the 

lamp and ballast included in the fixture. Fixture manufacturers would be required to report 

the system lumens per watt (lm/W) of every lamp and ballast pair included in their 

fixtures. This approach has the potential to save more energy and allow more design 

flexibility for manufacturers. However, this approach is somewhat at odds with current 

fixture sales practices. Fixture manufacturers commonly ship fixtures with the ballast 

installed to ensure that the fixture is compliant with fire safety requirements and meets 

energy conservation standards. There are currently no requirements for fixtures to be 

shipped with certain lamps, and in general, fixture manufacturers noted that few fixtures 

are sold with lamps, giving consumerscustomers flexibility to choose lamps from a 

variety of manufacturers. In a lamp-ballast system approach, fixture manufacturers would 

be required to provide fixtures with installed lamps and ballasts, and consumerscustomers

would be limited to predetermined lamp and ballast combinations. 

During preliminary interviews, DOE found that there are several metal halide 

ballast manufacturers that do not manufacture metal halide lamps. In a lamp-ballast 

system approach, these manufacturers could have a competitive disadvantage compared 

with manufacturers that manufacture both lamps and ballasts. Manufacturers said that for 

45
fixture manufacturers that are not vertically integrated (i.e., fixture manufacturers that do 

not also produce lamps and ballasts), sourcing lamp and ballast systems is problematic as 

only a few manufacturers have the capability to provide them. Non-vertically-integrated 

manufacturers also said that they would not have the same ability to optimize the fixtures 

as their lamp and ballast-manufacturer competitors. Based on the concern that some 

manufacturers would be at a disadvantage to their vertically integrated competitors and 

that fixtures are typically not shipped with lamps, DOE preliminarily determined that 

ballast efficiency was a better approach than lamp-ballast systems.

NEMA described the pros and cons of a simple lumens-per-watt standard based 

on a lamp-ballast system. NEMA stated that this methodology provides more 

technological flexibility and can yield overall higher performance by including the effect 

of lamp efficacy. On the other hand, NEMA stated that there are compatibility issues with 

operation of certain lamp and ballast pairs. While some of these compatibility issues

would be resolved through use of a database, that database would require management by 

the industry, which represents additional cost and a reporting burden if manufacturers are 

required to report on various lamp and ballast combinations. It also might require 

manufacturers to transport mercury (if DOE mandates that a fixture be sold with a lamp). 

(NEMA, No. 34 at p. 5) 

Georgia Power and NEEA commented on the practical limitations of a lampballast system approach. Georgia Power pointed out that utilities buy lamps and fixtures 

separately and strive to minimize the number of lamp types that they must stock to use in 

new and existing fixtures. Georgia Power said that matching different lamps to different 

46
ballasts of the same wattage would be costly and very confusing. Additionally, Georgia 

Power noted that training the installers and relampers would be costly and impractical for 

the utilities. (Georgia Power, No. 28 at p. 1) NEEA commented that because there is no 

way to control which replacement lamps are used after the initial lamp fails, real system 

energy savings may be smaller than forecasts that assume an equivalent lamp is used as a 

replacement. (NEEA, No. 31 at p. 2)

With regards to lamp-ballast compatibility concerns with a lamp-ballast approach 

to setting standards, OSI commented that lamp and electronic ballast manufacturers 

already maintain lists of compatible products, indicating a lamp-ballast approach would 

not create additional burden. OSI stated that NEMA’s main concern is with highfrequency electronic ballasts operating high-wattage lamps. As noted in section V.C.8,

these ballasts can create acoustic resonance problems with lamps. The issue is further 

complicated by the fact that different lamps have different acoustic resonance points. OSI 

noted that NEMA has assembled a task force on lamp and electronic ballast compatibility 

issues, and the task force is close to finalizing compatibility test procedures. Once 

finalized, each manufacturer will conduct testing based on the procedure to determine 

compatibility with other products. OSI recommended that all electronic metal halide 

ballasts be designed to meet existing American National Standards Institute (ANSI)

standards based on magnetic operation. This redesign will help assure lamp and ballast 

compatibility. (OSI, No. 27 at p. 7)

47
In the preliminary TSD, DOE also considered a ‘table of standard lamps’ for use 

in a lamp-ballast system standard approach. The use of a table of standard lamps would 

allow for fixture performance to be assigned to all fixtures, including those not shipped 

with lamps. This table of standard lamps would allow for conversion of tested ballast 

efficiency to lumens per watt for determination of compliance with a lamp-ballast system 

standard, mitigating the potential for lost competitive advantage for ballast-only 

manufacturers. NEEA commented that they did not agree that a table of standard lamps 

(and a lamp-ballast system approach without a table of standard lamps) would adequately 

control which replacement lamps are used in fixtures. (NEEA, No. 31 at p. 2) 

DOE recognizes these positive and negative aspects of the lamp and ballast 

approach (both with and without the table of standard lamps) and has weighed them 

carefully and tentatively decided not to propose this approach. DOE found that a lamp

and ballast system approach might be burdensome due to unresolved compatibility and 

compliance issues related to specifying performance of every lamp and ballast 

combination sold. DOE tentatively agrees with Georgia Power’s concern that some users 

could need to stock multiple lamps for pairing with different manufacturers’ ballasts of 

the same wattage, unless they were willing to place all of their lamp and ballast orders 

from a single supplier. Additionally, once the original lamp fails, consumerscustomers

may replace it with a lower efficiency-efficacy alternative. A lamp-ballast system 

approach could also complicate defining categories and classes. In regards to a lampballast system approach with a table of standard lamps, DOE agrees with NEEA that such 

a table would not address consumerscustomers using less-efficacious replacement lamps 

48
and does not provide an adequate improvement over a traditional lamp-ballast system 

approach or a simple ballast efficiency approach. Though inclusion of the table could be 

more equitable for ballast-only manufacturers, it is still hindered by compliance and 

compatibility issues, and would likely result in less energy savings than a pure lampballast system approach.

2. Fixtures Systems – Lamp, Ballast, Optics, and Enclosure

For the preliminary TSD, DOE analyzed fixture-level metrics by conducting 

independent research and interviewing manufacturers. DOE found that fixture energy use

depends on four variables: (1) lamp efficacy; (2) ballast efficiency; (3) light absorption 

by the fixture; and (4) usefulness of light emitted by the fixture (direction or light 

distribution pattern). DOE considered two alternative metrics to quantify these areas of 

importance, namely FTE and TER. DOE drafted the FTE metric for the solid-state 

lighting (SSL) ENERGY STAR® program. NEMA, along with its luminaire division, 

developed TER. FTE and TER metrics treat each fixture-energy-use area of importance 

more effectively in some ways than others.

The FTE metric measures the fixture performance by fitting a rectangle to a 

uniform “pool” of light for each fixture, then multiplying the lumens delivered to this 

pool by the percent coverage of the rectangular target, and dividing the result by input 

watts to the fixture. Because FTE was developed for roadway and parking lot 

applications, separate algorithms for each respective application would need to be 

calculated and verified. As FTE is calculated using a rectangular area, a fixture that is 

49
designed to (1) light a non-rectangular area, (2) produce a large amount of unlighted area 

within the rectangle, or (3) produce specific light patterns that light both a horizontal 

plane and a vertical plane, or even above the fixture, will be at a disadvantage.

TER involves calculating fixture efficacy by multiplying the light leaving the 

fixture by the Coefficient of Utilization (CU), which factors in the distribution of light, 

room geometry, and room surface reflectances. CU represents the percentage of rated 

lamp lumens reaching a fixture specific target.the workplane. The calculation of efficacy 

for TER also takes into account lamp and ballast efficiency. TER has 22 different types 

of luminaire classifications, each with a different TER calculation method and value,

16

though every classification is not applicable to metal halide lamp fixtures. 

For the preliminary TSD, DOE tentatively decided not to implement either FTE 

or TER. DOE found that FTE only accounts for light hitting the specified test area and 

does not take into account other surfaces that the luminairefixture is designed to light. 

This methodology disadvantages fixture types not designed to light a uniform, flat, 

rectangular space. DOE tentatively decided not to use TER out of concern that certain 

fixtures could fall within multiple categories of luminairefixture due to their designs. 

Because of the need for uniformity and more simplicity, DOE preliminarily found TER 

unsuitable this rulemaking. The following discussion describes the comments DOE 

received about the use of these metrics. 

16 There are two main calculation methods – one for indoor and one for outdoor. applications. The methods 

are then customized to each classification.

50

 
Georgia Power and Progress Energy Carolinas suggested that TER and FTE were 

better metrics than the current ballast-efficiency metric because they address the optical 

performance of the entire fixture, accounting for light directionality and losses. (Georgia 

Power, No. 28 at p. 1; Progress Energy Carolinas, No. 24 at p. 1) However, NEEA 

commented that it did not believe that FTE or TER is appropriate as the basis for energy 

efficiency standards at this time. NEEA stated that either approach could be used as a 

design optimization framework, but both have sufficient drawbacks and lack of field 

implementation experience that render them unusable as the basis for a minimum 

efficiency standard. (NEEA, No. 31 at p. 2) NEMA agreed with the preliminary TSD, 

stating that because this rulemaking covers all types of products (e.g., downlights, track 

lighting, industrial highbay/lowbay, streetlighting, roadway lighting, floodlights, parking

lots, parking garages), it is challenging to define a metric that effectively covers all 

applications without flawed assumptions. Specifically, NEMA pointed out that none of 

the metrics considered covers a productequipment that is designed to be aimed or tilted. 

(NEMA, No. 34 at p. 6) Both NEEA and Empower Electronics also supported DOE’s 

determination from the preliminary TSD not to use either FTE or TER. (NEEA, No. 31 at 

p. 2; Empower Electronics, No. 36 at p. 4)

Though a fixture-level metric has the potential to save the most energy, DOE does 

not believe an approach currently exists that adequately assesses the types of metal halide 

lamp fixtures included in this rulemaking. Because FTE is focused on applications that 

deliver light to a horizontal space and a TER standard would require fixture 

classifications that have not yet been developed, DOE has determined that ballast 

51
efficiency is a better approach at this time. Therefore, DOE does not find fixture-level 

metrics practicable for setting standards for this equipment at this time, and proposes not 

to use a system-approach metric in this rulemaking.

3. California Title 20 Approach

California’s Title 2017 includes regulations that aim to reduce energy consumption 

in appliances, including metal halide lamp fixtures.18 For metal halide lamp fixtures, Title 

20 requires compliance through one of four primary paths: (1) the use of lamps from 

reduced-wattage bins with a minimum 88 percent efficient ballast; (2) an integrated 

motion sensor and high-low control with a minimum 88 percent efficient ballast; (3) an 

integrated daylight sensor and high-low control (for indoor only) with a minimum 88 

percent efficient ballast; and (4) high-efficiency ballasts with a minimum efficiency of 90 

percent for 150 W to 250 W lamps or 92 percent for 251 W to 500 W lamps. In the 

preliminary TSD, DOE requested comment on the implementation of a similar approach, 

with multiple options for compliance, including the integration of controls.

Several commenters gave direct feedback on the Title 20 approach. Energy 

Solutions supported DOE’s consideration of a Title 20 or Title-20-like metricapproach. 

(Energy Solutions, Public Meeting Transcript, No. 33 at p. 39) NEMA and Acuity Brands 

Lighting (Acuity) stated that although it also adds complexity to the associated 

enforcement and reporting, the Title 20 approach provides flexibility for manufacturers 

and designers. Additionally, NEMA and Acuity noted that the Title 20 requirement for 

17 www.energy.ca.gov/regs/title20/index.html 18 California’s term ‘metal halide luminaire’ refers to the same item as DOE’s ‘metal halide lamp fixture.’

52

 
336 W to 500 W reduced-wattage lamps to beproduce 80 lm/W is not currently 

achievable. Acuity requested that DOE not consider these lamp specifications, and stated 

that they have been working with the California Energy Commission (CEC) to correct 

that efficacy level. (NEMA, No. 34 at p. 6; Acuity, Public Meeting Transcript, No. 33 at 

p. 41)

NEMA also NEMA and Philips then addressed regulations that consider lamps 

and ballasts simultaneously for analysis, but assign performance metrics to each 

component individually. NEMA commented that they would support regulation that 

allows for lower ballast efficiency requirements in conjunction with highhigher lamp 

efficacy requirements. However, NEMA noted that a requirement to ship high-efficacy 

lamps in new fixtures would not prevent future replacement of these lamps with lowerefficacy alternatives. (NEMA, No. 34 at p. 5) Philips noted that it is possible to specify 

certain lamps for particular fixtures through an Underwriters Laboratories (UL) listing. 

Philips explained that if a ballast and a fixture are labeled for a particular lamp, then that 

fixture would only keep its UL listing when that lamp is used. This could mitigate the 

risk that the type of lamp originally packaged with the fixture would be replaced with a 

less-efficacious alternative. Additionally, Philips pointed out that for ENERGY STAR 

and fluorescent lamps, NEMA has maintained a table of corresponding lamp and ballast 

efficacies so that fixture manufacturers can easily select compliant products. Philips 

suggested that DOE could create a similar database for this rulemaking. (Philips, Public 

Meeting Transcript, No. 33 at pp. 33-34)

53
DOE also received many comments on the controls and dimming compliance 

pathways of the Title 20 approach. The CA IOUs noted that dimming and occupancy 

controls can greatly reduce the overall electricity consumption of a lighting system. The 

CA IOUs stated that many electronic ballasts in the 150 W to 575 W range include 

dimming circuitry. (CA IOUs, No. 32 at p. 5) OSI agreed that the use of dimming as an 

energy-saving tool is growing. OSI clarified that it is actually easier to develop an 

electronic metal halide dimming ballast than a magnetic one; and the electronic ballast 

will provide more utility for the end user. (OSI, No. 27 at p. 3) The CA IOUs specifically 

noted that for outdoor fixtures, from a public safety standpoint, dimming can be 

prohibitively slow in magnetic ballasts. However, there are commercially available 

electronically ballasted systems with appropriate response times that are much better 

suited for the transition towards fully controllable and dimmable fixtures. (CA IOUs, No. 

32 at p. 5)

Several commenters provided feedback on the relative merits of electronic metal 

halide lamp dimming, magnetic metal halide lamp dimming, and other lighting 

technologies like fluorescent lighting. OSI explained that magnetic ballasts (by using a 

split capacitor) can only provide two light levels (bi-level dimming). An electronic ballast 

has a microprocessor to provide stepped dimming at programmed levels or 0 to 10 V 

continuous dimming. Such using a continuous0 to 10 V signal. A continuously dimming 

ballast is compatible with daylight harvesting, scheduling, building management, demand 

response systems, and other processes where dimming is desirable. OSI stated that 

dimming can be provided in various applications, including outdoor lighting, by 

54
replacing a magnetic ballast with an electronic one with no rewiring needed. (OSI, No. 27 

at p. 3) Progress Energy Carolinas stated that bi-level dimming in magnetic ballasts has 

been around for years and has a proven track record. WhileAlthough there is a lumens per 

wattan efficacy decrease associated with dimming to 50 percent, Progress Energy 

Carolinas concluded that bi-level dimming is cost effective. (Progress Energy Carolinas, 

No. 24. at pp. 1-2) NEMA stated, however, that the incremental cost associated with an 

integrated bi-level dimming control in a metal halide lamp fixture can almost double the 

overall fixture cost. By contrast, the cost of integrated controls for a fluorescent lamp 

fixture designed for the same application requirements are about 30 to 40 percent higher 

than without controls, and the controls have more functionality due to the instant on and 

continuous dimming capability of the fluorescent system. For these reasons, NEMA 

argued that bi-level dimming with metal halide lamp fixtures is more costly and has less 

functionality than alternative technologies. (NEMA, No. 34 at p. 9)

Next, DOE received several comments relating to the applications that commonly 

use dimming, and the potential for difficulty in distinguishing some of these categories 

based on technical features. NEMA pointed out that although dimming metal halide lamp 

fixtures in certain applications where there is sporadic or limited occupancy (e.g., highbay and low-bay applications for warehousing) can result in significant energy reduction, 

NEMA pointed out that many MHLF applications are not well suited for bi-level control 

capabilities, such as operations and roadway lighting that operates 24 hours per day, 7 

days per week. (NEMA, No. 34 at p. 9) Progress Energy Carolinas also noted that apart 

from dusk-to-dawn photocontrol, occupancy sensors will not work for street lighting. 

55
Progress Energy Carolinas stated that street lighting would need to be controlled with a 

smart-box type of control. (Progress Energy Carolinas, No. 24 at p. 2) Cooper Lighting 

suggested that DOE analyze dimming in roadway lighting separately from other 

applications. (Cooper, Public Meeting Transcript, No. 33 at p. 40) Georgia Power 

recognized that the specifics of which applications can and cannot be dimmed, and how 

to measure energy reduction in unmetered applications (e.g., roadway lighting provided 

by a utility), will be complex. (Georgia Power, No. 28 at p. 1) NEMA noted that because 

DOE cannot distinguish products based on application type, it is unclear how DOE would 

describe regulatory requirements without specifying the use of controls based on 

application characteristics. (NEMA, No. 34 at p. 9) Specifically, NEMA also observed 

that the Title 20 approach requires differentiation between indoor and outdoor products, 

which DOE would have to define based on product attributes. (NEMA, No. 34 at p. 6)

Several commenters reported on the low percentage of fixtures using the controls 

pathways to compliance for California Title 20. Energy Solutions and the CA IOUs 

reported that of the chosen compliance pathways recorded in the CEC Appliance 

Database, most are either the reduced lamp wattage or the ballast efficiency requirement; 

not many report the controls compliance pathway. (Energy Solutions, Public Meeting 

Transcript, No. 33 at pp. 39-40; CA IOUs, No. 32 at p. 2) Philips explained that the 

controls compliance pathway has not been embraced because Title 20 requires all pieces 

of a control system to be integral to the fixture. Philips urged DOE to consider that a 

simplified approach to controllable fixtures would encourage more dimming systems and,

therefore, more energy savings. (Philips Lighting Electronics, Public Meeting Transcript, 

56
No. 33 at p. 40) Similarly, NEMA supported the concept of controllable fixtures and also 

suggested that controls be separate from the fixture for any regulations. NEMA stated 

that any incorporation of controls should be technology-neutral, allowing various control 

technologies without requiring the control to be integral to the fixture. (NEMA, No. 34 at 

p. 6)

NEEA saidexpressed concern over any forecasted energy savings resulting from 

the implementation of dimming ballasts, commenting that the presence of controls and 

the capability of dimming are no guarantee of use, and therefore, no guarantee of the 

promised energy savings. Consequently, NEEA did not agree with a Title 20 approach as 

part of a federal minimum efficiency standard. Furthermore, NEEA opposed DOE’s 

adoption of the Title 20 approach because California’s regulatory approach depends 

heavily on the existence of its Title 24 regulations (which have no DOE analog) for 

compliance and enforcement, including verifying the installation of the qualifying 

components that would meet the system requirements. For these reasons, NEEA felt that 

the Title 20 approach is unworkable at the federal level. (NEEA, No. 31 at p. 3)

In response to the various approaches in California Title 20, DOE is concerned 

that adopting these methods would risk reducing energy savings and complicating 

compliance and enforcement relative to ballast-efficiency-only regulations. With regards 

to the controls/dimming approach, DOE tentatively agrees that a standard requiring the 

presence of controls or dimming does not ensure energy savings. DOE believes that the 

use of such technologies is much less popular for metal halide systems relative to other 

57
lighting technologies. Metal halide lamp fixtures typically take 5 to 10 minutes to restrike and turn on again after being turned off, so controls that would turn metal halide 

lamp fixtures on and off more frequently have less utility relative to lighting with instant 

restarting capability. Additionally, a majority of metal halide lamp fixtures installed 

today use magnetic ballasts. Magnetic ballasts are typically only capable of bi-level 

dimming, giving them less functionality compared to other lighting technologies. 

Regarding the approach to allow less-efficient ballasts when sold in fixtures with more 

efficacious lamps, DOE is concerned that some energy savings could be lost if the lamp 

is replaced with a less efficacious lamp after the first failure, similar to its conclusions 

with lamp and ballast systems. Given the uncertainty of resulting energy savings, DOE 

has tentatively decided not to propose Title-20-like standards in this rulemaking.

C. Combined Rulemakings

In addition to system approaches, another method for maximizing energy savings 

and simplifying compliance would be to combine the metal halide lamp fixture and highintensity discharge (HID) lamp rulemakings (Docket EERE-2010-BT-STD-0043). These 

rulemakings are related because the MH lamps used in metal halide lamp fixtures are a 

subset of HID lamps. During the comment period and the public meeting for the metal 

halide lamp fixture preliminary TSD, and also in subsequent manufacturer interviews, 

DOE received requests that DOE consider metal halide lamp fixtures and HID lamps in a 

combined manner. The stated benefits of this approach include maximizing potential 

energy savings, avoiding conflicting rules for related technologies, avoiding duplicative 

efforts, improving consistency and ease of review, saving taxpayer dollars, and 

58
simplifying compliance. Based on the outcome of this NOPR, DOE will consider how to 

best combine the rulemakings. 

OSI, NEMA, and Philips commented that the metal halide lamp fixture 

rulemaking should be conducted in conjunction with metal halide lamp rulemakings. 

(OSI, No. 27 at p. 6; NEMA, Public Meeting Transcript, No. 33 at p. 15; NEMA, No. 34 

at p. 5; Philips, Public Meeting Transcript, No. 33 at p. 32) NEMA expressed concern 

that potential energy savings could be missed by keeping the metal halide lamp fixtures 

and HID lamps rulemakings separate. (NEMA, Public Meeting Transcript, No. 33 at p. 

15) OSI and NEMA recommended that the ballast efficiency and lamp efficacy 

regulations be completed in conjunction so that overall system efficacy can be recognized 

in resulting regulations. (OSI, No. 27 at p. 6; NEMA, No. 34 at p. 21) Additionally, 

Philips stated that keeping the lamp and ballast rulemakings separate will add complexity 

to maintaining lamp and ballast compatibility. (Philips, Public Meeting Transcript, No. 

33 at p. 32) Philips noted that if ballast regulations eliminate certain ballast types, they 

may also take certain lamps out of the market, losing all energy savings that were meant 

to be generated by the lamps’ standards. (Philips, Public Meeting Transcript, No. 33 at p. 

132) 

In its work to date on the HID lamp and MHLF energy conservation standards, 

DOE has identified and is using a number of shared data sources and analytical processes 

in the two rulemakings. The following is an initial inventory of rulemaking data and 

59
processes either fully or partially shared between HID lamps and metal halide lamp 

fixtures:

• market and technology assessments;

• distribution channels and price markups;

• annual operating hours;

• lamp, fixture, and ballast lifetimes;

• lamp lumen maintenance;

• installation times and costs;

• electricity prices;

• discount rates;

• lamp and fixture shipments;

• life-cycle cost (LCC) subgroup analysis; and

• regulatory impact analysis. 

DOE is currently evaluating the data and analytical processes that are shared 

between the two rulemakings.

D. Standby Mode and Off Mode Energy Consumption Standards

EPCA requires energy conservation standards adopted for a covered 

productequipment after July 1, 2010 to address standby mode and off mode energy use. 

(42 U.S.C. 6295(gg)(3)) The requirement to incorporate standby mode and off mode energy 

use into the energy conservation standards analysis is therefore applicable in this rulemaking. 

60
EISA 200710 CFR 431.322 defines the terms “active mode,” “off mode,” and “standby 

mode,” and “off mode” as follows: 

• “Active mode” is the condition in which an energy-using piece of equipment 

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

more main functions.

• “Off mode” is the condition in which an energy-using piece of equipment is 

connected to a main power source, and is not providing any standby or active 

mode function.

• “Standby mode” is the condition in which an energy-using piece of equipment 

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

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

of other functions (including active mode) by remote switch (including remote 

control), internal sensor, or timer; or providing continuous functions, 

including information or status displays (including clocks) or sensor-based 

functions.

For the preliminary TSD, DOE analyzed these definitions to determine their 

applicability to metal halide lamp fixtures. DOE tentatively found that it is possible for 

metal halide fixtures to operate in active mode and standby mode. The off mode 

condition does not apply because metal halide lamp fixtures do not operate in off mode. 

61
74 FR 33171, 33175 (July 10, 2009).

19 Therefore, for this energy conservation standard 

rulemaking , DOE only considered the active mode and standby mode energy use 

provisions from EISA 2007 applicable to metal halide lamp fixtures that are (or could be) 

covered by this rulemaking. 

DOE recognizes that metal halide lamp fixtures can be designed with auxiliary 

control devices, which could consume energy in standby mode. One example of this 

fixture design involves Digitally Addressable Light Interface (DALI) enabled ballasts. 

These ballasts may draw power in standby mode, as the internal circuitry remains on and 

active even when the ballast is not driving any lamps. DOE has yet to encounter such a 

ballast that it could purchase. DOE has continued to search for and consider DALIenabled fixtures, as well as other types of metal halide lamp fixtures, to evaluate the issue 

of standby mode energy use in metal halide lamp fixtures. In the preliminary TSD, DOE 

tentatively concluded that it cannot establish a separate standard that incorporates standby 

mode energy use and invited comments on the issue of standby mode and ballast designs 

that incorporate it. 

Philips and NEMA both expressed NEMA’s view, agreeing that a standard cannot 

be established for standby mode energy consumption. (Philips, Public Meeting 

Transcript, No. 33 at p. 29, NEMA, No. 34 at p. 3) Empower Electronics also commented 

that a standby mode energy standard cannot be established. (Empower Electronics, No. 

19 The definition of “off mode” requires that ballasts be connected to a main power source and not provide 

any standby mode or active mode function. (42 U.S.C. 6295(gg)(1)(A)(ii)) As discussed in the metal halide 

ballast test procedures, DOE does not believe that there is any condition in which the ballast is connected to 

the main power source and is not already accounted for in either active mode or standby mode.

62

 
36 at p. 2) NEEA agreed with DOE’s findings and proposals for standby mode and off 

mode. (NEEA, No. 31 at p. 2)

With no new findings with regard to ballasts drawing power in standby and off 

modes and comments supporting DOE’s preliminary proposal, DOE continues to 

conclude in this NOPR that it cannot establish a separate standard that incorporates

standby mode or off mode energy consumption.

IV. General Discussion

A. Test Procedures

1. Current Test ProcedureProcedures

The current test procedures for metal halide ballasts and fixtures are outlined in 

Subpart S of 10 CFR Part 431. The test conditions for the power supply, ballast, lamp, 

setup, and test instrumentation is specified in section 4.0methodology generally follow 

the guidance of ANSI C82.6-2005. Testing requires the use of a reference lamp, which is 

to be driven by the ballast under test conditions until the ballast reaches operational 

stability. Ballast efficiency for the fixture is then calculated as the measured ballast 

output power divided by the ballast input power. In this NOPR, DOE proposes changes to 

thetest input voltage for, testing, high-frequency electronic ballast testingballasts, and 

rounding requirements.

63
2. Test Input Voltage

Metal halide ballasts can be operated at a variety of voltages, with different 

voltages chosen based on the application and use of the fixture. The most common 

voltages are 120 V, 208 V, 240 V, 277 V, and 480 V. Ballasts will also commonly be 

rated for more than one, such as dual-input-voltage ballasts that can be operated on 120 V 

or 277 V, or quad-input-voltage ballasts that can be operated on 120 V, 208 V, 240 V, or 

277 V. DOE received manufacturer feedback that the specific design of a ballast and the 

voltage of the lamp operated by the ballast can affect the trend between input voltage and 

efficiency. DOE likewise observed that changes in efficiency (on the level of several 

percent) were possible in individual ballasts based on its own testing of multiple-inputvoltage ballasts. 

The existing test procedures do not specify the voltage at which a ballast is to be 

tested. Therefore, to ensure consistency among testing and reported efficiencies, the input 

voltage should be specified in the test procedures. To set an energy conservation standard 

based on test data, DOE needed to determine which input voltage to use for its data. In 

addition, manufacturers would need to test their productsequipment at the same input 

voltage asthat DOE used when developing energy conservation standards for the 

regulations to have the intended effect. Because the majority of ballasts sold are capable 

of operating at multiple input voltages, DOE is considering standardizing this aspect of 

testing. In the preliminary TSD, DOE requested comment on this issue, specifically on 

the possibility of testing at all input voltages and reporting the average of the efficiencies. 

DOE discusses several input voltage specification options in the following paragraphs.

64
a. Average of Tested Efficiency at all Possible Voltages

In the preliminary TSD, DOE asked for comment on the possibility of testing 

ballasts at each input voltage at which they are able to operate, then having a standard for 

the average of these efficiencies. NEEA commented that they saw the positive aspects of 

this method of testing. NEEA said that even though it would increase testing burden, it 

would also reduce efficiency bias associated with input voltage. (NEEA, No. 31 at p. 2) 

Philips commented that adapting a magnetic ballast for use with multiple input voltages 

lowers the efficiencies on one or more of the voltages, but the market has demanded the 

use of multi-tap ballasts, especially because the manufacturers desire to reduce inventory 

in an effort to lower cost. (Philips, Public Meeting Transcript, No. 33 at p. 28) NEMA 

said it disagreed with measuring at multiple voltages and then averaging due to the 

increased testing burden and associated costs. (NEMA, No. 34 at p. 2) Although DOE 

found little difference in ballast efficiency at different input voltages, DOE recognizes the 

possibility for efficiencies associated with rarely used input voltages to skew the overall 

efficiency of ballasts under this averaged-efficiencies approach. For example, a ballast 

might have the capability to operate on 120 V and 277 V at approximately 90 percent

efficiency, but at 208 V (an uncommon input voltage for metal halide lighting) it 

operated at only 88 percent efficiency. Averaging these three efficiencies would lead to a 

reported value of about 89 percent, when the ballast will in all likelihood only operate at 

120 V or 277 V (at 90 percent efficiency). In this instance, averaging the efficiencies 

misrepresents the performance of the ballast in its most common uses. Additionally, DOE 

recognizes that testing at each input voltage could increase the burden relative to a 

65
requirement of testing ballasts at only a single voltage. For these reasons, in this NOPR, 

DOE is not proposing to test at all available input voltages and average the resulting 

efficiencies. 

b. Posting the Highest and Lowest Efficiencies

Another approach, suggested by Empower Electronics, would require testing at 

each input voltage and listing the best and worst efficiencies on the product label. 

(Empower Electronics, No. 36 at p. 2) DOE acknowledges that, as with voltage 

averaging, this method could help address the concern that a manufacturer could optimize 

their ballasts on a voltage that could easily increase in efficiency, while most 

consumerscustomers would be using a non-optimized voltage. Also similar to voltage 

averaging, however, DOE finds that this approach would lead to a compliance burden for 

manufacturers and would increase the required tests compared to a requirement to test 

ballasts only at a single voltage.

c. Test at Single Manufacturer-Declared Voltage

In response to the preliminary TSD, NEMA suggested that the test procedures

should allow testing at a single voltage determined by the manufacturer and declared in 

the test report. (NEMA, No. 34 at p. 2) In manufacturer interviews, DOE received 

feedback that manufacturers optimize ballasts at a specific voltage and prefer to test their 

products at that voltage. DOE is concerned, however, that manufacturers might optimize 

efficiency at a voltage that is most convenient or least expensive rather than the voltage 

most used by consumerscustomers. Were manufacturers to optimize efficiency at a less 

66
commonly used voltage, the efficiency claimed at this voltage would not be 

representative of typical efficiency in the more common uses. Because the efficiency at 

the manufacturer-declared voltage and the efficiency at the more commonly used 

voltages may not have direct correlation, such a test procedureprocedures could 

potentially reduce the energy savings of this rulemaking. 

d. Test at Highest-Rated Voltage

Another input voltage specification could be that the ballast should be tested at 

the highest voltage possible. OSI commented, and NEEA agreed, that fluorescent ballast 

test procedures set the precedent for having to test only at the highest rated voltage. They 

also said that this would reduce costs associated with additional testing for metal halide 

ballasts. (OSI, Public Meeting Transcript, No. 33 at p. 29; NEEA, No. 31 at p. 2) DOE 

understands the concern regarding increased burdens and costs associated with being 

required to test ballasts at multiple input voltages. DOE’s research, however, found that a 

ballast’s highest-rated voltage is not always its most common input voltage. For example, 

DOE found a significant number of 70 W ballasts that were capable of operating on 120 

V, 208 V, 240 V, and 277 V. Testing at the highest-rated voltage would mean these 

ballasts are tested at 277 V, but manufacturer feedback indicated that 70 W ballasts are 

much more likely to be actually used in 120 V applications. One possible reaction to 

energy conservation standards based on this test procedure specification could be for 

manufacturers to optimize 70 W ballasts at 277 V (the tested voltage) as opposed to 120 

V (the more commonly used voltage). Because of this possibility, DOE finds that testing 

67
and enforcing standards at the highest voltage could reduce the potential energy savings 

of this rulemaking.

e. Test on Input Voltage Based on Wattage and Available Voltages

In this NOPR, DOE is proposing that the most common input voltages for each 

wattage range be used in testing. Progress Energy Carolinas commented that an 

amendment to the current test procedures that would specify the required input voltage 

for testing would not provide enough energy savings for the additional expense. (Progress 

Energy Carolinas, No. 24 at p. 2) DOE disagrees with Progress Energy Carolinas’ 

assertion that an added expense is inherent in specification of the input voltage for 

testing. DOE’s proposal only requires testing at one input voltage, the minimum number 

of tests possible. By proposing testing at a single voltage, DOE reduces testing burden 

relative to a requirement for testing at multiple input voltages. In addition, because the 

input voltage specification matches the most commonly used voltage, the requirement 

encourages optimization of efficiency around an input voltage commonly used in 

practice. Finally, analysis of the impact of energy savings for this rulemaking is made 

more accurate by assessing ballast efficiency at the most commonly used input voltages.

In manufacturer interviews, DOE received feedback on usage of different input 

voltages. DOE learned that 208 V is the least used and least optimized voltage. DOE also 

received feedback that efficiencies at 277 V and 240 V are similar to each other. In 

general, DOE determined that fixtures with wattages less than 150 W were most often 

68
used at 120 V. Wattages of 150 W and above were most commonly used at 277 V. Thus, 

this NOPR proposes that testing of metal halide ballasts use the following input voltages:

• For ballasts less than 150 W that have 120 V as an available input voltage, 

ballasts are to be tested at 120 V.

• For ballasts less than 150 W that lack 120 V as an available voltage, ballasts 

should be tested at the highest available input voltage.

• For ballasts operated at greater than or equal to 150 W and less than or equal 

to 2000 W that also have 277 V as an available input voltage, ballasts are to 

be tested at 277 V.

• For ballasts greater than or equal to 150 W and less than or equal to 2000 W 

that lack 277 V as an available input voltage, ballasts should be tested at the 

highest available input voltage. 

3. Testing Electronic Ballasts

With regards to testing electronic metal halide ballasts, DOE received feedback 

on several issues in response to the preliminary TSD. Some interested parties commented 

that the test procedures do not apply to any electronic ballasts and others commented that 

high-frequency electronic ballast testing is not specified and is more prone to 

measurement variation than low-frequency electronic ballast testing is. DOE discusses 

these comments below.

69
In the preliminary TSD, DOE noted that it would continue to use the 20022005

version of ANSI C82.6 for testing both electronic and magnetic ballasts. Philips and 

Venture both commented that there are currently no test procedures for electronic 

ballasts. (Philips, Public Meeting Transcript, No. 33 at p. 130; Venture, Public Meeting 

Transcript, No. 33 at p. 130) Both Cooper and NEMA noted that an update to ANSI 

C82.6 that was to be released by the end of 2011 would include test procedures for lowfrequency electronic (LFE) ballasts, but not high-frequency electronic (HFE) ballasts.20

(Cooper, Public Meeting Transcript, No. 33 at pp. 27-28; NEMA, No. 34 at p. 2) NEEA 

commented that this delay should preclude DOE from altering the test procedures for 

electronic metal halide ballasts at this time. (NEEA, No. 31 at p. 2) In DOE’s reading of 

ANSI C82.6, the scope dictates testing HID lamp ballasts without specifying applicability 

only to magnetic ballasts. In interviews with manufacturers, DOE received feedback 

confirming that ANSI C82.6-2005 does provide a method for testing low-frequency 

ballasts. Additionally, section 4.4.3 of ANSI C82.6 provides for fixtures that include2005 discusses low-frequency electronic ballasts. in the context of alternative 

stabilization methods.

DOE also received comments that HFE ballasts should be excluded from the 

rulemaking because there are no test procedures for them. Philips, OSI, and NEMA noted 

that the available equipment cannot test HFE ballast frequencies above 125 kHz as 

accurately as other ballasts, and Philips noted that HFE ballast testing accuracy can range 

from plus or minus two to five percent. (Philips, Public Meeting Transcript, No. 33 at p. 

20 At the time of development of this NOPR in mid-2012, an update to ANSI C82.6-2005 was not yet 

available.

70

 
130; NEMA, No. 34 at p. 14; OSI, No. 27 at p. 4) NEEA commented that manufacturers 

stated that there are no ANSI or NEMA HFE standards, and that no test procedures could 

accurately assess the efficiency of these ballasts to within plus or minus one percent. 

Based on this information, NEEA recommended that DOE should not consider these 

products in this rulemaking. (NEEA, No. 31 at p. 9) Empower Electronics commented 

that the test procedures should be amended to include HFE ballast testing. (Empower 

Electronics, No. 36 at p. 2) DOE agrees that the instrumentation in ANSI C82.6-2005 is

ratedspecified only up to 800 Hz for ammeters and voltmeters and to 1 kHz for 

wattmeters, and also that these would be insufficient for measurements of HFE ballasts. 

DOE is proposing to amend the metal halide ballast and fixtures test procedures to 

specify the instrumentation required to test HFE ballasts. DOE found that the

equipmentinstrumentation commonly used for high-frequency electronic metal halide 

ballast testing is the same equipmentinstrumentation used for fluorescent lamp ballast 

testing. DOE proposes that equipmentinstrumentation at least as accurate as required by

ANSI C82.6-2005 be used to assess the output frequency of the ballast. Once the output 

frequency is determined to be greater than or equal to 1000 Hz, (the frequency at which 

DOE proposes to define high-frequency electronic ballasts), the test procedure 

equipmentinstrumentation would be required to include a power analyzer that conforms 

to ANSI C82.6-2005 with a maximum of 100 picofarads (pF) capacitance to ground and 

frequency response between 40 Hz and 1 MHz. The test procedures would also require a 

current probe compliant with ANSI C82.6-2005 that is galvanically isolated and has a 

frequency response between 40 Hz and 20 MHz, and lamp current measurement where 

71
the full transducer ratio is set in the power analyzer to match the current to the analyzer. 

The full transducer ratio would be required to satisfy: 

Iin

Vout

×

Rin

Rin+Rs

 Where:

Iin is current through the current transducer;

Vout is the voltage out of the transducer;

Rin is the power analyzer impedance; and

Rs is the current probe output impedance. 

4. Rounding Requirements

DOE also proposes to amend the metal halide ballast test procedure requirements 

for measuring and recording input wattage and output wattage to require rounding to the 

nearest tenth of a watt, and the resulting calculation of efficiency to the nearest tenth of a 

percent. Through testing, DOE found that testing multiple samples of the same ballast 

yielded a range of ballast efficiencies typically differing by less than half of one percent. 

Because this data introduces both repeatabilitytest measurement and 

reproducibilitysample to sample variation, the test methodmeasurement itself should be at 

least this accurate (because part of the variation would have been due to sample to sample 

variation).. Therefore, DOE believes its test procedures can resolve differences of less 

than half of one percent and rounding to the tenths decimal place would be reasonable.

72
B. Technological Feasibility

1. General

In each standards rulemaking, DOE conducts a screening analysis based on 

information it has gathered on current technology options and prototype designs that 

could improve the efficiency of the products or equipment that are the subject of the 

rulemaking. As the first step in this analysis, DOE develops a list of design options for 

consideration in consultation with manufacturers, design engineers, and other interested 

parties. DOE then determines which of these options for improving efficiency is 

technologically feasible.21 DOE considers technologies incorporated in commercially 

available products or in working prototypes to be technologically feasible. 10 CFR 430, 

subpart C, appendix A, section 4(a)(4)(i).)

Once DOE has determined that particular design options are technologically 

feasible, it evaluates each of these design options according to the following three

screening criteria: (1) practicability to manufacture, install, or service; (2) adverse 

impacts on product utility or availability; and (3) adverse impacts on health or safety. 

Section V.B of this notice discusses the results of the screening analysis for metal halide 

lamp fixtures. In particular, it lists the designs DOE considered, those it screened out, and 

those that are the basis for the TSLs in this rulemaking. For further details on the 

screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.

21 DOE considers technologies incorporated in commercially available products or in working prototypes to 

be technologically feasible. 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i)

73

 
2. Maximum Technologically Feasible Levels

Section 325(o) of EPCA requires that when DOE amends standards for a type or 

class of covered productequipment, it must determine the maximum improvement in 

energy efficiency or maximum reduction in energy use that is technologically feasible for 

that product. (42 U.S.C. 6295(o)) Accordingly, DOE determined the maximum 

technologically feasible (“max tech”) ballast efficiency in this NOPR’s engineering 

analysis, using the design options identified in the screening analysis (see chapter 4 of the 

NOPR TSD). 

To determine the max tech level, DOE conducted a survey of the MHLF market 

and the research fields that support the market. DOE’s view based on test data is that 

within a given equipment class, no working prototypes exist that have a distinguishably 

higher ballast efficiency than currently available equipment. Therefore, the highest 

efficiency level presented, which represents the most efficient tier of commercially 

available equipment, is the max tech level for this rulemaking. This highest efficiency 

level requires electronic ballasts using the best components and circuit topologies 

commercially available for fixtures rated ≥50 W to ≤500 W. The max tech efficiency 

level requires the highest grades of core steel and copper windings for the fixtures rated 

>500 W and ≤2000 W.

As discussed in section , the onlyDOE did not screen out any technology screened 

out due to potential technological infeasibilityoptions in the preliminary analysis was the 

use of laminated sheets of amorphous steel. 

74
. DOE received several comments regarding its determination of max tech 

ballast efficiency in the preliminary TSD. These comments are discussed in section 

V.C.8. For this NOPR, DOE conducted additional analysis to determine the appropriate 

max tech levels for metal halide ballasts. As discussed in section V.C.3, DOE added 150 

W as a representative wattage, and tested ballasts to establish an appropriate max tech 

level for this wattage. DOE also conducted additional testing of the 70 W, 250 W, 400 W, 

and 1000 W ballasts on the market, and determined the highest efficiency levels that are 

technologically feasible within each equipment class. As discussed in section V.C.9, data 

for each equipment class has been fit with a wattage-efficiency equation to determine the 

minimum efficiency levels. Table IV.1 presents the max tech efficiencies for each 

wattage range analyzed in the NOPR.

Table IV.1 Max Tech Levels

Equipment Class 

Wattage Range

Efficiency 

Level*

Efficiency Level Equation

%

≥50 and ≤100 EL4 1100/(1+0.36∗P^(-0.3))†

≥>100 and <150* EL4 1100/(1+0.36∗P^(-0.3))

≥150** and ≤250 EL4 1100/(1+0.36∗P^(-0.3))

>250 and ≤500 EL4 1100/(1+0.36∗P^(-0.3))

>500 and ≤2000 EL2

For >500 W to <1000 W:

3.2∗10^(-53)∗P + 089.9

For ≥1000 W to ≤2000 W: 92.5%93.1

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; that are also rated for use in wet 

locations, as specified by the National Electrical Code 2002, section 410.4(A); and containcontaining a ballast that is rated to operate at 

ambient air temperatures above 50 °C, as specified by UL 1029–2001. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; that are also rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

†P is defined as the rated wattage of the lamp that the fixture is designed to operate

75
DOE requests comment on its selection of the max tech levels and whether it is 

technologically feasible to attain these high efficiencies. Specifically, DOE seeks data on 

the potential change in efficiency, the design options employed, and the associated 

change in cost. Any design option that DOE considers to improve efficiency must meet 

the four criteria outlined in the screening analysis: technological feasibility; practicability 

to manufacture, install, and service; adverse impacts on product or equipment utility to 

consumerscustomers or availability; and adverse impacts on health or safety. DOE also 

requests comment on any technological barriers to an improvement in efficiency above 

the max tech efficiency levels for all or certain types of ballasts.

C. Energy Savings

1. DOE used its national impact analysis spreadsheet to estimateDetermination of 

Savings

For each TSL, DOE projected energy savings from new or amended standards for 

the metal halide lamp fixturesequipment that are the subject of this rulemaking. (The NIA 

spreadsheet model is described purchased in section of this proposed rule and in chapter 

11 of the NOPR TSD.) DOE forecasted energy savings beginning in 2015, 30-year period 

that begins in the year thatof compliance with new or amended standards (2016–2045). 

The savings are measured over the new and amended standards is required, and ending in 

2044 for each TSL.entire lifetime of products purchased in the 30-year period.22 DOE 

22 In the past DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings 

measured over the entire lifetime of equipment purchased in the 30-year period. DOE has chosen to modify 

its presentation of national energy savings to be consistent with the approach used for its national economic 

analysis.

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quantified the energy savings attributable to each TSL as the difference in energy 

consumption between aeach standards case and the base case. The base case is the 

forecastrepresents a projection of energy consumption in the absence of new and 

amended mandatory efficiency standards, and considers market forces and policies that 

affect demand for higher-efficiency products.more efficient equipment. For example, 

DOE models in the base case, DOE models a migration from covered metal halide lamp 

fixtures to higher-efficiency technologies such as high-intensity fluorescent (HIF), 

induction (integrally ballasted fluorescent) lights, and light-emitting diodes (LEDs). DOE 

also models in the base case a move to other HID fixtures such as high-pressure sodium, 

based on data given by manufacturers during the 2010 framework public meeting. 

(Philips, Public Meeting Transcript, No.8 at p. 91)

DOE used its NIA spreadsheet to estimate energy savings from new or amended

standards for the metal halide lamp fixtures that are the subject of this rulemaking. The 

NIA spreadsheet model (described in section V.G of this notice and in chapter 11 of the 

NOPR TSD) calculates the electricityenergy savings in “site energy” expressed in 

kilowatt-hours (kWh). Site energy , which is the energy delivered to and used directly 

consumed by metal halide lamp fixtures products at the locations where they are 

operated. To compileused. DOE reports national energy savings on an annual energy 

savings, DOE uses aggregated basis in terms of the source (primary) energy savings, 

which are onis the savings in the energy requiredthat is used to generate and transmit the 

site energy. (See NOPR TSD chapter 11.) To convert site energy to source (primary) 

energy, DOE derived time-dependentannual conversion factors from the model used to 

77
prepare the Energy Information Administration’s (EIA’sEIA) Annual Energy Outlook 

2013 (AEO2013).

DOE has begun to also estimate energy savings using full-fuel-cycle metrics. The 

full-fuel-cycle (FFC) metric includes the energy consumed in extracting, processing, and 

transporting primary fuels, and, thus, presents a more complete picture of the impacts of 

efficiency standards. DOE’s approach is based on application of FFC multipliers for each 

fuel type used by covered products and equipment, as discussed in DOE’s statement of 

policy published in the Federal Register on August 18, 2011 (AEO2011) reference 

case.76 FR 51281), and in the notice of policy amendment. 77 FR 49701 (August 17, 

2012).

2. EPCA prohibitsSignificance of Savings

As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard 

that for a covered product unless such standard would not result in “significant” energy 

savings. Although the term “significant” is not defined in the Act, the U.S. Court of 

Appeals, in Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 1373

(D.C. Cir. additional energy savings23. The estimated energy savings in the 30-year 

analysis period for the 1985), indicated that Congress intended “significant” energy 

savings in this context to be savings that were not “genuinely trivial.” The energy savings 

for all of the TSLs considered in this rulemaking (presented in section VI.B.3range from 

23 While the term “significant” is not defined in the Act, the U.S. Court of Appeals, in Natural Resources 

Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended 

“significant” energy savings in this context to be savings that were not “genuinely trivial.”

78

 
0.3 to 0.4 quads, an amount) are nontrivial, and, therefore, DOE considers them 

“significant” within the meaning of section 325 of EPCA.

D. Economic Justification

1. Specific Criteria

As noted in section II.A, EPCA provides seven factors to be evaluated in 

determining whether a potential energy conservation standard is economically justified. 

(42 U.S.C. 6295(o)(2)(B)) The following sections discuss how DOE addresses each of 

those seven factors in this rulemaking.

a. Economic Impact on Manufacturers and ConsumersCustomers

In determining the impacts of a new or amended standard on manufacturers, DOE 

first determines quantitative impacts using an annual-cash-flow approach. This approach 

includes both a short-term assessment—based on the cost and capital requirements during 

the period between the announcement of a regulation and when the regulation comes into 

effect—and a long-term (30-year) assessment. The quantitative impacts analyzed include 

INPV (which values the industry based on expected future cash flows), annual cash 

flows, and changes in revenue and income. Second, DOE analyzes and reports the 

impacts on different types of manufacturers, including an analysis of impacts on small 

manufacturers. Third, DOE considers the impact of standards on overall and technologyspecific domestic manufacturer employment and manufacturing capacity, as well as the 

potential for standards to result in plant closures and loss of capital investment for 

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technology-specific manufacturers. DOE also takes into account cumulative impacts of 

different DOE regulations and other regulatory requirements on manufacturers.

For individual consumerscustomers, measures of economic impact include the 

changes in LCC and PBP associated with new or amended standards. LCC is separately 

specified as one of the seven factors to consider when determining the economic 

justification for a new or amended standard (42 U.S.C. 6295(o)(2)(B)(i)(II)), and is 

discussed in the following section. For consumerscustomers viewed from a national 

perspective, DOE calculates the net present value of the economic impacts on them over 

the 30-year forecastequipment shipments period used in this rulemaking.

b. Life-Cycle Costs

The LCC is the sum of the purchase price of a fixture (including its installation) 

and its operating expenses (including energy, maintenance, and repair expenditures) 

discounted over the lifetime of the fixture. The LCC savings for the considered efficiency 

levels are calculated relative to a base case that reflects likely trends in the absence of 

new or amended standards. The LCC analysis required a variety of inputs, such as 

equipment prices, equipment energy consumption, energy prices, maintenance and repair 

costs, equipment lifetimes, and consumercustomer discount rates. DOE assumed in its 

analysis that consumerscustomers purchase the productequipment in 20152016.

To account for uncertainty and variability in specific inputs, such as equipment 

lifetime and discount rate, rather than using a single value in its estimates, DOE uses a 

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distribution of values, with probabilities attached to each value. By using this approach 

DOE can identifyidentifies the percentage of consumerscustomers estimated to 

achievereceive LCC savings or experiencingexperience an LCC increase, in addition to 

the average LCC savings associated with a particular standard level. In addition to 

identifying ranges of impacts, DOE can also evaluateevaluates the LCC impacts of 

potential standards on sub-groups of consumersidentifiable subgroups of customers that 

may be affected disproportionately affected by a national standard.

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement 

for imposing an energy conservation standard, EPCA requires DOE, in determining the 

economic justification of a standard, to consider the total projected energy savings that 

are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As 

discussed in section V.G, DOE uses the NIA spreadsheet to project national energy 

savings.

d. Lessening of Utility or Performance of Products

In establishing classes of equipment and evaluating design options and the impact 

of potential standard levels, DOE seeks to develop standards that would not lessen the 

utility or performance of the equipment under consideration. The efficiency levels 

considered in today’s NOPR will not affect features valued by consumers, such as 

starting method, ballast factor, or cold temperature operation.customers, such as input 

voltage and light output. Therefore, DOE believes that none of the TSLs presented in 

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section VI.A would reduce the utility or performance of the ballasts considered in the 

rulemaking. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) 

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider any lessening of competition likely to result from 

standards. It directs the Attorney General to determine the impact, if any, of any 

lessening of competition likely to result from a proposed standard and to transmit this 

determination to the Secretary, not later than 60 days after the publication of a proposed 

rule, together with an analysis of the nature and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) DOE has transmitted a copy of today’s proposed rule to 

the Attorney General and has requested that the Department of Justice (DOJ) provide its 

determination on this issue. DOE will address the Attorney General’s determination in 

any final rule.

f. Need of the Nation to Conservefor National Energy Conservation

The non-monetary benefits ofenergy savings from the proposed standards are 

likely to provide improvements to the security and reliability of the nation’s energy 

system. Reductions in the demand for electricity also may result in reduced costs for 

maintaining the reliability of the nation’s electricity system. DOE conducts a utility 

impact analysis to estimate how standards may affect the nation’s needed power 

generation capacity.

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The proposed standards also are likely to result in environmental benefits in the 

form of reduced emissions of air pollutants and greenhouse gases associated with energy 

production. DOE reports the environmental effectsemissions impacts from today’s 

proposed standards, and from each TSL it considered, in section VI.B.6—in the 

environmental assessment contained in the NOPR TSD. of this notice. DOE also reports 

estimates of the economic value of emissions reductions resulting from the considered 

TSLs.

g. Other Factors

EPCA allows the Secretary to consider any other relevant factors in determining 

whether a standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) Under 

this provision, DOE considered subgroups of consumerscustomers that may beexperience

disproportionately adversely affected byadverse effects under the standards proposed in 

this rule. DOE specifically assessed the impacteffect of standards on low-income 

consumers, institutions of religious worshiputilities, transportation facility owners, and 

institutions that serve low-income populationswarehouse owners. In considering these 

subgroups, DOE analyzed differences in electricity prices, operating hours, discount 

rates, and baseline ballasts. See section V.H for further detail.

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA provides forcreates a 

rebuttable presumption that an energy conservation standard is economically justified if 

the additional cost to the consumercustomer of a productequipment that meets the 

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standard is less than three times the value of the first-year year’s energy (and, as 

applicable, water) savings resulting from the standard, as calculated under the applicable 

DOE test procedure. DOE’s LCC and PBP analyses generate values thatused to calculate 

the payback period for consumers of potential new and amendedeffects that proposed

energy conservation standards, including would have on the payback period for 

customers. These analyses include, but are not limited to, the 3-year payback period from 

contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts 

an economic analysis that considers the full range of impacts to the consumer, 

manufacturer,customers, manufacturers, the nation, and the environment, as required 

under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis enable DOE to evaluate 

definitivelyserve as the basis for DOE’s evaluation of the economic justification for a 

potential standard level (thereby supporting or rebutting the results of any preliminary 

determination of economic justification). The rebuttable presumption payback calculation 

is discussed in section VI.B.1 of this NOPR.

V. Methodology and Discussion 

DOE used two spreadsheet tools to estimate the impact of today’s proposed 

standards. The first spreadsheet tool calculates LCCs and PBPs of potential new energy 

conservation standards. The second spreadsheet tool provides shipments 

forecastsshipment projections and then calculates national energy savings and net present 

value impacts of potential new energy conservation standards. The Department also 

assessed manufacturer impacts, largely through use of the Government Regulatory 

Impact Model (GRIM). 

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Additionally, DOE estimated the impacts of energy efficiency standards on 

utilities and the environment. DOE used a version of EIA’s National Energy Modeling 

System (NEMS) for the utility and environmental analyses. The NEMS model simulates 

the energy sector of the U.S. economy. EIA uses NEMS to prepare its Annual Energy 

Outlook, a widely known reference energy forecast for the United States. The NEMSbased model used for appliance standards analysis is called NEMS-BT (BT stands for 

DOE’s Building Technologies Program), and is based on the AEO2011current AEO 

(AEO2013) NEMS with minor modifications.24 The NEMS-BT accounts for the 

interactions between the various energy supply and demand sectors and the economy as a 

whole. For more information on NEMS, refer to The National Energy Modeling System: 

An Overview, DOE/EIA–0581 (98) (Feb.1998), available at: 

tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf.

A. Market and Technology Assessment

1. General

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the equipment concerned, 

including the purpose of the products, the industry structure, and the market 

characteristics. This activity includes both quantitative and qualitative assessments based 

on publicly available information. The subjects addressed in the market and technology 

24 The EIA does not approve use of the name “NEMS” unless it describes an AEO version of the model 

without any modification to code or data. Because the present analysis entails some minor code 

modifications and runs the model under various policy scenarios that deviate from AEO assumptions, the 

name “NEMS-BT” refers to the model as used here.

85

 
assessment for this rulemaking include: equipment classes and manufacturers; historical 

shipments; market trends; regulatory and non-regulatory programs; and technologies or 

design options that could improve the energy efficiency of the product(s) under 

examination. See chapter 3 of the NOPR TSD for further discussion of the market and 

technology assessment.

2. Equipment Classes

In establishing energy conservation standards, DOE divides covered equipment 

into classes by: (a) the type of energy used, (b) the capacity of the equipment, or (c) any 

other performance-related feature that justifies different standard levels, such as features 

affecting consumer utility. (42 U.S.C. 6295(q)) DOE then considers establishing separate 

standard levels for each equipment class based on the criteria set forth in 42 U.S.C. 

6295(o).

In the preliminary analysis, DOE considered several potential class-setting factors 

for fixtures, including rated lamp wattage, input voltage, number of lamps operated, 

starting method, electronic configuration, circuit type, and fixture application. DOE 

preliminarily determined that rated lamp wattage was the only factor affecting both 

consumer utility and efficiency. DOE, therefore, analyzed four equipment classes for 

fixtures with rated lamp wattages: (1) greater than or equal to 50 W and less than 150 W; 

(2) greater than or equal to 150 W and less than or equal to 250 W; (3) greater than 250 

W and less than or equal to 500 W; and (4) greater than 500 W. As discussed in the 

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following sections, several interested parties commented on the preliminary equipment 

classes and the other class-setting factors that DOE considered.

a. Input Voltage

Metal halide lamp fixtures are available in a variety of input voltages (such as 120 

V, 208 V, 240 V, 277 V, and 480 V), and the majority of fixtures are equipped with 

ballasts that are capable of operating at multiple input voltages (for example quad-inputvoltage ballasts are able to operate at 120 V, 208 V, 240 V, and 277 V). DOE determined 

that input voltage represents a feature affecting consumer utility as certain applications 

demand specific input voltages. Although input voltage can affect ballast resistive losses 

and thus, efficiency, for the preliminary analysis, DOE’s ballast testing did not indicate a 

prevailing relationship (e.g., higher voltages are not always more efficient) between 

discrete input voltages and ballast efficiencies. Therefore, in the preliminary analysis, 

DOE did not establish separate equipment classes for metal halide lamp fixtures based on 

input voltage. In the preliminary analysis, DOE suggested that efficiency be represented 

by the average of tested efficiencies at each of the input voltages at which the ballast is 

rated for operation.

In response to the preliminary analysis, DOE received several comments 

supporting and opposing input voltage as a class-setting criterion. NEMA noted that 

multiple-input-voltage ballasts are often optimized for the most popular voltage 

application. For example, a quint-input-voltage ballast (able to operate at five different 

input voltages) will often have a lower efficiency at 480 V than at 277 V because the 

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ballast is optimized for 277 V operation. NEMA suggested that 480 V-capable ballasts be 

given an efficiency allowance, or that all ballasts be allowed to be tested at the optimal 

operating voltage as specified by the manufacturer. (NEMA, No. 34 at p. 10) Georgia 

Power also commented that due to their increased costs relative to non-480 V ballasts, 

dedicated 480 V and quint-input-voltage ballasts should be in a separate equipment class. 

(Georgia Power, No. 28 at p. 1) Progress Energy Carolinas agreed that separate 

equipment classes should be established for ballasts above 300 V. (Progress Energy 

Carolinas, No. 24 at p. 2) NEEA found that voltage does not appear to be a significant 

factor in energy efficiency performance or system utility. However, NEEA had no 

objection to treating 480 V systems as a separate class, should DOE choose to do so. 

(NEEA, No. 31 at p. 3) Empower Electronics commented that a separate classification 

based on input voltage is not needed. (Empower Electronics, No. 36 at p. 5) 

As discussed in section IV.A of this NOPR, DOE is proposing that metal halide 

ballasts be tested at a single input voltage, based on the lamp wattage operated by the 

ballast. Ballasts that operate lamps 150 W or less would be tested at 120 V, and all others 

would be tested at 277 V, unless the ballast is incapable of operating at the specified 

input voltage; in that case, the ballast would be tested at the highest input voltage 

possible. DOE’s view is that this proposal would reduce the testing burden and better 

characterize the energy consumption of metal halide lamp fixtures for the majority of 

applications in which they are installed. Based on the proposed test procedures, DOE 

evaluated efficiency differences between dedicated 480 V, quint-input-voltage, and quadinput-voltage ballasts (which represent the vast majority of ballasts on the market). DOE 

88
found that the quint-input-voltage ballasts had similar efficiencies as the quad-inputvoltage ballasts when both were tested at 120 V or 277 V. In contrast, DOE found that 

the dedicated 480 V ballasts (tested at 480 V) were, on average, 1.4 percent less efficient 

than quad-input-voltage ballasts (tested at 120 V or 277 V).

Because dedicated 480 V ballasts have a distinct utility and a difference in 

efficiency relative to ballasts tested at 120 V and 277 V, DOE proposes separate 

equipment classes for ballasts tested at 480 V (in accordance with the test procedures). 

These would include dedicated 480 V ballasts and any ballasts that are capable of being 

operated at 480 V, but incapable of being operated at the input voltage specified by the 

test procedures (either 120 V or 277 V, depending on lamp wattage). DOE requests 

comment on this proposal.

b. Fixture Application

Metal halide lamp fixtures are used in a variety of applications such as parking 

lots, roadways, warehouses, big-box retail, and flood lighting. Although the fixture size, 

shape, and optics are often tailored to the application, generally the same types of ballasts 

are currently utilized for most of the applications. DOE did not expect fixtureapplication-related attributes to affect ballast efficiency for a given lamp wattage, and in 

the preliminary analysis DOE did not analyze separate equipment classes based on such 

attributes.

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In response to the preliminary analysis, DOE received several comments 

regarding the problems of utilizing electronic ballasts in outdoor applications and 

recommending that DOE establish separate equipment classes for outdoor fixtures and 

indoor fixtures. Energy Solutions noted that there are significant fixture design 

considerations necessitated by outdoor use. (Energy Solutions, Public Meeting 

Transcript, No. 33 at pp. 46-47) Progress Energy Carolinas clarified that ballasts used in 

outdoor fixtures need to be able to withstand high temperatures, voltage variations, and 

lightning and other voltage surges. Progress Energy Carolinas also indicated that the 

same concerns existed with LED fixtures (utilizing electronic drivers) and that they were 

successfully addressed by adding heat sinks to dissipate excess heat; building regulation 

into the drivers to deal with voltage variations; and adding metal oxide varistor (MOV) 

protection (typically 10 kilo volt [kV] ANSI C62.41.1-200225 Class C protection) to 

protect against lightning and other voltage surges. LED fixtures also underwent field 

testing through all four seasons to prove overall reliability. Progress Energy Carolinas 

explained that until some of these issues are similarly addressed and their solutions 

proven, end users will be reluctant to use electronic metal halide ballasts in outdoor 

fixtures. (Progress Energy Carolinas, No. 24 at p. 1) Georgia Power and Progress Energy 

Carolinas stated that outdoor electronic metal halide ballasts have not been widely 

adopted by utilities, largely due to these reliability concerns. NEMA urged DOE to 

establish MHLF standards for outdoor applications (which have higher transient 

requirements and wider operating temperature ranges) such that magnetic ballasts would 

be compliant. (NEMA, No. 34 at p. 9) If electronic ballasts are mandated for outdoor 

25 “Institute of Electrical and Electronics Engineers Guide on the Surge Environment in Low-Voltage (1000

V and Less) AC Power Circuits,” Approved April 4, 2003.

90

 
fixtures, Progress Energy Carolinas recommended that utilities be exempt until reliability 

concerns decrease. (Georgia Power, No. 28 at p. 2; Progress Energy Carolinas, No. 24 at

p. 2)

The CA IOUs, however, stated that electronic ballasts have been successfully 

applied in outdoor applications and are readily available on the market today, citing 

examples of commercially available electronic metal halide products rated for outdoor

use and municipalities that have adopted electronically ballasted metal halide streetlights. 

The CA IOUs expressed their belief that the application environment does not affect the 

utility or the achievable efficiency of a ballast. The CA IOUs also stated that should DOE 

decide that the use of electronic ballasts in outdoor environments requires additional 

fixture modifications, DOE would need to conduct separate cost and savings analyses for 

indoor versus outdoor applications. If DOE decides to set different equipment classes for 

indoor and outdoor metal halide lamp fixtures, the CA IOUs suggested that DOE adopt 

California’s approach for differentiation of these types by specifying fixtures that are 

“UL 1598 Wet Location Listed and labeled ‘Suitable for Wet Locations’ as specified by 

the National Electrical Code [NEC] 2005, Section 410.4(A).” (CA IOUs, No. 32 at pp. 2-

3)

Although electronic ballasts are being successfully used in certain outdoor 

applications, DOE acknowledges that there is currently a market reluctance to use 

electronic metal halide ballasts in outdoor applications, particularly due to concerns with 

the electronic ballast’s ability to withstand voltage transients. However, DOE disagrees 

91
with NEMA that an efficiency level that requires electronic ballasts should not be 

analyzed or proposed on the basis of the features of transient suppression and operating 

temperature ranges. DOE’s view is that addressing these concerns with either (1) an 

external surge protection device or (2) internal transient protection of the ballast using 

MOVs in conjunction with other inductors and capacitors or with an external surge 

protection device is technologically feasible, as shown by the CA IOUs’ list of examples, 

to address these concerns either with internal transient protection to the ballast using 

MOVs in conjunction with other inductors and capacitors or with an external surge 

protection device. DOE understands that this added protection also adds an incremental 

cost to the ballast or fixture (further discussed in section V.C.12). As these incremental 

costs could affect the cost effectiveness of fixtures for outdoor applications, DOE 

proposes separate equipment classes for indoor and outdoor fixtures. DOE proposes that

outdoor fixtures be defined as those that (1) are rated for use in wet locations and (2) 

have 10 kV of voltage transient protection. Conversely, fixtures that do not meet these 

requirements will be defined as indoor fixtures.

DOE proposes to define the wet location rating as labeled for use in wet locations 

as specified by the National Electrical Code 2011,

26 section 410.10(A) or Underwriters 

Laboratories (UL) 1598 Wet Location Listed.

27 DOE believes that providing two possible 

26 The NEC 2011 states that fixtures installed in wet or damp locations shall be installed such that water 

cannot enter or accumulate in wiring components, lampholders, or other electrical parts. All fixtures 

installed in wet locations shall be marked, “Suitable for Wet Locations.” All fixtures installed in damp 

locations shall be marked “Suitable for Wet locations” or “Suitable for Damp Locations.”

27 UL Standard Publication 1598 defines a wet location is one in which water or other liquid can drip, 

splash, or flow on or against electrical equipment. A wet location fixture shall be constructed to prevent the 

accumulation of water on live parts, electrical components, or conductors not identified for use in contact 

92

 
definitions will reduce the compliance burden as many manufacturers are already familiar 

with one or both of these ratings (the NEC definition was included in EISA 2007 and 

both are used in California energy efficiency regulations). For 10 kV voltage transient 

protection, DOE proposes to use the 10 kV voltage pulse withstand requirement from 

ANSI C136.2-2004 as a characteristic unique to outdoor fixtures. As discussed in section 

VI.C This standard specifies that outdoor fixtures must be rated to withstand a 10 kV 

pulse. , based on weighing the benefits and drawbacks of different requirements, DOE is 

proposing efficiency standards that are the same for indoor and outdoor equipment 

classes. If a different requirement is ultimately adopted by DOE in the final rule, the 

definitions of indoor and outdoor will be added to the Code of Federal Regulations for 

metal halide lamp fixtures.

c. Electronic Configuration and Circuit Type

Of the two metal halide ballast types (electronic and magnetic), magnetic ballasts

are currently more common. Magnetic ballasts typically use transformer-like copper or 

aluminum windings on a steel or iron core. The newer electronic ballasts, which are more 

efficient but less common, rely on electronic filtersintegrated circuits, switches, and 

capacitors/inductors to control current and voltage to the lamp. Both electronic and 

magnetic ballasts are capable of producing the same light output and, with certain 

modifications (e.g., thermal management, transient protection, 120 V auxiliary power 

functionality), can be used interchangeably in all applications.

with water. A luminairefixture that permits water to enter the luminairefixture shall be provided with a 

drain hole.

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Magnetic metal halide ballasts are available in the market in several types of 

circuit configurations including high-reactance autotransformer, constant-wattage 

isolated transformer, constant-wattage autotransformer (CWA), linear reactor (reactor), 

and magnetically regulated-lag (reg-lag or mag-reg) ballasts. Each magnetic circuit type 

listed has different characteristics that may be preferred in certain applications. These 

characteristics (discussed further in chapter 3 of the NOPR TSD) include size, efficiency, 

and power regulation. For example, magnetically regulated-lag ballasts are typically the 

largest and heaviest circuit type, but provide the greatest degree of resistance to input

voltage variation (which sustains light output). In the preliminary analysis, DOE 

determined that although magnetic ballasts are usually less efficient and have a lower 

initial cost than electronic ballasts, neither configuration provides a distinct consumer

utility over the other. Because electronic ballasts can provide the same utility as any 

magnetic circuit type, can be used as substitutes in all applications, and are generally 

more efficient than magnetic ballasts, DOE determined in the preliminary analysis that 

setting separate equipment classes based on electronic configuration (magnetic vs. 

electronic) or on circuit type was unnecessary. 

At wattages greater than 500 W, few electronic ballasts are available due to their 

higher cost and lower expected efficiency improvement over magnetic ballasts. Electronic 

ballasts have two primary circuit types, either driving that operate the lamp at either “high” or 

“low” frequency. DOE defines a lampproposes to be driven atdefine a high-frequency once 

theballast to be a ballast with output frequency from the ballast to the lamp is greater than or 

equal to 1000 Hz. For low-frequency electronic ballasts, a square current waveform is used to 

94
diminish acoustic resonance and maintain lamp life. All lamps operate well on low-frequency 

square waves, so these low-frequency ballasts have few compatibility issues with lamps. 

Above 300 HzAt higher frequencies, however, acoustic resonance issues and electromagnetic 

interference (EMI) effects cause compatibility issues with lamps. At these high frequencies, 

ballasts have to be designed to have the right frequency for a desired lamp, but the selected 

frequency may be incompatible with other lamps designed for different frequencies. 

Therefore, high-frequency electronic ballasts are less widely compatible with lamps relative 

to low-frequency electronic ballasts. High-frequency ballasts may also have difficulty 

complying with Federal Communications Commission (FCC) standards.28 

In response to DOE’s preliminary determination not to use electronic 

configuration or circuit type as a class-setting factor, DOE received several comments 

relating to replacement of magnetic ballasts with electronic ballasts, possible reliability 

issues with electronic ballasts, and non-efficiency-related benefits to using electronic 

ballasts. Cooper Lighting stated that electronic ballasts are not direct replacements for 

magnetic ballasts in fixtures. (Cooper Lighting, Public Meeting Transcript, No. 33 at p. 

64) With regard to reliability, Georgia Power said that (1) electronic ballasts are 

unproven in outdoor applications and (2) electronic ballasts are vulnerable to failures due 

to high temperature, moisture, and voltage variations and surges caused by lightning and 

other outdoor events. Progress Energy Carolinas did not disagree with including 

28 FCC regulations at 47 CFR part 18, subpart C set forth technical standards for industrial, scientific, and 

medical equipment that specify frequency bands and tolerance ranges tolerances as well as electromagnetic 

fieldsfield strength limits. Some metal halide ballasts may be covered under these “industrial, scientific, 

and medical (ISM) equipment” standards, which list the general operating conditions for ISM equipment. 

Ballasts designed to exceed 9 kHz ballast frequency have to be designed so that interference with 

transmitted radio frequencies is eliminated. 47 CFR 18.111, 18.301-11

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electronic and magnetically ballasted fixtures in the same equipment class, but 

commented that the expected energy savings are small. They stated that other operating 

characteristics drive the use of electronic ballasts for metal halide system forin indoor 

applications (i.e., CCTcorrelated color temperature variation, LLDlamp lumen 

depreciation, and dimming). (Progress Energy Carolinas, No. 24 at p. 2) The CA IOUs 

agreed with Georgia Power that electronic ballasts, especially in conjunction with pulsestart ceramic metal halide lamps that offer higher efficacy and improved color rendering 

index (CRI), have other advantages that can offset their added cost. The CA IOUs also 

stated that electronic ballasts do save energy relative to magnetically ballasted systems. 

(CA IOUs, No. 32 at p. 4) Finally, Empower Electronics supported DOE’s preliminary 

determination, stating that equipment classes need not be set according to electronic 

configuration and circuit type. (Empower Electronics, No. 36 at p. 6) 

As discussed in section V.C.12, DOE recognizes the technological differences 

between magnetic and electronic ballasts and has incorporated the cost of additional 

devices or modifications necessary for certain applications into its analysis. In section 

V.I.2, DOE addresses impacts on manufacturers of a transition to electronic ballasts, but 

does not consider these impacts in development of equipment classes. While 

acknowledging that consumerscustomers make purchasing decisions on electronic versus 

magnetic ballasts after consideration of other parameters in addition to efficiency, DOE 

has determined that significant energy savings can be realized through a transition from 

magnetic to electronic ballasts (see section VI.B.3). For this NOPR, DOE maintains that 

electronic configuration does not affect consumer utility because with the necessary 

96
design adders, electronic ballasts can provide the same utility (with additional features) as 

magnetic ballasts. Because of this, DOE is not proposing to define equipment classes 

based on electronic configuration and requests comment on this matter. 

d. Lamp Wattage

As lamp wattage increases, lamp and ballast systems generally (but not always) 

produce increasing amounts of light (lumens). The goal of efficiency standards is to 

decrease the wattage needed for the same lumens—resulting in an increase in energy 

efficiency. Because certain applications require more light than others, wattage often 

varies by application. For example, low-wattage (less than 150 W) lamps are used today 

in commercial and some residential, applications for general lighting. Medium-wattage 

(150-500 W) lamps are the most widely used today and include warehouse, street, and 

general commercial lighting. High-wattage (greater than 500 W) lamps are used today in 

searchlights, stadiums, and other applications that require powerful white light. In the 

preliminary analysis, based on its impact on light output, DOE determined that the lamp 

wattage affects consumer utility. DOE also determined that the wattage of the lamp in a

lamp and operated by a ballast system has a correlation tois correlated with the ballast

efficiency, which generally increases atfor higher lamp wattages-wattage loads. For 

electronic ballasts, this efficiency gain can be attributed to the decreasing proportion of 

fixed losses (e.g., switches) to total losses. For low-wattage electronic ballasts, certain 

fixed losses contribute a larger proportion of total losses than they do for high-wattage 

ballasts. Magnetic ballasts--essentially transformers (sometimes with capacitors for 

power correction and igniters for pulse-starting)--have proportionally lower overall losses 

97
with increased wattage. Transformer losses (resistive losses in windings, eddy currents, 

and hysteresis) do not scale linearly with wattage, meaning that overall efficiency 

increases with wattage. Because wattage affects consumer utility (lumen output) and has 

a strong correlation to efficiency, DOE determined that separate equipment classes based 

on wattage were warranted. As a result in the preliminary analysis, DOE analyzed four 

lamp wattage class bins: ≥50 W and <150 W, ≥150 W and ≤250 W, >250 W and ≤500 

W, and >500 W. 

NEEA, Empower Electronics, and Progress Energy Carolinas supported DOE’s 

determination in the preliminary analysis that wattage can determineshould be a classsetting factor. (NEEA, No. 31 at p. 3; Empower Electronics, No. 36 at p. 7; Progress 

Energy Carolinas, No. 24 at p. 3) Because no adverse comments were received on DOE’s 

determination, DOE proposes to continue using lamp wattage as a class-setting factor for 

this NOPR.

For the NOPR, DOE found that even within a designated wattage range (such as 

between 100 W and 150 W), the potential efficiencies manufacturers can reach is not 

constant, but rather varies with wattage. Instead of setting a constant efficiency standard 

within a wattage bin, DOE is proposing the use of an equation-based energy conservation 

standard for certain equipment classes (see section V.C). DOE is also continuing to use 

wattage bins (instead of a single equation spanning the entire covered wattage range) to 

define equipment classes, for two reasons. First, the range of ballast efficiencies 

considered can differ significantly by lamp wattage, thus making it difficult to construct a 

98
single continuous equation for ballast efficiency from 50 W to 2000 W. This efficiency 

difference can be attributed to the varying cost of increasing ballast efficiency for 

different wattages and the impact of legislated (EISA 2007) standards that affect only 

some wattage ranges. Defining equipment classes based on wattage is still necessary. 

Second, different wattages often serve different applications and have unique costefficiency relationships. Analyzing each wattage range as a separate equipment class 

allows DOE to establish the energy conservation standards that are cost-effective for each 

wattage bin.

DOE also received comment that certain wattage ranges used in the preliminary 

analysis should be further divided. Progress Energy Carolinas commented that further 

division of the 50 W to 250 W equipment class was warranted on the basis of different 

levels of efficiency being possible for different wattages. (Progress Energy Carolinas, No. 

24 at p. 1) For this NOPR, DOE determined that the ≥50 W and <150 W range should be 

further subdivided. DOE’s test data indicates that efficiency varies more significantly for 

ballasts that operate 50 W to 150 W lamps than for any other wattage range considered in 

the preliminary TSD. Based on catalog information and manufacturer interviews, DOE 

determined that 50 W and 100 W fixtures typically serve the same applications, while 

150 W products begin to serve applications with increased light demand such as area 

lighting or parking lots. DOE used this natural division in wattage based on application to 

further divide the lowest-wattage range from the preliminary analysis. 

99
With regards to the specification of the boundary between fixtures rated to operate 

at wattages above and below 150 W, Georgia Power commented that 150 W fixtures 

should be included with fixtures less than 150 W, not those greater than 150 W. (Georgia 

Power, No. 2 at p. 2) DOE agrees that some 150 W fixtures (those exempted by EISA 

2007) should be included in the >100 to <150 W equipment classes. As discussed 

previously in section III.A.1, there is an existing EISA 2007 exemption for ballasts rated 

for only 150 W lamps, used in wet locations, and that operate in ambient air temperatures 

higher than 50 °C. This exemption has led to a difference in the commercially available 

efficiencies for ballasts that are exempted or not exempted from EISA 2007. The 

exempted ballasts have a range of efficiencies similar to wattages less than 150 W. 

Ballasts not exempted by EISA 2007 have efficiencies similar to ballasts greater than 150 

W. As a result, DOE is proposing that 150 W fixtures previously exempted from EISA 

2007 be included in a >100 W and <150 W range, while 150 W fixtures subject to EISA 

2007 standards would be included in a ≥150 W to ≤250 W range.

In the preliminary analysis, DOE included all fixtures rated to operate at wattages 

greater than 500 W in the same equipment class. OSI suggested that DOE include 500 W 

ballasts in the highest-wattage range. OSI stated that electronic ballasts that operate 

lamps greater than or equal to 500 W have not been developed yet. (OSI, No. 27 at p. 4) 

In response to the lack of electronic ballasts operating lamps greater than or equal to 500 

W, DOE agrees that there are not commercially available electronic ballasts at these 

wattages today, but also notes that magnetic ballasts are also unavailable at this wattage. 

Because leaving the boundary between these two wattage ranges at 500 W does not affect 

100
any commercially available products, DOE proposes to maintain the >250 W and ≤500 

W range for consistency with the EISA 2007 covered wattage range. 

In summary, DOE is proposing to define metal halide lamp fixture equipment 

classes by rated lamp wattage ranges ≥50 W to ≤100 W, >100 W to <150 W, ≥150 W to 

≤250 W, >250 W to ≤500 W, and >500 W to ≤2000 W. DOE proposes that 150 W 

fixtures previously exempted by EISA 2007 be included in the >100 W to <150 W range, 

while 150 W fixtures subject to EISA 2007 standards continue to be included in the ≥150 

W to ≤250 W range. DOE requests comment on these wattage ranges.

e. Number of Lamps

Metal halide lamp fixtures are commonly designed to operate with a single lamp 

because of lamp characteristics related to re-striking (turning the lamp on again after 

being turned off, because metal halide lamps require time to cool down before being 

lighted again) and voltage regulation. DOE’s review of manufacturer catalogs revealed

that while a majority of available ballasts operate only one lamp, a small fraction are 

designed for two lamps. Based on this review, DOE determined that there is little to no 

change in efficiency between one-lamp and two-lamp metal halide ballast fixtures. In the 

preliminary analysis, DOE determined it unnecessary to consider multiple-lamp ballasts 

in equipment classes separate from single-lamp ballasts. 

NEMA agreed with DOE on the limited number of two-lamp metal halide lamp 

fixtures. Because two-lamp ballasts represent such a small part of the market, NEMA 

suggested they be excluded from the rulemaking. Given the optical size of a metal halide 

101
lamp, NEMA found it unlikely that a manufacturer would use this exemption as a 

loophole. Fixtures using multiple-lamp ballasts would have to be larger, more expensive, 

and less optically efficient than those with single-lamp ballasts. (NEMA, No. 34 at p. 10) 

Because catalog data shows no difference in efficiency, in this NOPR, DOE continues to 

propose including ballasts with differing numbers of lamps in the same equipment class. 

DOE is not proposing to exclude 2-lamp ballasts from the scope of coverage. Ballasts 

that operate 2-lamps are in a category of ballasts that operate any number of lamps rated 

between 50 and 2000 W with the potential for significant energy savings.

f. Starting Method

Metal halide lamp fixtures currently available in the market are designed to 

operate with either probe-start or pulse-start lamplamps, but not a mixture of both types 

of lamps at the same time.29 The main differences between these starting methods are: (1) 

the inclusion of a third probe in probe-start lamps, (2) the need for an igniter circuit for 

pulse-start lamps, and (3) the different wiring specification for ballasts of each starting 

method. Most new applications in the market are pulse-start due to its higher efficacy 

(pulse-start lamps provide more lumens per watt than probe start ballasts). Probe start

ballasts can be replaced by pulse start ballasts with minor changes to the wiring 

specification and configuration within a fixture as well as replacing the probe start lamp 

with a pulse start lamp.-start lamps). In the preliminary analysis, DOE did not consider 

probe versus pulse-starting to be a class-setting factor. While pulse-start lamps are more 

29 DOE is aware of some metal halide lamps that can be operated by a pulse-start or a probe-start ballast. 

These lamps are much less common than lamps designed to be operated by ballasts of only one starting 

method.

102

 
efficacious than probe-start lamps, probe and pulse-start ballasts can achieve the same 

levels of ballast efficiency and are used in similar applications. DOE did not receive any 

adverse comment relating to this preliminary determination, so in this NOPR, DOE 

proposes that both probe and pulse-start ballasts be included in the same equipment class.

EISA 2007 distinguishes nonpulse-start electronic equipment classes by 

separating them into two rated lamp wattage ranges (≥150 W and ≤250 W, and >250 W 

and ≤500 W) and applying a more stringent standard to them than to other ballast types. 

According to DOE’s review of manufacturer catalogs and information provided by 

manufacturers during interviews, nonpulse-start electronic metal halide lamp fixtures are 

not available in the market. While EISA 2007 contemplated the creation of additional 

classes for alternative technologies that could become available in the future, DOE has no 

information that indicates differences in efficiency or consumer utility based on pulsestart versus nonpulse-start ballast fixtures. Based on this information, in the preliminary 

analysis, DOE determined that a separate equipment class for nonpulse-start ballasts was 

unnecessary. DOE did not receive adverse comments relating to this preliminary 

determination, so in this NOPR, DOE is proposing that nonpulse-start electronic ballasts 

be included in the same productequipment class as all other starting methods. The term 

nonpulse-start electronic ballast is currently undefined in the CFR. To avoid confusion, 

DOE is proposing to define ‘nonpulse-start electronic ballast’ in 10 CFR 431.322 as an 

electronic ballast with a starting method other than pulse-start.

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Due to their apparent interchangeability and lack of unique or separate utility that 

would affect efficiency, DOE proposes not to use ballast-starting method as a classsetting feature. 

g. Conclusions

Based on interested party input and additional research, in this NOPR, DOE has 

decided to propose the equipment classes in the following table. DOE has revised the 

wattage bins considered in the preliminary analysis to account for a varying number of 

efficiency levels, different cost-efficiency relationships in the lower wattages, and the 

lack of general lighting applications for wattages higher than 2000 W. Additionally, each 

of these wattage bins is further divided into indoor and outdoor applications to account 

for the difference in consumer utility and the cost-efficiency relationships for these 

application types (see section V.C.12 for further details about the cost adders that effect 

these relationships). Finally, each of these classes is subdivided by input voltage, with 

one class for ballasts tested at 480 V (in accordance with the 2009 test 

procedureprocedures, supplemented with the testing guidance included in this document), 

and the non-480 V ballasts in a separate class. Ballasts tested at 480 V include dedicated 

480 V ballasts and any ballast capable of being operated at 480 V, but incapable of being 

operated at the input voltage specified by the amendments to the test procedures proposed 

in this NOPR (either 120 V or 277 V, depending on lamp wattage). DOE invites 

comments on these proposed equipment classes.

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Table V.1 Metal Halide Lamp Fixture NOPR Equipment Classes

Equipment Classes Rated Lamp Wattage Indoor/Outdoor† Input Voltage Type‡

1 ≥50 W and ≤100 W Indoor Tested at 480 V30

2 ≥50 W and ≤100 W Indoor All others

3 ≥50 W and ≤100 W Outdoor Tested at 480 V

4 ≥50 W and ≤100 W Outdoor All others

5 >100 W and <150 W* Indoor Tested at 480 V

6 >100 W and <150 W* Indoor All others

7 >100 W and <150 W* Outdoor Tested at 480 V

8 >100 W and <150 W* Outdoor All others

9 ≥150 W** and ≤250 W Indoor Tested at 480 V

10 ≥150 W** and ≤250 W Indoor All others

11 ≥150 W** and ≤250 W Outdoor Tested at 480 V

12 ≥150 W** and ≤250 W Outdoor All others

13 >250 W and ≤500 W Indoor Tested at 480 V

14 >250 W and ≤500 W Indoor All others

15 >250 W and ≤500 W Outdoor Tested at 480 V

16 >250 W and ≤500 W Outdoor All others

17 >500 W and ≤2000 W Indoor Tested at 480 V

18 >500 W and ≤2000 W Indoor All others

19 >500 W and ≤2000 W Outdoor Tested at 480 V

20 >500 W and ≤2000 W Outdoor All others

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that are also; rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A);); and containing a ballast that is rated to operate at 

ambient air temperatures above 50 °C, as specified by UL 1029–2001. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, 

as specified by the National Electrical Code 2002, section 410.4(A);); and containing a ballast that is rated to operate at ambient air 

temperatures above 50 °C, as specified by UL 1029–2001.

†DOE’s proposed definitions for “indoor” and “outdoor” metal halide lamp fixtures are described in section V.A.2.

‡Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 

120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these 

voltages would be tested at the highest voltage the ballast is designed to operate. See section IV.A for further detail.

DOE requests comment on the proposed equipment classes.

B. Screening Analysis

For the screening analysis, DOE consults with industry, technical experts, and 

other interested parties to develop a list of designtechnology options for consideration 

and to determine which technology options to consider further and which to screen out.

30 Input voltage for testing as defined in section IV.A.

105

 
Section 325(o)(2) of EPCA requires that any new or revised standard achieve the 

maximum improvement in energy efficiency determined to be technologically feasible 

and economically justified. (42 U.S.C. 6295(o)(2)) Appendix A to subpart C of 10 CFR 

part 430, “Procedures, Interpretations, and Policies for Consideration of New or Revised 

Energy Conservation Standards for Consumer Products” (the Process Rule), sets forth 

procedures to guide DOE in its consideration and promulgation of new or revised energy 

conservation standards. These procedures elaborate on the statutory criteria provided in 

42 U.S.C. 6295(o) and, in part, eliminate problematic technologies early in the process of 

prescribing or amending an energy conservation standard. In particular, sections 4(b)(4) 

and 5(b) of the Process Rule provide guidance to DOE for determining which design 

options are unsuitable for further consideration: 

Technological feasibility. DOE will consider technologies incorporated in 

commercial products or in working prototypes to be technologically feasible.

Practicability to manufacture, install, and service. If mass production and 

reliable installation and servicing of a technology in commercial products could be 

achieved on the scale necessary to serve the relevant market at the time the standard 

comes into effect, then DOE will consider that technology practicable to manufacture, 

install, and service.

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Adverse impacts on product utility or product availability. If DOE determines 

a technology would have significant adverse impacts on the utility of the product to 

significant subgroups of consumers, or would result in the unavailability of any covered

productequipment type with performance characteristics (including reliability), features, 

sizes, capacities, and volumes that are substantially the same as productsequipment

generally available in the United States at the time, it will not consider this technology 

further.

Adverse impacts on health or safety. If DOE determines that a technology will 

have significant adverse impacts on health or safety, it will not consider this technology 

further.

For the preliminary analysis, DOE identified the design options listed in Table 

V.2 as technologies that could improve MHLF ballast efficiency and pass the screening 

criteria discussed above. For further details on these design options, see chapter 3 of the 

NOPR TSD. DOE received several comments, discussed below, in response to the design 

options presented in the preliminary analysis, particularly on “improved core steel” for 

magnetic ballasts and “improved components” for electronic ballasts.

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Table V.2 Metal Halide Lamp Fixture Preliminary Analysis Design Options

Ballast Type Design Option Description

Magnetic

Improved Core Steel

Use a higher grade of electrical steel, including 

grain-oriented silicon or amorphous steel, to lower 

core losses.

Copper Wiring Use copper wiring in place of aluminum wiring to 

lower resistive losses.

Increased Stack Height Add steel laminations to lower core losses.

Increased Conductor Cross-Section Increase conductor cross section to lower winding 

losses.

Electronic Ballast Replace magnetic ballasts with electronic ballasts. 

Electronic

Improved 

Components

Magnetics

Use grain-oriented or amorphous electrical steel to 

reduce core losses.

Use optimized-gauge copper or litz wire to reduce 

winding losses.

Add steel laminations to lower core losses.

Increase conductor cross section to lower winding 

losses.

Diodes Use diodes with lower losses.

Capacitors Use capacitors with a lower effective series 

resistance and output capacitance.

Transistors Use transistors with lower drain-to-source 

resistance.

Improved Circuit 

Design

Integrated 

Circuits

Substitute discrete components with an integrated 

circuit.

DOE received comment on whether improved core steel was a design option or if 

the highest-grade steels are already used in commercially available ballasts. NEEA was 

generally in support of the 13 selected design options and DOE’s decision to not screen 

any of them further. However, NEEA did comment that if higher-grade electrical steels 

are already being utilized in the baseline efficiency ballasts, this may limit DOE’s ability 

to apply “improved core steel” as a design option for improving efficiency. (NEEA, No. 

31 at p. 4) DOE agrees that some ballasts available on the market today already use some 

of the highest grades of grain-oriented core steel available. For example, DOE has 

received feedback that 175 W magnetic ballasts typically require M6 steel, a high-grade, 

grain-oriented steel, to reach 88 percent, the minimum EISA 2007 requirement. (Philips, 

108
Public Meeting Transcript, No. 33 at p. 69-70) However, through manufacturer 

interviews, DOE has learned that there exists significant opportunity for improvement in 

the steels used for other wattage ballasts. Therefore, DOE continues to consider highergrade, grain-oriented silicon steel as a design option to improve magnetic ballast 

efficiency. 

ASAP commented that DOE should evaluate the efficiency potential of using 

amorphous steel in cores for the highest efficiency levels analyzed. (ASAP, Public 

Meeting Transcript, No. 33 at pp. 68-69) Conversely, NEMA stated that amorphous steel 

is neither technologically feasible nor practicable to manufacture for any HID ballast, 

including metal halide ballasts. NEMA commented that distribution transformers are 

linear devices that have relatively simpler core configurations. In contrast, HID 

ballastsaremetal halide ballasts are non-linear devices that require specific flux leakages 

and wave shaping. These unique characteristics are achieved through reconfiguring flux 

pathways within the HIDmetal halide ballast by using flux choke points and leakage 

paths between the primary and secondary circuits. NEMA explained that these 

manipulations of the core are extremely difficult with relatively brittle amorphous steel 

without causing fractures. (NEMA, No. 34 at p. 12) Based on this feedback and the lack 

of any commercially available metal halide ballast or prototype that utilizes amorphous 

steel cores, DOE proposes to screen out amorphous steels within the “improved core 

steel” design option due to the impracticability to manufacture at the scale necessary to 

serve the relevant market. 

109
NEMA also commented that commercially available electronic ballasts already 

utilize the high-quality components. (NEMA, No. 34 at p. 12) Based on its teardown 

analysis and assessment of the components in commercially available metal halide 

electronic ballasts, DOE concurs with NEMA that these ballasts generally use low-loss 

components. However, as discussed in section V.C which describes the Engineering 

Analysis,, DOE found a range of efficiencies commercially available for electronic 

ballasts. As these efficiency differences were, at least in part, due to variations in 

components used, DOE believes that “improved components” is a valid design option 

and continues to consider it in the engineering analysis.

C. Engineering Analysis

1. Approach

The engineering analysis develops cost-efficiency relationships depicting the 

fixture manufacturing costs of achieving increased ballast efficiency. DOE applies two 

methodologies to estimate manufacturing costs for the engineering analysis: (1) the 

design-option approach, which provides the incremental costs of adding the design 

options (e.g., improved core steels) discussed in section V.B to improve the efficiency of

a baseline model; and (2) the efficiency-level approach, which estimates the costs of 

achieving increases in energy efficiency levels, through ballast efficiency testing and 

teardowns, without regard to the design options used to achieve such increases. Details of 

the engineering analysis are in chapter 5 of the NOPR TSD. The following discussion 

summarizes the general steps of the engineering analysis:

110
Determine Representative Equipment Classes. When multiple equipment classes 

exist, to streamline testing and analysis, DOE selects certain classes as “representative” 

primarily because of their high market volumes. DOE then extrapolatesadapts the 

efficiency levels (ELs) from representative equipment classes to those equipment classes 

it does not analyze directly. 

Determine Representative Wattages. Within each representative equipment class, 

DOE also selects a particular wattage fixture as “representative” of the wattage range,

primarily because of their high market volumes. In this NOPR, DOE assigns only one 

representative wattage per representative equipment class.

Representative Fixture Types. To calculate the typical cost of a fixture at each 

representative wattage, DOE selects certain types of fixtures to analyze as representative. 

Select Baseline Units. DOE establishes a baseline unit for each representative 

wattage. The baseline unit has attributes (circuit type, input voltage capability, electronic 

configuration) typical of ballasts used in fixtures of that wattage. The baseline unit also 

has the lowest (base) efficiency for each equipment class. DOE measures changes 

resulting from potential amended energy conservation standards compared with this 

baseline. For fixtures subject to existing Federal energy conservation standards, a 

baseline unit is a metal halide lamp fixture with a commercially available ballast that just 

meets existing standards. If no standard exists for a fixture, the baseline unit is the metal 

halide lamp fixture with a ballast within that equipment class with the lowest tested 

111
ballast efficiency that is sold. To determine energy savings and changes in price, DOE 

compares each higher energy-efficiency level with the baseline unit. 

To determine the ballast efficiency, DOE tested a range of metal halide ballasts 

from multiple ballast manufacturers. Appendix 5A of the NOPR TSD presents the test 

results. In some cases, DOE selects more than one baseline for a representative wattage to 

ensure consideration of different fixture and ballast types and their associated 

consumercustomer economics. 

Select More Efficient Units. DOE selects commercially available metal halide 

lamp fixtures with higher-than-baseline-efficiency ballasts as replacements for each 

baseline model in each representative equipment class. In general, DOE can identify the 

design options associated with each more-efficient ballast model by considering the 12 

design options identified in the technology assessment (chapter 3 of the NOPR TSD) and 

screening analysis (chapter 4 of the NOPR TSD). Where technology design options 

cannot be identified for that class by the product number or catalog description, DOE 

uses a database of commercially available ballasts. DOE then tests these ballasts to 

determine their efficiency. Appendix 5A of the NOPR TSD presents these test results. All 

ballast efficiencies were calculated according to the metal halide ballast test procedures

(10 CFR 431.324) unless otherwise specified. DOE estimates the design options likely to 

be used in the ballast to achieve a higher efficiency based on information gathered during 

manufacturer interviews. interview and information presented in ballast catalogs.

112
Determine Efficiency Levels. DOE develops ELs based on: (1) the design options 

associated with the equipment class studied and (2) the maximum technologically 

feasible (max tech) efficiency level for that class. As just noted and as discussed in 

section IV.B.2, DOE’s efficiency levels are based on catalog data, test data collected 

from commercially available equipment, and manufacturer input.

Conduct Price Analysis. DOE generated a bill of material (BOM) by 

disassembling multiple manufacturers’ ballasts from a range of efficiency levels and 

fixtures that span a range of applications for each equipment class. The BOMs describe 

the equipment in detail, including all manufacturing steps required to make and/or 

assemble each part. DOE then developed a cost model to convert the BOMs for each 

representative unit into manufacturer production costs (MPCs). By applying derived 

manufacturer markups to the MPCs, DOE calculated the manufacturer selling prices31

and constructed industry cost-efficiency curves. In cases where DOE was not able to 

generate a BOM for a given ballast, DOE estimated an MSP based on the relationship 

between teardown data and retail data. DOE also estimated ballast and fixture cost adders 

necessary to allow replacement of more efficient substitutes for baseline models.

2. Representative Equipment Classes

As described above, DOE selects certain equipment classes as “representative” to 

focus its analysis. The 20 equipment classes proposed in this NOPR (based on rated lamp 

31 The MSP is the price at which the manufacturer can recover all production and non-production costs and 

earn a profit. Non-production costs include selling, general, and administration (SG&A) costs, the cost of 

research and development, and interest.

113

 
wattage, test voltage, and indoor or outdoor designation) and the criteria used for 

development are presented in section V.A.2. Due to their low shipment volume (as 

indicated through manufacturer interviews), DOE does not directly analyze the 

equipment classes containing only fixtures with ballasts tested at 480 V. DOE selected all 

other equipment classes as representative, resulting in a total of ten representative classes 

covering the full range of lamp wattages, as well as indoor and outdoor designations. 

3. Representative Wattages

In the preliminary analysis, DOE selected four representative rated wattages of 

fixtures (70 W, 250 W, 400 W, and 1000 W) to analyze in the engineering analysis. Each 

representative wattage was typically the most commonly sold wattage within each 

equipment class, based on analysis of fixture availability from catalogs and manufacturer 

input. DOE received several comments relating to the criteria for representative wattage 

selection, as well as recommendations to change specific wattages analyzed in the 

preliminary analysis. Also, because of the addition of the 101 W to 150 W equipment 

classes (discussed in section V.A.2), DOE proposes to add an additional representative 

wattage at 150 W. These comments and proposed changes are discussed further below.

In general, NEMA recommended that DOE use the lowest-rated-wattage ballast 

to propose energy efficiency levels and the most prevalent model within a class to 

determine the volume of shipments. NEMA explained that the highest attainable 

efficiency for a rated wattage range is determined by the lowest-rated-wattage ballast, 

while in many cases that equipment may not represent the highest volume. OSI explained 

114
that the ballast losses (power dissipated within the ballast) in a lower-rated-wattage 

ballast represent a higher percentage of the total system wattage, thus resulting in lower 

efficiencies at lower rated powers. In particular, NEMA, OSI, and NEEA disagreed with 

the choice of the 250 W fixture as the representative wattage for the 150 W to 250 W 

equipment class, recommending instead 175 W as a more appropriate wattage due to its 

high market share. (OSI, Public Meeting Transcript, No. 33 at p. 54; NEEA, No. 31 at p. 

4; OSI, No. 27 at p. 3; NEMA, No. 34 at p. 13) 

DOE recognizes that lower-rated-wattage ballasts will have lower efficiencies 

than higher-rated-wattage ballasts. To account for this effect in the NOPR, as discussed 

in section V.C.9, DOE is proposing to use equations for each wattage range to define 

minimum efficiency requirements as a function of rated lamp wattage. This equationbased approach allows DOE to, in general, base its selection of representative wattages, 

and thus the resulting economic analysis, on the high-market-share products, while still 

ensuring technological feasibility of the entire equipment class. DOE has continued to 

use 250 W as the representative wattage primarily because it is the only wattage in the 

>150 W to 250 W equipment class with a range of commercially available magnetic 

ballast efficiencies above the EISA 2007 minimum requirements. By conducting a costefficiency analysis on 250 W fixtures, DOE is able to characterize the potential energy 

savings of equipment within this class at efficiency levels below those characterized by 

electronic ballasts.

115
Although 175 W fixtures may currently have high market share, DOE understands 

that EISA 2007 has caused, and may continue to cause, a significant shift from 175 W 

probe-start metal halide fixtures to the 150 W pulse-start fixtures exempted from EISA 

2007 standards. DOE believes that this may result in 250 W fixtures gaining market share 

(relative to 175 W fixtures) in the future. Thus, DOE believes that 250 W is an 

appropriate representative wattage for analysis. 

Because of the current and projected high market share of 150 W fixtures 

exempted from EISA standards, and to match the newly proposed equipment class for 

fixtures rated from 100 W to 150 W (discussed in section V.A.2), DOE has decided to 

add a 150 W representative unit. Based on an assessment of commercially available 

fixtures and manufacturer interviews, DOE has come to the conclusion that 150 W 

fixtures represent the vast majority of the equipment class and, therefore, believes it to be 

an appropriate representative wattage.

In summary, after considering the comments received and changes to the 

proposed equipment class structure, DOE has selected five representative wattages for 

analysis: 70 W, 150 W, 250 W, 400 W, and 1000 W.

4. Representative Fixture Types

After selecting representative wattages for analysis, DOE identified the 

applications commonly served by each equipment class’s wattage range in order to select 

representative fixture types. Although DOE is evaluating ballast efficiency only as a 

116
metric for reducing MHLF energy consumption, DOE recognizes that technological 

changes in the ballast, specifically moving from magnetic ballasts to electronic ballasts, 

can necessitate alterations to the fixture. These changes, discussed in further detail in 

section V.C.12, often incur additional costs dependent on the fixture type that is 

redesigned. In the engineering analysis, DOE estimates a baseline fixture cost as well as 

incremental costs to the fixture (with increasing ballast efficiency) based on the 

representative fixture types selected.

For the preliminary analysis, DOE selected one to three representative fixture 

types for each rated wattage range. For wattages less than 150 W, DOE selected canopy 

fixtures as the representative fixture types. For wattages from 150 W to 250 W, DOE 

identified three representative fixture types: canopy, low-bay, and wallpack. For wattages 

greater than 250 W, DOE chose canopy, flood, and high-bay fixtures as representative 

fixture types.32 Georgia Power commented that DOE should consider post tops as a 

representative fixture for 150 W fixtures. (Georgia Power, No. 28.1 at p. 2) During metal 

halide lamp fixture manufacturer interviews, DOE requested market data on the most 

common fixture types sold for each wattage range analyzed. For the equipment class 

represented by the 150 W fixture, DOE did not receive feedback that post-tops were a 

large portion of that market. Instead, manufacturers responded that area lighting and 

wallpacks comprised the majority of the 150 W market. Thus, for this NOPR, and similar 

to the representative fixtures for the 150 W to 250 W equipment, DOE selected canopy, 

32 Descriptions of each of these fixtures types can be found in chapter 3 of the NOPR TSD.

117

 
low-bay, and wallpack fixtures as representative fixture types for the 100 W to 150 W 

equipment class.

5. Ballast Efficiency Testing

After selecting representative wattages and fixture types, DOE purchased and 

tested a multitude of metal halide ballasts, ranging from low-efficiency magnetic to highefficiency electronic, in order to evaluate the range of commercially available ballast 

efficiencies. In selecting units for testing and analysis, DOE focused its effort on 

representative wattage ballasts with operating characteristics similar to ballasts prevalent 

in the market. For example, through interviews and an assessment of commercially 

available products, DOE learned that the majority of metal halide ballasts sold are quadinput voltage ballasts. Thus, DOE primarily tested metal halide ballasts capable of quadinput or multiple-input voltage operation. 

Regarding magnetic circuit types, Progress Energy Carolinas commented that

there is wide variation between magnetic operating characteristics of the different 

magnetic ballast types, such as regulated, magnetic regulated, CWA, reactor, and highpower-factor reactor. They suggested that DOE study this issue further to ensure proper 

selection of representative units for analysis. (Progress Energy Carolinas, No. 24 at p. 2) 

In response, DOE has investigated the technical differences between magnetic circuit 

types and provides its assessment in Chapter 3 of the NOPR TSD. In addition, through an 

assessment of commercially available products and manufacturer interviews, DOE has 

learned that at low wattages (less than or equal to 150 W), high reactance autotransformer 

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(HX-HPF) ballasts and CWA ballasts are most prevalent. At higher wattages, CWA 

ballasts compose the vast majority of the market. In consideration of these findings, DOE 

focused its testing and analysis on HX-HPF and CWA ballasts for the 70 W and 150 W 

representative units and CWA ballasts for all other wattage units.

Average ballast efficiencies (across four samples) were determined in accordance 

with metal halide ballast test procedures (10 CFR 431.324) by dividing measured output 

power by measured input power. As discussed in sections V.C.7 and V.C.8, DOE selects 

baseline and higher-efficiency representative units for analysis based on these average 

efficiencies. Also, as discussed in the following section, DOE determines representative 

ballast input power for each efficiency level based on these tested ballast efficiencies. To 

determine the efficiency levels under consideration, as discussed in section V.C.9, DOE 

uses a reported efficiency value based on the four tested samples, pursuant to the metal 

halide ballast certification procedures in 10 CFR 429.54.

6. Input Power Representations

In the preliminary analysis, ballast input powers for use in the downstream 

analyses (such as the LCC and NIA analyses) were normalized such that system 

producedthe ballast outputted the rated light output (as dictated by the metal halide lamp)

input power by dividing rated lamp wattage by measured ballast efficiency. In response, 

NEMA commented that ballast efficiency should not be calculated based on rated lamp 

power and input power. They remarked that not all ballasts operate lamps at their rated 

wattages and, thus, these ballasts could appear to have higher efficiencies than 

technologically feasible if this method is used. (NEMA, No. 34 at p. 13)

119
To clarify, DOE is not calculating ballast efficiencies based on rated lamp powers. 

Rather, DOE is using measured ballast efficiencies and rated lamp output to calculate 

normalized input powers for the downstream energy-use analyses. Although DOE’s test 

results indicate slight variations in ballast output power relative to rated lamp power from 

unit to unit, based on the marketing of these ballasts, DOE concludes that the metal 

halide ballasts tested are generally designed to operate lamps at their rated wattages. DOE 

believes these variations (on the order of three percent of the rated lamp power) are 

unlikely to significantly affect average ballast efficiency. In this NOPR, DOE continues 

to utilize normalized input powers in order to best characterize the energy use of all 

products that meet a particular efficiency level and to eliminate any artifacts due to the

particular model chosen. 

Additionally, OSI noted that the system wattage of magnetic ballasts increases up 

to 11 percent over lamp life. In contrast, electronic ballasts do not exhibit this behavior 

and, thus, have even lower energy use relative to a magnetic system of the same 

efficiency when considering operation over the lifetime of the lamp. (OSI, No. 27 at p. 7) 

DOE’s research indicates that as metal halide lamps age, they require higher voltages. 

Electronic ballasts have the capability to sense that the lamp voltage has increased and, in 

response, decrease their output current to maintain constant wattage throughout the life of 

the ballast. The CA IOUs also noted that electronic ballasts can improve lamp efficacy 

and lumen maintenance, resulting in higher mean rated lumens over the lifetime of the 

lamp. The CA IOUs urged DOE to consider scenarios where either reduced-wattage 

120
lamps or fewer (but more luminous) total fixtures can be used with electronic ballasts to 

capture even greater energy savings while maintaining the same mean system light 

output as the baseline system. (CA IOUs, No. 32 at p. 4)

DOE accounted for the increase in wattage for magnetic ballasts by using a 

multiplier when calculating magnetic efficiencies. DOE assumed that magnetic ballasts’ 

wattage increase occurs in a linear fashion over the life of the ballast. With this 

assumption, the ballast would average a 5.5 percent increase in output wattage over its 

lifetime. Therefore, DOE multiplied the rated lamp wattage by 1.055 when calculating 

the input power normalized to rated lamp power for all magnetic ballasts, but not for 

electronic ballasts. To investigate electronic ballast lumen maintenance, DOE reviewed 

lamp and ballast manufacturer product information, but did not find a consistent 

description of the impact of an electronic ballast on lumen maintenance. Based on the 

limited information and uncertainty of the potential impacts, DOE is not proposing an 

adjustment to electronic ballast input power to account for improved lumen maintenance 

relative to magnetic ballast operation. DOE requests comment on using a 5.5 percent 

increase when calculating the representative input power of magnetic ballasts.

7. Baseline Ballast Models 

DOE selected baseline models as reference points for each representative 

equipment class, against which DOE measured changes in energy use and price resulting 

from potential amended energy conservation standards. For metal halide lamp fixtures 

and ballasts subject to existing Federal energy conservation standards, a baseline model is 

121
a commercially available ballast that just meets existing standards and provides basic 

consumer utility. If no standard exists for a specific fixture type (e.g., less than 150 W or 

greater than 500 W fixtures), DOE chooses baselines that represent lowest efficiency 

products (based on average test ballast efficiencies) or highest-volume products within 

the representative parameters defined (e.g., representative wattage, magnetic circuit type, 

input voltage). For the preliminary analysis, DOE analyzed a CWA, quad-input voltage, 

pulse-start baseline ballast for each of the 70 W, 250 W, 400 W, and 1000 W 

representative wattages. As DOE received no adverse comment to the selection of the 70 

W, 250 W, and 400 W baselines, DOE continues to use the same baseline ballasts for the 

NOPR. The following paragraphs discuss changes to the 1000 W baseline and the 

additions of a second 70 W baseline and a new 150 W baseline.

a. 70 W Baseline Ballast

In the preliminary analysis, DOE analyzed a single 70 W magnetic ballast with an 

efficiency of 72.0 percent as the baseline unit. However, through manufacturer 

interviews, DOE has learned that electronic ballasts compose a significant portion 

(estimated at nearlyas more than 25 percent) of this equipment class’s market.the ≥50 W 

and ≤100 W ballasts shipped with indoor fixtures. Therefore, for this NOPR, DOE has 

added an electronic baseline ballast for analysis. This ballast utilizes an LFE circuit, 

operates at quad-voltage, and has an efficiency of 88.0 percent. DOE requests comment 

on the addition of this electronic 70 W baseline ballast.

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b. 150 W Baseline Ballast

As discussed earlier, to analyze the new equipment classes with a rated wattage 

range of 100 W to 150 W, DOE has added a 150 W representative unit to its analysis. 

Through market research and ballast efficiency testing, DOE has determined that both 

CWA and HX-HPF ballasts are common at the 150 W level. Based on test results, DOE 

found the lowest efficiency ballast that could be incorporated into a fixture exempt from 

EISA 2007 standards was a magnetic pulse-start, quad-voltage CWA ballast with an 

efficiency of 81.2 percent, and, thus, analyzed this ballast as a baseline.

c. 1000 W Baseline Ballast

In the preliminary analysis, DOE selected a 1000 W CWA, quad-input voltage, 

magnetic, pulse-start ballast with an efficiency of 91.8 percent as a baseline for the >500 

W equipment class. Since publication of the preliminary analysis, DOE has learned that 

although pulse-start ballasts are available at the 1000 W level, probe-start, CWA, quadvoltage units predominate in this wattage category, and are, therefore, more appropriate 

baselines. Because DOE’s analysis indicates that ballast efficiency is not affected by 

starting method, DOE created a probe-start baseline by utilizing the same baseline ballast 

efficiency (91.8 percent) and applying a manufacturer production cost more similar 

torepresentative of a probe-start ballast. DOE further discusses the derivation of 

manufacturing production costs in section V.C.12 of this NOPR and in chapter 5 of the 

NOPR TSD.

123
8. Selection of More Efficient Units

After selection of baseline models, DOE used a combination of two methods to 

determine more efficient units for analysis within each representative unit.equipment 

class. The first method was by examining DOE’s own test data (discussed in section 

V.C.5) to select commercially available ballasts to represent higher efficiency levels. The 

second method involved filling in large gaps of efficiency present in the test data (often 

between commercially available magnetic and electronic ballasts) through estimating 

efficiency increases due to the implementation of several of the design options described 

in section V.B. DOE derived those estimates based on manufacturer interviews and by 

validating or supplementing that input with independent modeling of potential reductions 

in losses. Specifically, DOE used the watts loss/pound characteristics for various steel 

types and the resistive losses for various winding materials to determine the levels of 

efficiency modeled ballasts could achieve. In modeling more efficient magnetic ballasts, 

DOE maintained the physical footprintsize of the higher-efficiency models relative to 

commercially available products within the representative wattages. DOE seeks comment 

on whether features or consumer utility of the ballasts such as the physical size, including

footprint, stack height, and weight can be maintained or if they would be adversely 

affected for the magnetic ballast efficiencies associated with the modeled ballasts.

In summary, for the NOPR, DOE developed a maximum technologically feasible 

magnetic ballast based on either commercially available equipment (for the 1000 W

level) or a modeled ballast (for other representative wattages) that utilizes the highest 

grade steels with whichpracticable for manufacturing metal halide ballasts are practicable 

Comment [AGA13]: Revised at the request of 

OIRA.

Comment [AGA14]: Revision requested by 

OIRA.

124
to manufacture.. DOE also developed a maximum technologicaltechnologically feasible 

electronic ballast (which also serves to represent the maximum technologically feasible 

level overall) for the 70 W, 150 W, 250 W, and 400 W representative wattages. To 

determine this level, DOE conducted a survey of the MHLF market and the research 

fields that support the market. DOE concluded that, within a given equipment class, no 

working prototypes exist that have a distinguishably higher ballast efficiency than 

currently available electronic ballasts. As such, the highest-efficiency units analyzed in 

the engineering analysis represent the most efficient tier of commercially available 

equipment. For further details on the higher-efficiency units analyzed in the NOPR, see 

chapter 5 of the NOPR TSD.

DOE received several comments, discussed below, on the higher-efficiency 

magnetic and electronic units analyzed in the preliminary analysis.

a. Higher-Efficiency Magnetic Ballasts

NEMA noted that magnetic ballasts are already as efficient as possible while still 

being cost-effective, and further changes to their designs could make them costprohibitive and not physically feasible for use in current products. In particular, NEMA 

stated that 150 W magnetic ballasts only exist on the market due to their current 

exemption from standards, and to make them any more efficient would involve a size 

increase and redesign. (NEMA, No. 34 at p. 7, 13-14) Similarly, Philips stated that 88 

percent efficiency is the highest possible efficiency for 175 W magnetic ballasts, but it is 

125
not achievable for lower-wattage magnetic ballasts. (Philips, Public Meeting Transcript, 

No. 33 at pp. 69-70)

On the other hand, the CA IOUs recommended that DOE re-examine the 

maximum technologically feasible efficiency for magnetic ballasts. They noted that 

according to the CEC database, 12 fixtures (at the representative 400 W level) listed by 

manufacturers in 2010 used magnetic ballasts that claimed 93 percent or higher ballast 

efficiency, which significantly more efficient than DOE’s highest magnetic ballast 

analyzed. (CA IOUs, No. 32 at p. 5-6)

As discussed in the screening analysis (section V.B), DOE recognizes that several 

commercially available magnetic ballasts (such as the 175 W 88-percent efficient ballast)

may already utilize the highest efficiency design options and have reached their 

efficiency limits. However, based on feedback from manufacturer interviews, DOE has 

learned that for each of the representative wattages analyzed, there exist design options to 

improve efficiency. Therefore, DOE utilizes these design options to estimate the 

maximum technologically feasible efficiency for magnetic ballasts for each 

representative wattage. DOE does account for efficiency limits of non-representative 

wattages by creating efficiency-level equations (dependent on rated wattage) for each 

equipment class. In response to the CA IOUs comment, DOE reviewed the CEC 

database, but was unable find any of the more-efficient 400 W ballasts available for 

purchase. As DOE was unable to test these ballasts and confirm their higher efficiencies, 

DOE could not include them in this analysis. 

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b. Electronic Ballasts

In the preliminary analysis and in this NOPR, DOE analyzed electronic ballasts as 

higher-efficiency replacements to magnetic ballasts and based max tech efficiencies on 

commercially available electronic ballasts independently tested by DOE. In response to 

those efficiencies, DOE received several comments, discussed below, regarding the 

appropriate electronic max tech efficiencies, use of high-frequency electronic ballasts as 

representative units of analysis, and whether electronic ballasts should be considered the 

maximum technologically feasible level for 1000 W ballasts.

Maximum Technologically Feasible Efficiencies

Regarding the maximum technologically feasible efficiency of electronic ballasts, 

OSI stated that their commercially available ballasts represent the current max tech. Any 

further increases in efficiency would be theoretical and not proven through actual 

performance. (OSI, No. 27 at p. 5) In contrast, the CA IOUs noted that the CEC database 

contains several electronic ballasts from manufacturers such as Metrolight and Advance 

with efficiencies significantly higher than those identified as max tech. The CA IOUs 

encouraged DOE to revisit maximum achievable efficiencies for each productequipment

class and technology option. (CA IOUs, No. 32 at p. 5-6) 

As DOE does not have any indication electronic ballast efficiency can exceed that 

which is currently commercially available, DOE agrees with OSI’s assessment that any 

efficiency improvement above commercially available electronic ballasts would be 

127
widely speculative. Therefore, all of the max tech levels proposed by DOE reflect 

existing commercially available ballasts. DOE has attempted to purchase and test the 

highest-efficiency ballasts, as determined through catalog rated efficiencies and the CEC 

metal halide lamp fixture database. Thus, DOE believes that its max tech electronic 

ballast efficiencies represent the highest efficiencies currentlythat are commercially 

available and validated by independent testing in accordance with DOE’s metal halide 

ballast test procedures.

High-Frequency Electronic Ballasts

In the preliminary analysis, the maximum technologically feasible level for 400 

W fixtures was based on a high-frequency electronic ballast. DOE requested comment on 

the appropriateness of using high-frequency electronic ballasts as representative units, 

particularly with respect to lamp and ballast compatibility concerns. 

In response, OSI, Philips, and NEMA opposed regulatory requirements obtainable 

only with high-frequency electronic ballasts. While they recognized that high-frequency 

electronic ballasts can have higher efficiencies, they noted that their test measurements

also have a significantly higher degree of error (as high as five percent) than those 

obtained with low-frequency ballasts. OSI and NEMA argued that if DOE establishes 

standards based on high-frequency technology, this increased variation should be 

accounted for. In addition, all three stakeholders remarked that high-frequency electronic 

ballast technology is often not compatible with the most efficacious systems, specifically 

noting their incompatibility with ceramic metal halide lamps, which represent the highest 

128
efficacy, best lumen maintenance, and longest life of metal halide lamps. (Philips, Public 

Meeting Transcript, No. 33 at p. 34, 62-63; OSI, No. 27 at p. 4; NEMA, No. 34 at p. 14) 

While acknowledging that there are some lamp and ballast compatibility concerns, 

Empower Electronics stated that high-frequency ballasts can be more efficient and should 

be used as a representative unit. (Empower Electronics, No. 36 at p. 8) 

In response, DOE has researched product application notes in catalogs and 

technical literature regarding lamp compatibility with high-frequency ballasts. Based on 

this research, DOE agrees that due to acoustic resonance issues, high-frequency ballasts 

may have significant compatibility problems with some high-efficacy metal halide lamps,

thus, reducing potential energy savings at those levels. Although DOE maintains highfrequency electronic ballasts as a valid design option to improve ballast efficiency, DOE 

will consider this potential reduction in energy savings intake the impact of lamp and 

ballast compatibility into account when adopting any amended standards.

Acuity also commented that high-frequency ballasts are less reliable in outdoor 

applications because ambient temperature and power quality effects. (Acuity, Public 

Meeting Transcript, No. 33 at p. 63) DOE is considering in this NOPR (discussed in 

section V.C.12) fixture redesigns (accounting for increased thermal management and 

voltage transient suppression) and corresponding incremental costs incurred as a result of 

implementing electronic ballasts in outdoor applications. DOE has not found evidence of 

any difference between high-frequency and low-frequency electronic ballasts in this 

regard. DOE requests clarification on whether high-frequency electronic ballasts require 

129
additional thermal and transient protection relative to low-frequency electronic ballasts. If 

so, DOE requests comment on technical reasons for this difference and whether ballast or 

fixture redesigns can overcome these barriers.

1000 W Electronic Ballasts

In the preliminary analysis, DOE analyzed only magnetic ballasts as higher 

efficiency replacements for the 1000 W baseline unit and requested comment on whether 

1000 W electronic metal halide ballasts are technologically feasible. Philips and OSI 

stated that 1000 W electronic ballasts only exist in niche applications, with no ballasts in 

general lighting or area lighting. Even though 1000 W electronic ballasts are 

commercially available, Philips pointed out that these ballasts do not have a significant 

efficiency improvement over the magnetic ballasts at that wattage, but may be preferred 

for technological reasons (e.g., in high definition TVs). (Philips, Public Meeting 

Transcript, No. 33 at pp. 63-64; OSI, No. 27 at p. 5) NEEA also recommended that DOE 

analyze only magnetic ballasts at 1000 W. (NEEA, No. 31 at p. 4) DOE’s research has 

confirmed that the 1000 W electronic ballasts on the market today appear to be for 

specialized functions, such as hydroponics and aquariums, rather than general 

illumination applications. Because these fixtures may have unique thermal 

characteristics, DOE cannot be certain that incorporating 1000 W electronic ballasts into 

general lighting fixtures is technologically feasible. Thus, DOE does not consider 

electronic ballasts as higher efficiency replacements for 1000 W magnetic ballasts.

130
9. Efficiency Levels

Based on the higher-efficiency ballasts selected for analysis, discussed in section 

V.C.8, DOE developed four efficiency levels for the 70 W, 150 W, 250 W, and 400 W 

representative unitswattages. Due to the fact that DOE did not analyze electronic ballasts 

for the 1000 W representative unitwattages, DOE analyzes only two efficiency levels for 

this unitwattage. The baseline of each representative equipment class represents the 

lowest-efficiency commercially available magnetic ballast covered by these standards. 

EL1 represents a moderately higher efficiency magnetic ballast, and EL2 represents the 

maximum technologically feasible magnetic ballast. EL1 and EL2 are characterized by a 

combination of commercially available and modeled magnetic ballasts. EL3 represents 

the lowest-efficiency commercially available electronic ballast, and EL4 represents the 

maximum technologically feasible level for all ballasts incorporated into metal halide 

lamp fixtures.

In the preliminary analysis, DOE considered both binned and equation-based 

approaches to defining efficiency levels within wattage ranges. In a binned approach, 

DOE would set the same standard for all wattages within an equipment class. In an 

equation-based approach, DOE would define equations that relate rated lamp wattage to 

ballast efficiency such that different wattages within an equipment class would be subject 

to different efficiency requirements. For the preliminary analysis, DOE analyzed setting 

standards based on a binned approach and received several comments in response to this 

decision.

131
Philips noted that there is significant change in ballast efficiency throughout the 

150 W to 250 W range, with a definite trend for higher efficiency as the wattage 

increases up to 500 W. (Philips, Public Meeting Transcript, No. 33 at pp. 55, 66) Philips 

suggested that efficiencies in the 150 W to 250 W range could benefit from further 

delineation, perhaps in the form of a formula approach. (Philips, Public Meeting 

Transcript, No. 33 at p. 47) Based on manufacturer comments at the preliminary analysis 

public meeting, NEEA supported the proposal to either divide the 150 W to 250 W range 

into two classes, or develop efficiency levels in the form of wattage-based equations. 

(NEEA, No. 31 at pp. 3-4)

In contrast, OSI did not recommend using an equation-based approach for 

efficiency levels. They commented that having a known, fixed efficiency requirement 

allows manufacturers to more easily redesign their ballasts to incorporate additional 

features (such as dimming or 120 V tap). (OSI, No. 27 at p. 4)

After considering all of the comments, DOE agrees with Philips and NEEA that 

an equation-based approach for efficiency levels would be most appropriate, as it allows 

DOE to account for changes in efficiency across a rated wattage range. In addition, this 

approach ensures that efficiency levels for all wattages, even those not analyzed as 

representative, are technologically feasible. To develop the equation forms and efficiency 

trends for each wattage range, DOE utilized its own efficiency test data as well as catalog 

efficiency data. The discussion below describes the equations used in each wattage bin. 

For further details, see chapter 5 of the NOPR TSD.

132
For the two lowest wattage bins, which consist of 50 W to 150 W ballasts, DOE 

used its own test data as well as efficiency trends according to catalog data to generate a 

separate power-law best fitfits for magnetic ballasts (EL1 and EL2) and separately for 

electronic ballasts (EL2EL3 and EL3EL4). 

The next wattage bin consists of 150 W ballasts, excluding the currently 

exempted 150 W, up through and including 250 W ballasts. Because EISA 2007 covered 

productsequipment in this wattage bin, DOE can only evaluate efficiencies equal to or 

above the existing standards to avoid backsliding. Manufacturers stated during interviews 

that 150 W magnetic ballasts could not be designed to meet 88 percent and that 175 W 

ballasts only reached 88 percent by using the high-grade-score steel and increasing the 

ballast’s footprint. DOE’s test data also indicated that there are no 150 or 175 W 

magnetic ballasts available that exceed 88 percent efficiency. Though DOE did not test 

any 200 W ballasts, a review of catalog data indicates that 200 W ballasts are only 

available at 88 percent efficiency. Because DOE has no specific information indicating 

that these ballasts can be designed to be more efficient, DOE assumed that 88 percent is 

also the max tech magnetic ballast efficiency for wattages up through 200 W. Thus, DOE 

maintained the EISA 2007 efficiency requirement of 88 percent for ELs designed to 

represent levels met by magnetic ballasts. DOE did not have any information about the 

achievable efficiencies for ballasts >200 W and <250 W, as products in this range are not 

commercially available. Therefore, DOE gradually increased the magnetic efficiency 

levels (EL1 and EL2) between 200 W and 250 W ballasts using a linear trend from 88 

133
percent to the efficiency of the EL1 and EL2 250 W representative units. For the 

electronic ballast efficiency levels (EL3 and EL4), DOE continued the power-law 

function fit from the 50 to 150 W range up to 250 W. 

The next wattage bin consists of ballasts higher than 250 W up through and 

including 500 W. Because the 250 W and 400 W magnetic representative units at EL1 

and EL2 have the same efficiency and utilize similar design options, DOE created a flat 

efficiency requirement for magnetic ballasts within this wattage bin. For the electronic 

ballast efficiency levels (EL3 and EL4), DOE continued the power-law function fit from 

the 250 to 500 W range up through 500 W. 

The highest wattage bin consists of ballasts higher than 500 W up through and 

including 2000 W. DOE examined catalog data for market availability and receivedfound 

no electronic ballasts for general lighting applications in this wattage range. Manufacturer 

feedback confirmed that there are no electronic ballasts currentlyfor general lighting 

applications commercially available above 500 W. Thus, there are two only efficiency 

levels at the highest wattage range rather than four. DOE used a linear fit for ballasts 

above 500 W through 1000 W after examining the efficiency trends within 

manufacturers’ product lines in this wattage bin. DOE fit the linear trend from the 

previous wattage bin’s 500 W efficiencies at efficiency levels 1 and 2 through the 

representative units at 1000 W. However, due to the lack of test data and limited wattage 

offerings for ballasts over 1000 W, DOE could not develop a conclusive trend between 

134
wattage and efficiency. Thus DOE created a flat efficiency requirement extending from 

the tested efficiency of the 1000 W representative unit to 2000 W. 

Table V.3 summarizes all of the functions and efficiencies describing each 

equipment class. DOE requests comment on the described efficiency levels.

Table V.3 NOPR Efficiency Level Descriptions for the Representative Equipment 

Class

Representative Equipment 

Class

Rep. 

UnitWattage EL Minimum Efficiency Equation

%

≥50 W and ≤100 W 70 W

EL1 1100/(1+3.90∗P^(-0.60)) †

EL2 1100/(1+2.50∗P^(-0.55))

EL3 1100/(1+0.60∗P^(-0.34))

EL4 1100/(1+0.36∗P^(-0.30))

>100 W and <150 W* 150 W

EL1 1100/(1+3.90∗P^(-0.60))

EL2 1100/(1+2.50∗P^(-0.55))

EL3 1100/(1+0.60∗P^(-0.34))

EL4 1100/(1+0.36∗P^(-0.30))

≥150 W** and ≤250 W 250 W

EL1 ≥150 W and ≤200 W:

9088.0

>200 W and ≤250 W:

(4.0E-40*10^(-2)∗P 

+ 80.0.8

EL2 ≥150 W and ≤200 W:

88.091.5

>200 W and ≤250 W:

(7.0E-40*10^(-2)∗P + 

74.0.7

EL3 1100/(1+0.60∗P^(-0.34))

EL4 1100/(1+0.36∗P^(-0.30))

>250 W and ≤500 W 400 W

EL1 90.0

EL2 91.5

EL3 1100/(1+0.60∗P^(-0.34))

EL4 1100/(1+0.36∗P^(-0.30))

>500 W and ≤2000 W 1000 W

EL1

>500 W and ≤1000 W:

91.85.0*10^(-3)∗P + 

87.5

>1000 W and ≤2000 

W:

( 92.5

.0E-5)∗P + 0.9

EL2

>500 W and ≤1000 W:

92.53.2*10^(-3)∗P + 

89.9

>1000 W and ≤2000 

W: 93.1

(3.2E-5)∗P + 0.9

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; that are also rated for use in wet 

locations, as specified by the National Electrical Code 2002, section 410.4(A); and containcontaining a ballast that is rated to operate at 

ambient air temperatures above 50 °C, as specified by UL 1029–2001. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; that are also rated for use in 

135
wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

†P is defined as the rated wattage of the lamp the fixture is designed to operate.

As discussed in section V.C.5, DOE used a reported efficiency value based on the 

four tested samples, pursuant to the metal halide ballast certification procedures in 10 CFR 

429.54, to describe its representative units and to develop the ELs. DOE invites comment 

on whether any adjustments to the ELs are necessary to account for sources of variation 

not captured by the reporting requirements of 10 CFR 429.54.

10. Design Standard 

In the preliminary TSD, DOE considered a design standard that would prohibit 

the sale of probe-start ballasts in newly sold fixtures. DOE notes that under 42 U.S.C. 

6295(hh)(4), DOE is permitted to set an energy efficiency standard based on both design 

and performance requirements. EISA prescribed probe-start ballasts to be 94 percent 

efficient, effectively banning probe-start ballasts between 150 and 500 W (except those 

150 W ballasts exempt by EISA) based on their inability to meet this performance 

requirement. (42 U.S.C. 6295(hh)(1)(A)(ii) Manufacturers responded to the EISA 2007 

standards by shifting their inventory to pulse-start ballasts, which are subject to less 

stringent standards. The following paragraphs describe comments received and DOE’s 

analysis of a design standard prohibiting probe-start ballasts to be sold in new fixtures in 

these wattages. 

With regards to probe-start ballast availability, OSI, NEMA, Hubbell Lighting 

Incorporated, Venture Lighting, and NEEA also commented that there are no 70 W 

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probe-start ballasts on the market. (OSI, Public Meeting Transcript, No. 33 at pp. 58-60; 

NEMA, No. 34 at p. 14; Hubbell, Public Meeting Transcript, No. 33 at pp. 42, 57, 59-60; 

Venture Lighting, Public Meeting Transcript, No. 33 at pp. 59-60; NEEA, No. 31 at p. 4) 

Hubbell also clarified that probe-start ballasts are available at wattages of 150 W and 

above. Hubbell stated that there are a few probe-start ballasts at 150 W and there are no 

probe-start ballasts at smaller wattages because the seals for the arc tubes in the lamps 

become too small to contain the third electrode needed to start probe-start ballasts. OSI 

added that when medium screw-base, low-wattage metal halide lamps were first 

introduced to the market, they were all pulse-start. The manufacturers never made lowwattage probe-start metal halide lamps. (Hubbell, Public Meeting Transcript, No. 33 at 

pp. 58-59; OSI, Public Meeting Transcript, No. 33 at p. 59) Even though probe-start has 

become technically possible at 150 W, OSI and NEMA pointed out that because of EISA 

2007, there are no new fixtures using probe-start ballasts less than 500 W, and, therefore,

no probe-start ballasts at less than 500 W on the market. (OSI, No. 27 at p. 5; NEMA, 

No. 34 at p. 15) Hubbell noted that pulse-start ballasts only provide 8 to 15 percent 

energy savings over probe-start ballasts for 250 W and 400 W products, and anywhere 

from 0 to 8 percent energy savings over probe-start ballasts in the 1000 W class. 

(Hubbell, Public Meeting Transcript, No. 33 at p. 42-43) GE put forward one cause for 

the mistaken impression that there are probe-start ballasts at lower wattages: in the 

manufacturers’ fixture catalogues, the lamp designation given for lower wattages is “M,” 

for metal halide. Even though the starting method of these lower wattage lamps is not 

explicitly labeled, they are all pulse-start. (GE, Public Meeting Transcript, No. 33 at p. 

60) Finally, NEMA and Hubbell commented further that only 1000 W ballasts have a 

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probe-start baseline. (NEMA, No. 34 at p. 14; Hubbell, Public Meeting Transcript, No. 

33 at pp. 57-58) 

DOE reexamined ballast availability in manufacturer catalogs and, in response to 

GE, was careful not to consider “M” designated lamps as probe-start erroneously. DOE 

determined that probe-start ballasts are only available at wattages above 150 W and also 

confirmed that there are no 70 W probe-start ballasts currently on the market. EISA 2007 

allowed probe-start ballasts in the 150 W to 500 W range, but set a minimum efficiency 

standard of 94 percent. None of the probe-start ballasts DOE found have an efficiency 

that meetscould meet this minimum efficiency level, so the standards from EISA 2007 

essentially prohibit probe-start ballasts less than or equal to 500 W for use in new 

fixtures. However, because certain fixtures designed for use with lamps rated at 150 W 

are exempted from EISA 2007 standards, probe-start ballasts can be used at 150 W in 

new fixtures. However, DOE’s review of manufacturer catalogs indicates that probe-start 

ballasts are not sold at 150 W. Therefore, the only wattage range in which probe-start 

ballasts are available for use in new fixtures is the greater than 500 W to 2000 W range. 

In this NOPR, DOE is analyzing the impact of a design standard that would prohibit 

probe-start ballasts from being sold in new fixtures in the greater than 500 to 2000 W 

range.

NEMA and Hubbell also commented that at that high wattage, there is very little 

to be gained from a switch to pulse-start, stating that 1000 W probe-start ballasts are 

already 92 percent efficient and havethese lamp-ballast systems produce only slightly 

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fewer mean lumens than pulse-start ballastslamp-ballast systems. (NEMA, No. 34 at p. 

14; Hubbell, Public Meeting Transcript, No. 33 at pp. 57-58) Given the absence of probestart ballasts at the lower wattages, and the insignificant discrepancy between probe-start 

and pulse-start ballasts at the higher wattages, NEEA did not see much utility in a design 

standard that prohibits probe-start systems. (NEEA, No. 31 at p. 3) DOE notes that the

major motivation for prohibiting probe-start ballasts is not the efficiency difference 

between the ballasts, but the decreased mean efficacy of probe-start lamps when 

compared to pulse-start lamps. Even a small percentage gain in mean lamp efficacy could 

yield energy savings on the order of the ballast efficiency savings calculated in other 

equipment classes.

Progress Energy Carolinas, however, supported requiring pulse-start ballasts in all 

wattages. Yet, Progress Energy Carolinas also urged DOE to consider other technologies 

to realize significant efficiency gains over pulse-start. Specifically, Progress Energy 

Carolinas cited the examples of ceramic arc tube metal halide lamps and the super metal 

halide technology as seen in the Elite and Cosmopolis models from Philips. Progress 

Energy Carolinas argued that both of these measures improve not only efficiency, but 

also other operating characteristics. While Progress Energy Carolinas noted that the super 

technology may be sole-source, proprietary technology only available in low- to midrange wattages, Progress Energy Carolinas commented that Philips may be willing to 

share the technology with others like they have offered to do with their fluorescent lowmercury lamp technology. (Progress Energy Carolinas, No. 24 at p. 2) DOE will not 

consider efficiency levels that require proprietary technology like that used in the Philips 

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Elite and Cosmopolis systems. Though a company like Philips may be willing to share 

technology, DOE is unable to analyze the impacts of the agreement because the terms of 

the agreement cannot be known in advance. In this MHLF rulemaking, DOE has decided 

to only consider performance and design requirements that affect the ballast included in a 

metal halide lamp fixture. Therefore, DOE is not planning to consider a design 

requirement that mandates the use of ceramic metal halide lamps in new metal halide 

lamp fixtures. 

Empower Electronics disagreed with the use of a design standard, instead 

recommending that a minimum ballast-and-lamp efficiency standard be established 

regardless of design to effectively prohibit the use of inefficient probe-start systems. 

Empower Electronics suggested that this standard be set at 94 percent for fixtures 

designed to operate lamps rated for 250 W and above, effectively requiring electronic 

ballast technology. (Empower Electronics, No. 36 at p. 8) DOE notes that it is planning to 

consider efficiency levels that require electronic ballasts when determining a proposed 

standard. In addition to this consideration, DOE is also continuing to analyze a design 

standard as a possibility for a proposed standard.

Georgia Power stated that the concept of using fewer fixtures when replacing

existing probe-start systems with pulse-start systems may be practical for indoor 

applications, but not for outdoor uses. Currently, parking lots have lighting system 

designs that use probe-start fixtures at an acceptable photometric level. DOE assumes 

that the poles, bases and conductors are all in place and the investment has been made. 

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Georgia Power said that using fewer pulse-start fixtures on the same poles at the same 

places will not result in the same photometric design. (Georgia Power, No. 28 at p. 2) In 

regards to setting a design standard requiring reduced wattage versions of lamps and the 

expected change in lumen output, Progress Energy Carolinas said that in general, the 

percent light reduction is half the percent wattage reduction. Progress Energy Carolinas 

also noted that reduced wattage pulse-start lamps are not currently available; instead, a 

reduced wattage probe-start lamp is used as a replacement. (Progress Energy Carolinas, 

No. 24 at p. 3) DOE agrees with Georgia Power that in some applications, changing the 

spacing of fixtures is not feasible. Instead, users of these applications may use the same 

number of pulse-start ballasts in their systems, but at reduced wattage while 

maintainingto maintain light output. This consumercustomer response to a design 

standard is discussed in more detail in section V.C.10. DOE disagrees with Progress 

Energy Carolinas that reduced-wattage lamps are only available in the probe-start variety. 

DOE has found several pulse-start lamps available at reduced wattages such as 320 W 

and 875 W.

To quantify the difference in mean lumen output of probe-start lamps relative to 

pulse-start lamps of the same wattage, DOE compared several major manufacturers’ 1000 

W lamp catalog data for these two lamp start types. DOE paired these lamps from the 

same manufacturer and of the same characteristics (open vs. enclosed, CRI, percentage of 

rated life at which the mean lumen value is recorded) and calculated the ratio of probestart mean lumens divided by pulse-start mean lumens. Then, DOE averaged the ratio of 

each pairing from every manufacturer and determined that, on average, probe-start metal 

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halide lamps are 5.6 percent less efficacious than comparable pulse-start lamps. Thus, 

pulse-start metal halide lamp and ballast fixtures can output 5.6 percent more lm/W than 

probe-start fixtures. Energy savings could be achieved in two ways. Because each pulsestart metal halide lamp fixture outputs 5.6 percent more lumens (for a given wattage) than 

comparable probe-start lamp fixtures, consumerscustomers could:

1. Illuminate an area to the same level with 5.6 percent fewer fixtures if they 

switch from probe-start to pulse-start; or 

2. Switch from full-wattage probe-start lamp fixtures to the same number of 

reduced-wattage pulse-start lamp fixtures, maintaining light output, but 

reducing energy consumption.

Using fewer fixtures (option 1) would lead to reduced energy consumption and 

could save administrative and maintenance costs associated with purchasing and 

maintaining fewer fixtures. However, this response to the design standard is only feasible 

in applications that have flexibility in fixture spacing. In some applications, such as small 

parking lots, changing spacing means moving poles and conductors, which would be 

expensive and could change the targeting of light in certain areas. For applications in 

which the height of the fixture is limited, the additional light output of a full-wattage 

pulse-start system might not be adequately distributed over a larger floor space (larger 

floor space because the number of fixtures has been reduced) without fixture redesign.

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For consumerscustomers using reduced-wattage pulse-start fixtures (option 2), a 

consumercustomer could, for example, change a 1000 W probe-start fixture for an 875 W 

pulse-start fixture, maintaining light output to near the original level. DOE’s view is that 

replacing probe-start lamp fixtures with reduced-wattage pulse-start lamp fixtures is 

generally more realistic and practical than replacing them with fewer pulse-start lamp 

fixtures because fixture spacing does not need to be changed. For this reason, DOE 

assumed reduced-wattage replacements in its analysis of a proposed design standard to 

prohibit metal halide lamp fixtures that use probe-start as their starting method. 

When analyzing the energy-savings impact of a design standard efficiency level, 

DOE multiplied the normalized input power of the 1000 W ballast tested by 0.944. 

Because DOE determined that using the same number of reduced-wattage fixtures is the 

most likely market response to a design standard, DOE did not also scale the cost of a 

design standard efficiency level by 0.944. Instead, DOE assumed that reduced-wattage 

systems would cost approximately the same amount as full-wattage systems, with the 

exception of the addition of an igniter (device that provides a voltage pulse to start the 

lamp). In the non-design-standard scenario, DOE assumed that the representative cost of 

a 1000 W ballast would equal the cost of a probe-start ballast as this starting method is 

the most common in the greater than 500 W but less than or equal to 2000 W equipment 

classes. However, in the design-standard scenario, an igniter would need to be added, as 

only pulse-start ballasts could be included in new fixtures.

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DOE requests comment on the decision to include a design standard that would 

prohibit the sale of probe-start ballasts in newly sold fixtures, the proposed methods of 

analyzing these levels, and the potential for lessening of the utility or the performance 

through the prohibition of the sale of probe-start ballasts in newly sold fixtures. 

11. Scaling to Equipment Classes Not Analyzed

In the preliminary analysis, DOE had oneanalyzed all equipment classclasses as 

representative and, therefore, did not scale. As discussed in section V.C.2, DOE has 

added additional equipment classes for the NOPR. Although DOE set efficiency levels 

for quad-voltage ballasts directly, DOE did not analyze 480 V input voltage ballasts 

directly. Thus, it was necessary to develop a scaling relationship for this input voltage. To 

do so, DOE compared quad-voltage ballasts to their 480 V ballast counterparts using 

catalog data over all representative wattages at various efficiencies. DOE found the 

average reduction to ballast efficiency to be 0.6 percent. Thus, DOE proposes to apply 

this scaling factor to the efficiency levels for the quad-volt ballasts to determine the 

appropriate values for the 480 V ballasts. DOE requests comments on this issueFor the 

≥150 W to ≤250 W equipment classes, DOE made adjustments to resulting scaled 

equations to ensure all efficiency levels were more stringent than the existing standards 

(see chapter 5 of the NOPR TSD for additional detail). DOE requests comment on this 

proposal.

Comment [AGA15]: Change requested by 

OIRA.

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12. Manufacturer Selling Prices 

For the preliminary analysis, DOE developed the manufacturer selling prices for 

metal halide lamp fixtures and ballasts by determining a manufacturer production cost 

(MPC), either through a teardown or retail pricing analysis, and then applying a markups

analysis to arrive at the manufacturer selling price (MSP). For further details on this 

analysis, see chapter 5 of the NOPR TSD.

Based on stakeholder comments and manufacturer interviews, DOE adjusted a 

number of parameters in its pricing analysis for this NOPR. In calculating prices, DOE 

adjusted material prices to better reflect current trends based on manufacturer input and 

commodity prices research. Additionally, for this NOPR, DOE applied incremental costs 

to fixtures utilizing electronic ballasts based on application characteristics (indoor vs. 

outdoor). Finally, DOE modified its approach to applying manufacturer markups to align 

better with existing fixture component manufacturing channels. The following sections 

describe these changes and approaches.

a. Manufacturer Production Costs

For the NOPR analyses, DOE conducted teardown analyses on a total of 32 

commercially available metal halide ballasts (including four 150 W ballasts not presented 

in the preliminary analysis) and eight metal halide lamp fixtures. Using the information 

from these teardowns, DOE summed the direct materials, labor, and overhead costs used 

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to manufacture a product to calculate the MPC.33 In the case of electronic ballasts, direct 

material costs represent the direct purchase price of components (resistors, connecting 

wires, etc.). In the case of magnetic ballasts, direct material costs represent the purchase 

prices of steel laminations, copper wires, and other components. The direct labor costs 

include fabrication and assembly labor. 

When determining material costs, DOE used material prices based on a five-year 

average to account for the fluctuations in the prices of certain raw materials, such as steel 

and copper. Several manufacturers of ballasts and fixtures noted the high prices and 

scarcity of copper and high-grade steels, such as M6 steel. Philips also commented that 

M6 steel is mostly manufactured in China, resulting in potential import difficulties. 

Acuity stated that volatility of material markets, especially in the availability and pricing

of steel and copper, has greatly increased since the preliminary analysis. Acuity and 

NEMA suggested that DOE consider availability and price volatility of an improved steel 

core or copper wiring in their cost analysis. NEMA suggested that DOE factor in 

expected inflation and price volatility for materials. (Philips, Public Meeting Transcript, 

No. 33 at p. 71; Hubbell, Public Meeting Transcript, No. 33 at p. 70; NEMA, No. 34 at p. 

7, 12, 16; Acuity, Public Meeting Transcript, No. 33 at p. 132-133)) 

DOE agrees that high-grade steel laminations and copper are materials that have 

seen high price fluctuations in recent years. Due to the uncertainty of how these prices 

will continue to change, DOE continues to use five-year average materials prices, rather 

33 When viewed from the company-wide perspective, the sum of all material, labor, and overhead costs 

equals the company’s sales cost, also referred to as the cost of goods sold (COGS).

146

 
than projected inflations, to characterize the expected cost impacts in years following the 

compliance date of the amended standards considered in this rule. For this NOPR, DOE 

updated these averages to include 2010 price data.

For the preliminary analysis, DOE used financial data to estimate the overhead 

cost (including indirect material and labor costs, maintenance, depreciation, taxes, and 

insurance related to assets) by calculating it as a percentage of the MPC. NEEA noted 

that manufacturers have previously recommended that DOE apply overhead only to labor 

costs. NEEA urged DOE to ensure that this part of the analysis accurately reflects reality 

in the manufacturing world relevant to each rulemaking. (NEEA, No. 31 at p. 5) NEMA 

and OSI noted that manufacturing and overhead costs can vary greatly by manufacturer, 

production volume, and complexity of the product (e.g., magnetic versus electronic 

technology). NEMA stated that design and overhead costs for electronic ballasts are 

inherently higher than those for electromagneticmagnetic ballasts and require different 

engineering specializations. (NEMA, No. 34 at p. 16; OSI, No. 27 at p. 5)

DOE recognizes that manufacturing and overhead costs can vary and, therefore,

developed separate estimates for material, labor, and overhead for each representative 

unit in the analysis. In response to NEEA’s comment, DOE notes that because it 

calculates overhead from available financial data, it can either calculate overhead as a 

percentage of the material and labor costs, or labor costs alone. In either case, overhead 

as a percentage of net sales remains the same. Thus, DOE maintained its approach from 

the preliminary TSD by estimatingutilizing information available in the recent standards 

147
rulemaking for fluorescent lamp ballasts.34 In that rulemaking, DOE used financial data 

to estimate the overhead cost by calculating it as a percentage of the MPC. DOE 

estimated the depreciation cost from a representative electronics fabrication company’s 

U.S. Securities and Exchange Commission (SEC) 10-K, and determined that it is 

approximately 2.6 percent of the cost of goods sold or the MPC. To determine the 

material and labor percentage, DOE marked down aggregated confidential MSPs to an 

MPC using the manufacturer markup. Then, DOE computed the ratio of aggregated 

teardown-sourced material and labor costs to the manufacturer-markdown-sourced MPC. 

DOE found the material and labor costs to be approximately 93.8 percent of the MPC. 

DOE then subtracted the materials and labor and depreciation percentages from 100 

percent to back out the remainder of overhead as a percentage of MPC. Overhead was 

estimated to be 3.6 percent of the MPC, which is reasonable as electronics manufacturing 

generally has low overhead costs.. DOE found overhead and depreciation to be 6.2 

percent of the MPC or 6.6 percent of the material and labor costs. The 6.6 percent factor 

was then used to mark up the material and labor costs contained in the teardown results to 

the MPC.

b. Incremental Costs for Electronically Ballasted Fixtures

After determining metal halide ballast MPCs and baseline fixture MPCs, DOE 

considered whether transitioning from magnetic to electronic ballast technology would 

require any further ballast or fixture design changes to accommodate the electronic 

ballast or maintain similar utility to the baseline magnetic ballast. In the preliminary 

34 http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/62

148

 
analysis, DOE identified three potential sources of additional costs of switching from 

magnetic to electronic ballasts: increasing the size of the fixture to accommodate the new 

footprint of the electronic ballast; increasing the heat sinking of the fixture to reduce 

thermal build up; and including voltage transient suppression for outdoor applications.

Based on its initial evaluation, DOE did not include any of these incremental costs 

in the preliminary analysis. In response, Philips and Georgia Power emphasized that 

electronic ballasts are not direct replacements for magnetic ballasts due to form factor. 

(Philips Lighting Electronics, Public Meeting Transcript, No. 33 at p. 64; Georgia Power, 

No. 28 at p. 1) Georgia Power noted that redesign of magnetic ballast luminairefixture

housing and optics may be required to accommodate electronic ballasts. (Georgia Power, 

No. 28 at p. 1) NEEA did not agree that there are no fixture incremental costs associated 

with a switch to electronic ballasts. NEEA recommended that DOE derive some 

incremental cost values for the analysis, and to the extent possible, use a distribution of 

costs for the analysis, perhaps with zero at the bottom end. (NEEA, No. 31 at p. 5) 

While DOE agrees that fixtures may require redesign to accommodate a new form 

factor of ballast, based on its analysis of selected commercially available fixtures, DOE 

tentatively concludes that this redesign does not necessarily incur additional material or 

labor costs. Instead, DOE accounts for the capital conversion costs of redesigning fixtures 

in the MIA, as discussed in section V.I.2. However, for this NOPR, DOE further 

investigated three sources of potential incremental costs: (1) outdoor transient protection, 

(2) thermal management, and (3) 120 V auxiliary tapspower functionality.

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Outdoor transient protection

In response to the preliminary TSD, DOE received a number of comments 

indicating that electronic ballasts were unfit to be used outside because of their inability 

to withstand high voltage surges. Cooper commented that the ANSI standard for area and 

roadway lighting in the utility division, ANSI C62.41.1-2002, requires that outdoor 

lighting be able to withstand a voltage transient of 10 kV. (Cooper, Public Meeting 

Transcript, No. 33 at p. 78) Progress Energy Carolinas specified that an inline MOV (a 

surge-protection device external to the ballast) is required for electronic ballasts in 

outdoor luminairesfixture. (Progress Energy Carolinas, No. 24 at p. 3) In response, OSI 

and Empower Electronics commented that some electronic ballasts incorporate integral 

transient protection and do not require additional technology. (OSI, Public Meeting 

Transcript, No. 33 at p. 74; Empower Electronics, No. 36 at p. 5) Similarly, NEEA 

agreed that because many electronic ballasts have voltage transient protection built-in 

already, transient protection will not be an incremental cost in all cases. (NEEA, No. 31 

at p. 5)

DOE recognizes the necessity for outdoor fixtures to be able to withstand large 

voltage transients, primarily due to lightning strikes. While metal halide fixtures with 

magnetic ballasts are robust and do not require any additional devices or enhancements to 

withstand these transients, based on its evaluation of commercially available products, 

DOE finds that fixtures with electronic ballasts usually require additional design features 

in order to have adequate protection. Some manufacturers indicated that a portion of their 

150
electronic ballasts already have 10 kV surge protection built in, but most electronic 

ballasts are only rated for 2.5-6 kV voltage spikes. Though magnetic ballasts are known 

to provide protection in excess of the 10 kV ANSI C62.41.1-2002 Class C rating, for this

NOPR, DOE only considers the cost of just meeting the 10 kV requirement. Through 

interviews and an assessment of commercially available voltage-transient suppressors, 

DOE developed an incremental fixture cost of $19 for 10 kV inline (external to the 

ballast) surge protection for electronically ballasted outdoor fixtures.

Thermal Management

Commenters also indicated that electronic ballasts are more vulnerable than 

magnetic ballasts to high ambient temperatures, which, if not managed well, can cause 

premature ballast failure. In order to correct for this difference, fixtures housing 

electronic ballasts would need to be redesigned to account for thermal management in 

both indoor and outdoor applications.

NEMA expressed concern about electronic ballasts’ ability to operate at high 

ambient temperatures. (NEMA, Public Meeting Transcript, No. 33 at p. 16) NEMA noted 

that while magnetic ballasts can operate at temperatures as high as 150 o

C, electronic 

ballasts generally cannot operate at temperatures exceeding 90 o

C. This temperature limit 

makes it impossible to place electronic ballasts in a luminairefixture in the traditional 

location near the lamp. (NEMA, No. 34 at pp. 8-9) NEMA and Progress Energy 

Carolinas indicated that the sensitivity of electronics to thermal conditions requires

redesign of the fixture or ballast, such as larger ballast housing, thermal shields, or 

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luminairefixture venting to sink the heat outside of the fixture. (NEMA, No. 34. at pp. 8-

9; Progress Energy Carolinas, No. 24 at p. 3) NEMA noted that these requirements add 

additional materials, redesigning, engineering resources, testing, and cost. Costs would 

include material, engineering, UL testing, and warranty burden costs. (NEMA, No. 34. at 

pp. 8-9) 

In contrast, OSI explained that electronic ballasts are more efficient than magnetic 

ballasts, and, therefore, generate less heat and run at cooler temperatures. OSI 

commented that they manufacture an electronic metal halide ballast with a maximum 

allowable case temperature of 90 oC, and a maximum ambient temperature of 55 oC. 

These ballasts also use a power foldback feature to manage the temperature of the ballast 

and prevent damage to the ballast in extreme high-heat conditions. OSI has successfully 

retrofitted magnetically ballasted luminairesfixtures with these electronic ballasts and 

achieved thermal performance that met the requirements of their five-year warranty. 

(OSI, No. 27 at p. 2) Empower Electronics noted that several companies have made 

strides in managing thermal issues surrounding electronic ballasts with a maximum 

tolerable case temperature of 85 o

C. (Empower Electronics, No. 36 at p. 5)

DOE agrees that because of temperature sensitivity concerns, manufacturers 

cannot directly replace a magnetic ballast with an electronic ballast in fixtures. Instead, 

the fixtures must be redesigned to tolerate the higher sensitivity to temperature of an 

electronic ballast. Manufacturers must design new and often larger brackets, and apply 

additional potting material to create an adequate thermal contact between the ballast and 

152
fixture. During interviews, manufacturers gave DOE information about the cost to add 

thermal management to fixtures with electronic ballasts. In aggregate, manufacturers 

indicated a 20-percent increase in fixture MPCs associated with thermal management. 

Additionally, DOE conducted teardown analyses of empty metal halide fixtures. Through 

analysis of pairs of fixtures designed for electronic ballasts and fixtures designed for 

comparable magnetic ballasts, DOE also found an approximately 20-percent increase in 

fixture MPCs to include thermal management for electronic ballasts. Accordingly, in the 

cost analysis for this rulemaking, all electronically ballasted metal halide lamp 

fixturefixtures incur a 20-percent incremental cost to the empty fixture MPCs. 

120 V Auxiliary Tap

In manufacturer interviews, DOE learned that for indoor applications, a number 

of magnetic ballasts include a 120 V auxiliary tap. This output is used to operate an 

emergency incandescent lamp after a temporary loss of power and while the metal halide 

lamp is still too hot to restart. These taps, primarily used in indoor applications, are 

generally required for only one out of every ten indoor lamp fixtures. A 120 V tap is 

easily incorporated into a magnetic ballast due to its traditional core and coil design, and 

incurs a negligible incremental cost. Electronic ballasts, though, require additional design 

to add this 120 V auxiliary power functionality. Using a combination of manufacturer 

information and market research, DOE concluded that a representative value for 

electronic ballasts to incorporate this auxiliary tap is $7.50. Because these taps arethis 

functionality is only added toneeded for 10 percent of ballasts in indoor fixtures, that 

153
number is multiplied by 0.10 to get an incremental ballast cost of $0.75 per indoor 

ballast.

c. Manufacturer Markups

The last step in determining manufacturer selling prices is development and 

application of manufacturer markups to scale the MPCs to MSPs. DOE developed initial 

manufacturer markup estimates by examining the annual SEC 10-K reports filed by 

publicly traded manufacturers of metal halide ballasts and metal halide lamp fixtures, 

among other products. DOE recognized that the financial information summarized in the 

10-K reports is not usually exclusive to the metal halide portion of their businesses. To 

account for this, DOE asked manufacturers during interviews to comment on the 

calculated average MSP, and to provide both the manufacturer markup and manufacturer 

selling price of metal halide ballasts or metal halide lamp fixtures. Using this

information, DOE determined in the preliminary TSD that a manufacturer markup of 1.47 

was appropriate for both the metal halide ballast and fixture industries across all 

distribution channels. 

In the preliminary TSD, DOE assumed that fixture manufacturers would not apply 

an additional markup to the ballasts they either purchase or manufacture in-house. Philips 

commented that a manufacturer would not carry the overhead of manufacturing their own 

ballasts if they could realize the same overall margin by purchasing one from a third 

party. Therefore, Philips found it unreasonable to use a single markup on the ballast. 

(Philips, Public Meeting Transcript, No. 33 at p. 74) NEEA suggested that DOE use 

154
separate markups for ballast manufacturers and fixture manufacturers, with the ballast 

manufacturer markup split into one value for the Original Equipment Manufacturer 

(OEM) channel and one value for the distributor channel. (NEEA, No. 31 at p. 4) NEEA 

also indicated that DOE should take into account the unique distribution channel for 

outdoor fixtures in its analysis when estimating markups and pricing for fixtures. (NEEA, 

No. 31 at p. 5)

DOE has revised its markup structure for today’s NOPR. Based on feedback from 

manufacturers, DOE now uses separate markups for ballast manufacturers (1.47) and 

fixture manufacturers (1.58). DOE also assumes that fixture manufacturers apply the 1.58 

markup to the ballasts used in their fixtures rather than to only the empty fixtures as 

assumed in the preliminary TSD. This assumption is consistent with feedback from both 

fixture manufacturers that purchase their ballasts and those that produce their ballasts inhouse. In aggregate, the markup also accounts for the different markets served by fixture 

manufacturers. The 1.47 markup for ballast manufacturers now applies only to ballasts 

sold to fixture OEMs directly impacted by this rulemaking. For the purpose of the LCC 

analysis, DOE assumes a higher markup of 1.60 for ballasts that are sold to distributors 

for the replacement market.

D. Markups to Determine Equipment Price

By applying markups to the MSPs estimated in the engineering analysis, DOE 

estimated the amounts consumerscustomers would pay for baseline and more efficient 

equipment. At each step in the distribution channel, companies mark up the price of the 

155
equipment to cover business costs and profit margin. Identifying the appropriate markups 

and ultimately determining consumercustomer equipment price depend on the type of 

distribution channels through which the equipment moves from manufacturer to 

consumercustomer.

1. Distribution Channels

Before it could develop markups, DOE needed to identify distribution channels 

(i.e., how the equipment is distributed from the manufacturer to the end-user) for the 

metal halide lamp fixture designs addressed in this rulemaking. DOE assumed aIn an 

electrical wholesaler distribution channel where, DOE assumed the fixture manufacturer 

sells the fixture to an electrical wholesaler (i.e., distributor), who in turn sells it to a 

contractor, who sells it to the end-user. In a contractor distribution channel, DOE 

assumed the fixture manufacturer sells the fixture directly to a contractor, who sells it to 

the end-user. In a utility distribution channel, DOE assumed the fixture manufacturer 

sells the fixture directly to the end-user (i.e., electrical utility).

2. Estimation of Markups

To estimate wholesaler and utility markups, DOE used financial data from 10-K 

reports from publicly owned electrical wholesalers and utilities. DOE’s markup analysis 

developed both baseline and incremental markups to transform the fixture MSP into an 

end-user equipment price. DOE used the baseline markups to determine the price of 

baseline designs. Incremental markups are coefficients that relate the change in the MSP 

of higher-efficiency designs to the change in the wholesaler and utility sales prices. These 

156
markups refer to higher-efficiency designs sold under market conditions with new and 

amended energy conservation standards. 

In the preliminary analysis, DOE assumed a wholesaler baseline markup of 1.23 

and a contractor baseline markup of 1.13, for a total wholesaler distribution channel 

baseline markup of 1.39 (excluding sales tax). In the public meeting, Philips inquired 

about documentation for these values. (Philips, Public Meeting Transcript, No. 33 at p. 

89) DOE responded that these values were consistent with values used in other lightingrelated rules (e.g., for fluorescent lamp ballasts), and that DOE would review the values. 

In its manufacturer interviews and background research, DOE confirmed that although 

the individual values for wholesaler and contractor markups varied, the total value was 

consistent with actual markups. For this proposed rule, DOE retained its wholesaler and 

contractor markups, and also assumed utility baseline markups of 1.00 and 1.13 for the 

utility distribution channel in which the manufacturer sells a fixture directly to the enduser, and the channel in which a manufacturer sells a fixture to a contractor who in turn 

sells it to the end-user, respectively.

The sales tax represents state and local sales taxes applied to the end-user 

equipment price. For the preliminary analysis, DOE obtained state and local tax data 

from the Sales Tax Clearinghouse.35 These data represent weighted averages that include 

state, county, and city rates. DOE then calculated population-weighted average tax values 

for each census division and large state, and then derived U.S. average tax values using a 

35 The Sales Tax Clearinghouse. Available at https://thestc.com/STRates.stm. (Last accessed July 11, 

2011June 24, 2013.)

157

 
population-weighted average of the census division and large state values. This approach 

provided a national average tax rate of 7.2613 percent. DOE received no comments 

related to sales tax, and retained its approach for this proposed rule.

3. Summary of Markups

Table V.4 summarizes the markups at each stage in the distribution channels and 

the overall baseline and incremental markups, and sales taxes, for each of the three 

identified channels.

Table V.4 Summary of Fixture Distribution Channel Markups

Wholesaler Distribution

Utility Distribution

Via Wholesaler & 

Contractor Direct to End-User

Baseline Incremental Baseline Incremental Baseline Incremental

Electrical 

Wholesaler 

(Distributor)

1.23 1.05 N/A N/A N/A N/A

Utility N/A N/A 1.00 1.00 1.00 1.00

Contractor 

or Installer 1.13 1.13 1.13 1.13 N/A N/A

Sales Tax 1.07 1.07 1.07

Overall 1.3949 1.1927 1.21 1.21 1.07 1.07

Using these markups, DOE generated fixture end-user prices for each efficiency 

level it considered, assuming that each level represents a new minimum efficiency 

standard. Chapter 6 of the NOPR TSD provides additional detail on the markups analysis.

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E. Energy Use Analysis

For the energy use analysis, DOE estimated the energy use of metal halide lamp 

fixtures in actual field conditions. The energy use analysis provided the basis for other 

DOE analyses, particularly assessments of the energy savings and the savings in 

operating costs that could result from DOE’s adoption of new and amended standard 

levels.

To develop annual energy use estimates for the preliminary analysis, DOE 

multiplied annual usage (in hours per year) by the lamp and ballast system input power 

(in watts). DOE characterized representative lamp and ballast systems in the engineering 

analysis, which provided measured input power ratings. To characterize the country’s 

average use of fixtures for a typical year, DOE developed annual operating hour 

distributions by sector, using data published in the 2010 U.S. Lighting Market 

Characterization:(LMC),36 the Commercial Building Energy Consumption Survey 

(CBECS),37 and the Manufacturer Energy Consumption Survey (MECS).38 NEMA 

agreed with this approach. (NEMA, No. 34 at p. 17)

36 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. 2010 U.S. Lighting 

Market Characterization. Volume I: National Lighting Inventory and Energy Consumption Estimate.

2002.2010. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf. 37 U.S. Department of Energy, Energy Information Agency. Commercial Building Energy Consumption 

Survey: Micro-Level Data, File 2 Building Activities, Special Measures of Size, and Multi-building 

Facilities. 2003. Available at www.eia.doe.gov/emeu/cbecs/public_use.html. 38 U.S. Department of Energy, Energy Information Agency. Manufacturing Energy Consumption Survey, 

Table 1.4: Number of Establishments Using Energy Consumed for All Purpose. 2006. Available at 

www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html.

159

 
In the preliminary analysis, DOE assumed the different operating hours for 

commercial and industrial (typically indoor) fixtures and for outdoor fixtures. NEMA 

stated that outdoor equipment operates largely at night. (NEMA, No. 34 at p. 21) NEEA 

did its own analysis of fixture operating hours and generally supported the estimates 

DOE used in the preliminary analysis. (NEEA, No. 31 at p.6) For this proposed rule, 

DOE revised its assumed fixture operating hours to better distinguish indoor and outdoor 

applications.

DOE’s preliminary energy use analysis assumed full operating power and no 

dimmed operation. NEMA suggested that HID dimming is possible, but significantly 

increases ballast and fixture cost, whereas fluorescent or other lighting technologies can 

be more easily and affordably dimmed. (NEMA, No. 34 at p. 8) OSI confirmed that they 

are developing dimming electronic ballasts for metal halide lamp fixtures. (OSI, No. 27 at 

p.3) DOE maintains that dimming is still a small portion of the MH market, however, and 

did not assume dimmed operation in the energy use analysis for this proposed rule.

Chapter 7 of the NOPR TSD provides a more detailed description of DOE’s energy use 

analysis. DOE is seeking data and information on the energy use analysis.

F. Life-Cycle Cost and Payback Period AnalysesAnalysis

DOE conducted the LCC and PBP analysis to evaluate the economic effects of 

potential energy conservation standards for metal halide lamp fixtures on individual 

consumerscustomers. For any given efficiency level, DOE measuresmeasured the PBP 

and the change in LCC relative to an estimated baseline equipment efficiency level. The 

Comment [AGA16]: Added at the request of 

OIRA.

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LCC is the total consumercustomer expense over the life of the equipment, consisting of 

purchase, installation, and operating costs (expenses for energy use, maintenance, and 

repair). To compute the operating costs, DOE discounted future operating costs to the 

time of purchase and summed them over the lifetime of the equipment. The PBP is the 

estimated amount of time (in years) it takes consumerscustomers to recover the increased 

purchase cost (including installation) of more efficient equipment through lower 

operating costs. DOE calculates the PBP by dividing the change in purchase cost 

(normally higher) by the change in average annual operating cost (normally lower) that 

results from the more efficient standard.

Inputs to the calculation of total installed cost include the cost of the equipment—

which includes MSPs, distribution channel markups, and sales taxes—and installation 

costs. Inputs to the calculation of operating expenses include annual energy consumption, 

energy prices and price projections, repair and maintenance costs, equipment lifetimes, 

discount rates, and the year that compliance with new and amended standards is required. 

To account for uncertainty and variability, DOE created value distributions for selected 

inputs, including operating hours, electricity prices, discount rates, and sales tax rates. 

For example, DOE created a probability distribution of annual energy consumption in its 

energy use analysis, based in part on a range of annual operating hours. The operating 

hour distributions capture variations across building types, lighting applications, and 

metal halide systems for three sectors (commercial, industrial, and outdoor stationary). In 

contrast, fixture MSPs were specific to the representative designs evaluated in DOE’s 

engineering analysis, and price markups were based on limited publicly available 

161
financial data. Consequently, DOE used discrete values instead of distributions for these 

inputs.

The computer model DOE uses to calculate the LCC and PBP, which incorporates 

Crystal Ball (a commercially available software program), relies on a Monte Carlo 

simulation to incorporate uncertainty and variability into the analysis. The Monte Carlo 

simulations randomly sample input values from the probability distributions and fixture 

user samples. NOPR TSD chapter 8 and its appendices provide details on the spreadsheet 

model and all the inputs to the LCC and PBP analysis.

Table V.5 summarizes the approach and data DOE used to develop inputs to the 

LCC and PBP calculations for the April 2011 preliminary TSD as well as the changes 

made for today’s NOPR. The subsections that follow discuss the initial inputs and DOE’s 

changes to them.

Table V.5 Summary of Inputs and Key Assumptions in the LCC and PBP Analysis*

Inputs Preliminary TSD Changes for the Proposed Rule

Equipment Cost Derived by multiplying MHLF MSPs 

by distribution channel markups and 

sales tax

No change

Installation Cost DerivedCalculated costs using 

estimated labor times and applicable 

labor rates from RS Means Electrical 

Cost Data (2009) and U.S. Bureau of 

Labor Statistics

No changeCalculated costs using 

estimated labor times, and 

applicable labor rates from RS 

Means Electrical Cost Data

(2010) and U.S. Bureau of Labor 

Statistics

Annual Energy Use Determined operating hours by 

associating building-type-specific 

operating hours with distributions of 

various building types using lighting 

market and building energy 

consumption survey data: LMC 

(2002), CBECS (2003), and MECS 

Determined operating hours separately 

for indoor and outdoor fixtures. Used 

lighting market and building energy 

consumption survey data: LMC 

(2002), CBECS (2003), and 

MECS (20062012)

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(2006)

Energy Prices Electricity: Based on EIA’s Form 861 

data for 2010

Electricity: Based on EIA’s Form 826

data for 2012

Variability: Energy prices determined at 

state level; incorporateincorporated

off-peak electricity prices in the Monte 

Carlo analysis

Energy Price 

Projections

ForecastedProjected using 

AEO2010

ForecastedProjected using 

AEO2011AEO2013

Replacement Costs Included labor and material costs for 

lamp and ballast replacement at the 

end of its lifetimetheir lifetimes

No change

Equipment Lifetime Ballasts: Assumed 50,000 hours for 

magnetic ballasts and 30,000 hours for 

electronic ballasts

Fixtures: Assumed as 20 years for 

indoor fixtures and 25 years for 

outdoor fixtures 

Ballasts: Assumed 50,000 hours for 

magnetic ballasts and 40,000 hours for 

electronic ballasts

Fixtures: No change

Discount Rates Commercial/Industrial: Estimated cost 

of capital to affected firms and 

industries; developed weighted 

average of the cost to the company of 

equity and debt financing

Outdoor Stationary: Assumed to be 

the same as commercial sector

Commercial/Industrial: Developed a 

distribution of discount rates for each 

end-use sector

Outdoor Stationary: Developed a 

distribution of discount rates for each 

end-use sector

Compliance Date 

of Standards

2015 No change

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the NOPR 

TSD.

1. ProductEquipment Cost

To calculate consumercustomer equipment costs, DOE multiplied the MSPs 

developed in the engineering analysis by the distribution channel markups described in 

section V.D.1 (along with sales taxes). DOE used different markups for baseline 

equipment and higher-efficiency equipment because the markups estimated for 

incremental costs differ from those estimated for baseline models. 

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For the April 2011 preliminary TSD, DOE assumed that the MSPs and retail 

prices of products meeting various efficiency levels remain fixed, in real terms, after 

2010 (the year for which the engineering analysis estimated costs) and throughout the 

analysis period. Subsequently, examination of historical price data for various appliances 

and equipment indicates that the assumption of constant real prices and costs may, in 

many cases, overestimate long-term appliance and equipment price trends. Economic 

literature and historical data suggest that the real costs of these products may in fact trend 

downward over time, partially because of “learning” or “experience.”39

On February 22, 2011, DOE published a notice of data availability (February 

2011 NODA; 76 FR 9696) stating that DOE may consider improving regulatory analysis 

by addressing equipment price trends. DOE notes that learning-curve analysis 

characterizes the reduction in production cost mainly associated with labor-based 

performance improvement and higher investment in new capital equipment at the 

microeconomic level. Experience-curve analysis tends to focus more on entire industries 

and aggregates over various casual factors at the macroeconomic level: “Experience 

curve” and “progress function” typically represent generalizations of the learning concept 

to encompass behavior of all inputs to production and cost (i.e., labor, capital, and 

materials). The economic literature often uses these two terms interchangeably. The term 

“learning” is used here to broadly cover these general macroeconomic concepts.

39 A draft paper, Using the Experience Curve Approach for Appliance Price Forecasting, posted on the 

DOE web site at www.eere.energy.gov/buildings/appliance_standards, provides a summary of the data and 

literature currently available to DOE that is relevant to price forecasts for selected appliances and 

equipment.

164

 
For this proposed rule and consistent with the February 2011 NODA, DOE 

examined two methods for estimating price trends for metal halide lamp fixtures: using 

historical producer price indices (PPIs), and using forecastedprojected price indices 

(called deflators). With PPI data, DOE found both positive and negative real price trends, 

depending on the specific time period examined, and did not use this method to adjust 

fixture prices. DOE instead adjusted fixture prices using deflators used by EIA to develop 

the AEO. When adjusted for inflation, the deflator-based price indices decline from 100 

in 2010 to approximately 76 in 2044. 2045.

DOE invites comment on methods to improve its fixture price 

forecastingprojections beyond the assumption of constant real prices, as well as any data 

supporting alternate methods. A more detailed discussion of price trend modeling and 

calculations is provided in appendix 8A8B of the NOPR TSD.

2. Installation Cost

Installation costs for metal halide lamp fixtures include the costs to install the 

fixture, maintain the ballast, and replace the lamp. For the April 2011 preliminary TSD, 

DOE used data collected for its July 2010 HID lamps determination,40 labor rates for 

electricians from RS Means,

41 and other research to estimate the installation costs. DOE 

annualized maintenance costs in its preliminary analysis, and NEEA questioned why 

40 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy Conservation 

Program for Consumer Equipment: Preliminary Technical Support Document: High-Intensity Discharge 

Lamps. 2010. Washington, D.C. 

<www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/60> 41 R.S. Means Company, Inc. 2010 RS Means Electrical Cost Data. 2010. Kingston, MA. 

165

 
DOE annualized costs that do not occur annually, but rather occur periodically during the 

equipment lifetime. (NEEA, Public Meeting Transcript, No. 33 at p. 102) For this NOPR, 

DOE developed a methodology that allows the use of annualized maintenance costs while 

maintaining the integrity of the NPV calculations in the NIA. For further detail, see 

chapter 8 of the NOPR TSD. 

3. Annual Energy Use

As discussed in section V.E, DOE estimated the annual energy use of 

representative metal halide systems using system input power ratings and sector 

operating hours. The annual energy use inputs to the LCC and PBP analysis are based on 

weighted average annual operating hours, whereas the Monte Carlo simulation draws on 

a distribution of annual operating hours to determine annual energy use.

4. Energy Prices

For the April 2011 preliminary TSD, DOE developed weighted average energy 

prices for 13 U.S. geographic areas consisting of the 9 census divisions, with 4 large 

states (1. California, 2. Florida, 3. New York, Florida,and 4. Texas, and California) 

treated separately. For census divisions containing one of these large states, DOE 

calculated the regional average excluding the data for the large state. Prices were based 

on data from EIA Form 826, “Monthly Electric Utility Sales and Revenue Data, 2011.” 

GE commented that metal halide lighting is commonly used outdoors during off-peak 

hours, and recommended that DOE account for off-peak electricity prices in the analysis. 

(GE, Public Meeting Transcript, No. 33 at p. 135) For this proposed rule, DOE 

166
incorporated off-peak electricity pricing by using a distribution of percentages of average 

electricity prices in its Monte Carlo analysis, from which a lower average electricity price 

for the outdoor sector was calculated and used in the main LCC analysis. For more 

information, see chapter 8 of the NOPR TSD. 

5. Energy Price Projections

To estimate the trends in energy prices, DOE used the price forecastsprojections

in AEO2011AEO2013. To arrive at prices in future years, DOE multiplied current 

average prices by the forecastprojected of annual average price changes in 

AEO2011AEO2013. Because AEO2011 forecastsAEO2013 projects prices to 20352040, 

DOE followed past EIA guidelines and used the average rate of change from 20202010 to 

20352040 to estimate the price trend for electricity after 20352040. In addition, the 

spreadsheet tools that DOE used to conduct the LCC and PBP analysesanalysis allow 

users to select price forecasts from the AEO low-growth, high-growth, and reference-case 

scenarios to estimate the sensitivity of the LCC and PBP to different energy price 

forecasts. DOE received no comments on the April 2011 preliminary TSD concerning its 

energy price forecastingprojecting method for the LCC analysis, and retained this 

approach for this proposed rule. During the course of this rulemaking, AEO2011 was 

released and DOE is using AEO2011 for the NOPR phase.

6. Replacement Costs

In the April 2011 preliminary TSD, DOE addressed ballast and lamp 

replacements that occur within the LCC analysis period. Replacement costs include the 

167
labor and materials costs associated with replacing a ballast or lamp at the end of their 

lifetimes and are annualized across the years preceding and including the actual year in 

which equipment is replaced. For the LCC and PBP analysis, the analysis period 

corresponds with the fixture lifetime that is assumed to be longer than that of either the 

lamp or the ballast. For this reason, ballast and lamp prices and labor costs are included in 

the calculation of total installed costs. DOE received comments regarding its annualizing 

approach concerning replacement costs for the LCC analysis in its April 2011 

preliminary TSD and developed a new annualizing methodology for this proposed rule.

(NEEA, Public Meeting Transcript, No. 33 at p. 103)

7. Equipment Lifetime

For the April 2011 preliminary TSD, DOE defined equipment lifetime as the age 

(in hours in operation) when a fixture, ballast, or lamp is retired from service. For fixtures 

in all equipment classes, DOE assumed lifetimes for indoor and outdoor fixtures of 20 

and 25 years, respectively.

Metal halide lamp fixtures are operated by either magnetic or electronic ballasts. 

In the April 2011 preliminary analysis, DOE assumed that magnetic ballasts last for 

50,000 hours and electronic ballasts last for 30,000 hours. NEMA and Empower 

Electronics agreed with DOE’s general estimates about magnetic and electronic ballast 

lifetimes, but NEMA cautioned that fixtures are often removed before end of service life,

especially as new energy-efficient alternatives appear on the market. (NEMA, No. 34 at 

p. 18; Empower Electronics, No. 36 at p. 11) Similarly, Philips noted that ballasts may be 

168
replaced prior to physical failure. (Philips, Public Meeting Transcript, No. 33 at p. 107)

OSI suggested an average rated life of 50,000 hours for electronic ballasts, and agreed 

with NEMA and Philips that fixtures may be replaced before end of service life. (OSI, 

No. 27 at p. 6) The California IOUs believed that DOE underestimated electronic ballast 

lifetime by as much as twofold based on their experience with electronic ballast 

manufacturers. (California IOUs, No. 32 at p. 3) Finally, NEEA suggested that DOE use 

a distribution of ballast lifetimes for LCC and other analyses. (NEEA, No. 31 at p. 7)

DOE notes that actual ballast lifetime data are limited. However, based on 

comments and additional research, DOE revised its average electronic ballast lifetime to 

40,000 hours and maintained its average lifetime of 50,000 hours for magnetic ballasts 

for this proposed rule. DOE agrees that ballast lifetimes can vary due to both physical 

failure and economic factors (e.g., early replacements due to retrofits). Consequently, 

DOE accounted for variability in lifetime in LCC and PBP via the Monte Carlo 

simulation, and in the shipments and NIA analyses by assuming a Weibull distribution 

for lifetimes to accommodate failures and replacements

42.

Metal halide lamp lifetimes vary by fixture equipment class. For the April 2011 

preliminary TSD, DOE assumed that lamps in the 70 W, 250 W, 400 W, and 1000 W 

equipment classes operate for 12,000, 15,000, 20,000, and 12,000 hours, respectively. 

Commenters noted that lamp lifetime can vary with operating position (e.g., vertical, 

horizontal, or tilted), and recommended that DOE consider this variation in developing

42 Weibull distribution is a probability density function; for more information, see 

www.itl.nist.gov/div898/handbook/eda/section3/eda3668.htm.

169

 
weighted-average lamp lifetimes. (GE, Public Meeting Transcript, No. 33 at p. 97; 

Hubbell, Public Meeting Transcript, No. 33 at p. 98) DOE agrees with the comments, and 

surveyed published MH lamp life ratings in developing weighted-average lamp lifetimes 

for this proposed rule.

Some public meeting participants asked about the effects of ballast type (i.e., 

magnetic vs. electronic) on lamp life. (ASAP, Public Meeting Transcript, No. 33 at p. 98; 

Energy Solutions Public Meeting Transcript, No. 33 at p. 104) Hubbell and Philips 

acknowledged the lack of industry consensus on this subject and the variability of related 

lifetime data between manufacturers. (Hubbell, Public Meeting Transcript, No. 33 at p. 

98; Philips, Public Meeting Transcript, No. 33 at p. 104) Based on its review of industry 

data and literature, DOE could not substantiate the effect of ballast type on MH lamp 

lifetimes, and used published lamp life ratings only in developing weighted-average lamp 

lifetimes for this proposed rule.

8. Discount Rates

The discount rate is the rate at which future expenditures are discounted to 

estimate their present value. In the April 2011 preliminary TSDthis NOPR, DOE 

estimated separate discount rates for commercial and, industrial consumers. The discount 

rate used for the and outdoor stationary sector is assumed to be the same as the commercial 

sector discount rate.customers. For all such consumerscustomers, 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 of 

170
equity and debt financing. For the proposed rule, DOE also developed a distribution of 

discount rates for each end-use sector from which the Monte Carlo simulation samples.

For the industrial and commercial sectorsFor each sector, DOE assembled data on 

debt interest rates and the cost of equity capital for representative firms that use metal 

halide lamp fixtures. DOE determined a distribution of the weighted-average cost of 

capital for each class of potential owners using data from the Damodaran online financial 

database.43 DOE used the same distribution of discount rates for the commercial and 

industrial sectors. The average discount rates, weighted by the shares of each rate value in 

the sectoral distributions, are 6.94.5 percent for commercial end-users and 7.2, 4.3

percent for industrial end-users, and 3.4 percent for outdoor stationary end-users. 

DOE received no comments on the April 2011 preliminary TSD concerning its 

estimated discount rates for the LCC analysis and retained this approach for this proposed 

rule.

1. Effective Date of Standards

9. The effective date is the date when fixture manufacturers must manufacture equipment 

that complies with the new and amended standards. DOE’s publication of a final rule in 

this standards rulemaking is scheduled for completion in 2012. The effective date of any 

new energy conservation standards for metal halide lamp fixtures or amended energy 

43 The data are available at pages.stern.nyu.edu/~adamodar. 

171

 
conservations standards is January 1, 2015. (42 U.S.C. 6295(hh)(2)(B)(ii)) Analysis 

Period

DOE calculated the LCC for all end-users as if each one would purchase a new 

fixture in the year compliance with the standard is required2016.

9.10. Fixture Purchasing Events

DOE designed the LCC and PBP analysesanalysis for this rulemaking around 

scenarios where consumerscustomers need to purchase a metal halide lamp fixture. The 

“event” that prompts the purchase of a new fixture (either a ballast failure or new 

construction/renovation) was assumed to influence the cost-effectiveness of the 

consumercustomer purchase decision. DOE assumed that a consumercustomer will 

replace a failed fixture with an identical fixture in the base case, or a new standardscompliant fixture with comparable light output in the standards case. DOE analyzed five 

representative equipment classes for fixtures and presented the results for each of these 

representative equipment classes by fixture purchasing event, which influenced the LCC 

and PBP results.

DOE received no comments on the April 2011 preliminary TSD concerning its 

assumed fixture purchasing events for the LCC analysis and retained this approach for 

this proposed rule.

172
G. National Impact Analysis–National Energy Savings and Net Present Value Analysis

DOE’s NIA assessed the national energy savings (NES) and the national net 

present value (NPV) of total consumercustomer costs and savings that would be expected 

to result from new or amended standards at specific efficiency levels. 

(“ConsumerCustomer” in this context refers to users of the regulated equipment.)

DOE used a Microsoft Excel spreadsheet model to calculate the energy savings 

and the national consumercustomer costs and savings from each TSL. The TSD and other 

documentation for the rulemaking help explain the models and how to use them, allowing 

interested parties to review DOE’s analyses by changing various input quantities within 

the spreadsheet.

DOE used the NIA spreadsheet to calculate the NES and NPV, based on the 

annual energy use and total installed cost data from the energy use and LCC analyses. 

DOE forecastedprojected the energy savings, energy cost savings, equipment costs, and 

NPV of consumercustomer benefits for each equipment class for equipment sold from 

20152016 through 20442045. The forecastsprojections provided annual and cumulative 

values for all four output parameters.

DOE evaluated the impacts of new and amended standards for metal halide lamp 

fixtures by comparing base-case projections with standards-case projections. The basecase projections characterize energy use and consumercustomer costs for each equipment 

class in the absence of new or amended energy conservation standards. DOE compared 

173
these projections with projections characterizing the market for each productequipment

class if DOE adopted new or amended standards at specific energy efficiency levels (i.e., 

the TSLs or standards cases) for that class. In characterizing the base and standards cases, 

DOE considered historical shipments, the mix of efficiencies sold in the absence of new 

standards, and how that mix may change over time. Additional information about the 

NIA spreadsheet is in the NOPR TSD chapter 11.

Table V.6 summarizes the approach and data DOE used to derive the inputs to the 

NES and NPV analyses for the April 2011 preliminary TSD, as well as the changes to the 

analyses for the proposed rule. A discussion of selected inputs and changes follows. See 

chapter 11 of the NOPR TSD for further details.

Table V.6 Approach and Data Used for National Energy Savings and 

ConsumerCustomer Net Present Value Analyses

Inputs Preliminary TSD Changes for the Proposed Rule

Shipments Developed annual shipments 

from shipments model

See Table V.7

Compliance Date of Standard 2015 No change

Annual Energy Consumption per 

Unit

Established in the energy use 

characterization (preliminary 

TSD chapter 7)

See section V.E

Rebound Effect 0% No change

Electricity Price Forecast AEO2010 AEO2011AEO2013

Energy Site-to-Source Conversion 

Factor

Assumed to be constant across 

time: 1 site kWh = 10,239 

source Btu 

Used annually variable site kWh 

to source Btu conversion 

factors]factor

Discount Rate 3% and 7% real No change

Present Year 2011 2013No change

1. Shipments

Equipment shipments are an important component of any estimate of the future 

impact of a standard. Using a three-step process, DOE developed the shipments portion 

174
of the NIA spreadsheet, a model that uses historical data as a basis for projecting future 

fixture shipments. First, DOE used a combination of historical fixture shipment data from 

the U.S. Census Bureau for HID fixtures from 1993 to 2001. DOE correlated the HID 

fixture data with HID lamp data from 1990 to 2010 from the HID lamps rulemaking 

(EERE-2010-BT-STD-0043). Fixture shipments correlated to roughly a third of lamp 

shipments. DOE applied this fixture-to-lamp correlation to the larger and more detailed 

data set of HID lamp data to estimate the total historical shipments of each fixture type 

analyzed. Second, DOE estimated an installed stock for each fixture in 20152016 based 

on the average service lifetime of each fixture type. Third, DOE developed annual 

shipment projections for 2015–20442016–2045 by modeling fixture purchasing events, 

such as replacement and new construction, and applying growth rate, replacement rate, 

and alternative technologies penetration rate assumptions. For details on the shipments 

analysis, see chapter 10 of the NOPR TSD. DOE is seeking comment on whether the 

assumptions and methods used to project MHLF shipments are reasonable and likely to 

occur. DOE is also seeking data and information that could be used to refine DOE’s 

estimates. DOE also requests comment on the impediments that prevent users of metal 

halide lamp fixtures from switching to LED lighting to garner further energy savings. Comment [AGA17]: Revision requested by 

OIRA

175
Table V.7 Approach and Data Used for the Shipments Analysis

Inputs Preliminary TSD Changes for the Proposed Rule

Historical Shipments Used historical shipments for 1990–2008 

to develop shipments and stock 

projections for the analysis period

Used historical MH lamp shipments 

for 1990–2010 to develop 

shipments and stock projections for 

MH fixtures

Fixture Stock Based projections on the shipments that 

survive up to a given date; assumed 

Weibull lifetime distribution

No change

Growth Adjusted based on fixture market No change

Base Case Scenarios Analyzed one scenario incorporating 

alternative technologies encroaching on 

fixture shipments

Developed “low” and “high” 

shipments scenarios

Standards Case 

Scenarios

Analyzed Roll-up and Shift scenarios Analyzed Roll-up only

a. Historical Shipments

For the April 2011 preliminary TSD, DOE reviewed U.S. Census Bureau data 

from 1993 to 2001 for metal halide lamp fixtures.44 DOE compared the MHLF census 

data to NEMA data for historical metal halide lamp shipments from 1990 to 2008 taken 

from DOE’s final determination for HID lamps published on July 1, 2010. 75 FR 37975. 

DOE found a correlation between metal halide lamp fixture and metal halide lamp 

shipments. From 1993 to 2001, the number of MHLF shipments on average represented 

37 percent of the amount of lamp shipments, with a standard deviation of 3 percent. 

Using this relationship, DOE multiplied all of the metal halide lamp shipments from 1990 

to 2010 by 37 percent to estimate the historical shipments of metal halide lamp fixtures. 

DOE received no comments on the April 2011 preliminary TSD regarding historical 

fixture shipments data and estimates and retains this approach for this proposed rule.

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

Fluorescent Lamp Ballasts, MQ335C. 2008. (Last accessed September 1, 2010). <www.census.gov/mcd/> 

176

 
b. Fixture Stock Projections

In its preliminary shipments analysis, DOE calculated the installed fixture stock 

using historical fixture shipments estimated from U.S. Census Bureau Current Industrial 

Reports data (1993–2001), data from the HID lamps rule, and its projected shipments for 

future years. DOE estimated the installed stock during the analysis period by using 

fixture shipments and calculating how many will survive up to a given year based on a 

Weibull lifetime distribution for each fixture type. DOE received no comments on the 

April 2011 preliminary TSD regarding its fixture stock projection method and retained 

this approach for this proposed rule.

c. Base Case Shipment Scenarios

For the April 2011 preliminary TSD, DOE’s forecastprojection showed fixture 

shipments increasing until 2020 and then declining. Several manufacturers stated that 

DOE’s forecastprojection overestimated fixtures shipments in the near term. (Acuity, 

Cooper, GE, Philips, Public Meeting Transcript, No. 33 at pp. 112 - 120) Philips noted 

that T5 and T8 fluorescent systems are already displacing metal halide systems, with 

solid-state lighting also starting to penetrate the metal halide lamp fixture market. 

(Philips, Public Meeting Transcript, No. 33 at p. 113) DOE revisited its preliminary 

fixture shipment estimates and manufacturer interview data, and revised its 

forecastsprojections downward for this proposed rule. DOE assumed that shipments for 

metal halide lamp fixtures would peak somewhere between 2010 and 2015. From the 

manufacturer interviews, DOE was able to approximate the shipments in 2010. Through 

separate data, additional assumptions, and research, DOE was able to approximate the 

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same shipments in 2010 in the DOE model. In the “low” shipment scenario, DOE 

reviewed trends in replacement technologies and forecastedprojected a decline such that

the 2040 shipment forecastprojection fell back to the level of the 2000 shipments. In the 

“high” scenario, the decline in metal halide lamp fixture shipments is not as large as in 

the “low” scenario. The shipments in the “high” scenario in 2040 roughly equal the 

shipments in 2006.

d. Standards Case Efficiency Scenarios

Several of the inputs for determining NES (e.g., the annual energy consumption 

per unit) and NPV (e.g., the total annual installed cost and the total annual operating cost 

savings) depend on equipment efficiency. For the April 2011 preliminary TSD, DOE 

used two shipment efficiency scenarios: “Roll-up” and “Shift.” DOE received no 

comments on its efficiency scenarios, but eliminated the Shift scenario and retained the 

Roll-up scenario for this proposed rule. The Roll-up scenario is a standards case in which 

all equipment efficiencies in the base case that do not meet the standard would ‘roll up’ to 

the lowest level that can meet the new standard level. Equipment efficiencies in the base 

case above the standard level are unaffected in the Roll-up scenario, as these 

consumerscustomers are assumed to continue to purchase the same base-case fixtures. 

The Roll-up scenario characterizes consumerscustomers primarily driven by the first -

cost of the analyzed equipment, which DOE believes more accurately characterizes the 

metal halide lamp fixture marketplace.

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2. Site-to-Source Energy Conversion 

To estimate the national energy savings expected from appliance standards, DOE 

uses a multiplicative factor to convert site energy consumption into primary or source 

energy consumption (the energy required to convert and deliver the site energy). These 

conversion factors account for the energy used at power plants to generate electricity and 

losses in transmission and distribution, as well as for natural gas losses from pipeline 

leakage and energy used for pumping. For electricity, the conversion factors vary over 

time due to projected changes in generation sources (i.e., the types of power plants 

projected to provide electricity to the country). The factors that DOE developed are 

marginal values, which represent the response of the system to an incremental decrease in 

consumption associated with appliance standards.

For the April 2011 preliminary TSD, DOE used the average of all annual site-tosource conversion factors based on the version of NEMS that corresponds to AEO2010, 

which provides energy forecasts through 2035. For 2036–20432044, DOE used 

conversion factors that remain constant at the 2035 values.

DOE has historically presented NES in terms of primary energy savings. In 

response to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle 

Measurement Approaches to Energy Efficiency Standards” appointed by the National 

Academy of Science, DOE announced its intention to use FFC measures of energy use 

and greenhouse gas and other emissions in the national impact analyses and emissions 

analyses included in future energy conservation standards rulemakings. 76 FR 51281 

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(August 18, 2011) While DOE stated in that notice that it intended to use the Greenhouse 

Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model to 

conduct the analysis, it also said it would review alternative methods, including the use of 

NEMS. After evaluating both models and the approaches discussed in the August 18, 

2011 notice, DOE published a statement of amended policy in the Federal Register in 

which DOE explained its determination that NEMS is a more appropriate tool for its FFC 

analysis and its intention to use NEMS for that purpose. 77 FR 49701 (August 17, 2012). 

DOE received one comment, which was supportive of the use of NEMS for DOE’s FFC 

analysis.45 

The approach used for today’s NOPR, and the FFC multipliers that were applied, 

are described in appendix 11B of the NOPR TSD. NES results are presented in both 

primary and FFC savings in sectionVI.BSection 1802 of EPACT 2005 directed DOE to 

contract a study with the National Academy of Science (NAS) to examine whether the 

goals of energy efficiency standards are best served by measurement of energy 

consumed, and efficiency improvements, at the actual point-of-use or through the use of 

the full-fuel-cycle (FFC), beginning at the source of energy production (Pub. L. No. 109-

58 (August 8, 2005)). NAS appointed a committee to conduct the study, which was 

completed in May 2009. The NAS committee defined FFC energy consumption as 

including, in addition to site energy use, the following: energy consumed in the 

extraction, processing, and transport of primary fuels such as coal, oil, and natural gas; 

45 Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk Lundblade.

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energy losses in thermal combustion in power generation plants; and energy losses in 

transmission and distribution to homes and commercial buildings.46

In evaluating the merits of using point-of-use and FFC measures, the NAS 

committee noted that DOE uses what the committee referred to as “extended site” energy 

consumption to assess the impact of energy use on the economy, energy security, and 

environmental quality. The extended site measure of energy consumption includes the 

energy consumed during the generation, transmission, and distribution of electricity, but, 

unlike the FFC measure, does not include the energy consumed in extracting, processing, 

and transporting primary fuels. A majority of the NAS committee concluded that 

extended site energy consumption understates the total energy consumed to make an 

appliance operational at the site. As a result, the NAS committee recommended that DOE 

consider shifting its analytical approach over time to use a FFC measure of energy 

consumption when assessing national and environmental impacts, especially with respect 

to the calculation of greenhouse gas emissions. The NAS committee also recommended 

that DOE provide more comprehensive information to the public through labels and other 

means, such as an enhanced website. For those appliances that use multiple fuels (e.g., 

water heaters), the NAS committee indicated that measuring FFC energy consumption 

would provide a more complete picture of energy consumed and permit comparisons 

across many different appliances, as well as an improved assessment of impacts.

46 The National Academies, Board on Energy and Environmental Systems, Letter to Dr. John Mizroch, 

Acting Assistant Secretary, U.S. DOE, Office of Energy Efficiency and Renewable Energy from James W. 

Dally, Chair, Committee on Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy 

Efficiency Standards, May 15, 2009.

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In response to the NAS recommendations, DOE issued, on August 20, 2010, a notice of 

proposed policy proposing to incorporate a FFC analysis into the methods it uses to 

estimate the likely impacts of energy conservation standards on energy use and 

emissions. Specifically, DOE proposed to use FFC measures of energy and GHG 

emissions, rather than the primary (extended site) energy measures it currently uses. 

Additionally, DOE proposed to work collaboratively with the FTC to make FFC energy 

and GHG emissions data available to the public to enable consumers to make cross-class 

comparisons. On October 7, 2010, DOE held an informal public meeting to discuss and 

receive comments on its planned approach. The notice, a transcript of the public meeting, 

and all public comments received by DOE are available at: . Following the close of the 

public comment period, DOE intends to develop a final policy statement on these 

subjects and then take steps to begin implementing that policy in rulemakings and other 

activities.

Consumer Sub-Group.

H. Customer Subgroup Analysis 

The life-cycle cost subgroup analysis evaluates impacts of standards on 

identifiable groups, such as different consumercustomer populations or business types 

that may be disproportionately affected by any national energy conservation standard 

level. DOE will estimate LCC savings and PBPs for consumerscustomers in the 

commercial, industrial, and outdoor stationary sectors. DOE will also analyze the LCC 

effects on consumerscustomers living in or operating different buildings in the 

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commercial and industrial sectors. In addition, DOE will analyze effects on 

consumerscustomers in different regions of the country. 

I. Manufacturer Impact Analysis

1. Overview

DOE performed a manufacturer impact analysis (MIA) to estimate the financial 

impact of proposed new and amended energy conservation standards on manufacturers of 

metal halide lamp fixtures and ballasts, and to estimate the impact of such standards on 

employment and manufacturing capacity. The MIA has both quantitative and qualitative 

aspects. The quantitative part of the MIA primarily relies on the GRIM, an industry cash 

flow model using inputs specific to this rulemaking. The key GRIM inputs are data on the 

industry cost structure, equipment costs, shipments, and assumptions about markups and 

conversion expenditures. The key output is the industry net present value (INPV). 

Different sets of shipment and markup assumptions (scenarios) will produce different 

results. The qualitative part of the MIA addresses factors such as equipment attributes; 

characteristics of, and impacts on, particular sub-groups of firms; and market and product 

trends. Chapter 13 of the NOPR TSD outlines the complete MIA.

DOE conducted the MIA for this rulemaking in three phases. In Phase 1, Industry 

Profile, DOE prepared an industry characterization based on the market and technology 

assessment, preliminary manufacturer interviews, and publicly available information. In 

Phase 2, Industry Cash Flow Analysis, DOE estimated industry cash flows in the GRIM 

using industry financial parameters derived in Phase 1 and the shipment scenarios used in 

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the NIA. In Phase 3, Sub-Group Impact Analysis, DOE conducted structured, detailed 

interviews with a representative cross-section of manufacturers that represent more than 

65 percent of domestic fixture sales and 90 percent of domestic ballast sales. During 

these interviews, DOE discussed engineering, manufacturing, procurement, and financial 

topics specific to each company, and obtained each manufacturer’s view of the MHLF 

industry as a whole. The interviews provided valuable information that DOE used to 

evaluate the impacts of new and amended standards on manufacturers’ cash flows, 

manufacturing capacities, and employment levels. See section V.I.4 for a description of 

the key issues manufacturers raised during the interviews.

During Phase 3, DOE also used the results of the industry characterization 

analysis in Phase 1 and feedback from manufacturer interviews to group manufacturers 

that exhibit similar production and cost structure characteristics. DOE identified one subgroup for a separate impact analysis – small manufacturers – using the small business 

size standards published by the Small Business Administration (SBA).47 These thresholds 

include all employees in a business’ parent company and any other subsidiaries. Based 

upon this classification, DOE identified 54 small metal halide lamp fixture manufacturers 

and five small metal halide ballast manufacturers that qualify as small businesses.

47 DOE determined whether a company is a small business (65 FR 30836, 30848 (May 15, 2000), as 

amended at 65 FR 53533, 53544 (Sept. 5, 2000) and codified at 13 CFR part 121). To be categorized as a 

small business, a metal halide lamp fixture manufacturer may have up to 500 employees; a metal halide 

ballast manufacturer, may have up to 750 employees.

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2. GRIM Analysis and Key Inputs

DOE uses the GRIM to quantify the changes in cash flow that result in a higher or 

lower industry value. The GRIM analysis uses a standard annual cash-flow analysis that 

incorporates manufacturer costs, markups, shipments, and industry financial information 

as inputs and models changes in costs, investments, and manufacturer margins that would 

result from new and amended energy conservation standards. The GRIM spreadsheet 

uses the inputs to calculate a series of annual cash flows beginning with the base year of 

the analysis, 20112013, and continuing to 20442045. DOE computes INPVs by summing 

the stream of annual discounted cash flows during this period. DOE uses a real discount 

rate of 9.5 percent and 8.9 percent for fixtures and ballasts, respectively. The discount 

rate estimates were derived from industry corporate annual reports to the Securities and 

Exchange Commission (SEC 10-Ks) and then modified according to feedback during 

manufacturer interviews.

The GRIM calculates cash flows using standard accounting principles and 

compares changes in INPV between a base case and various TSLs (the standards cases). 

The difference in INPV between the base case and a standards case represents the 

financial impact of the new and amended standard on manufacturers. The GRIM results 

are shown in section VI.B.2. Additional details about the GRIM can be found in chapter 

13 of the NOPR TSD.

DOE typically presents its estimates of manufacturer impacts by groups of the 

major equipment types served by the same manufacturers. Although the covered 

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equipment in today’s proposed rulemaking is metal halide lamp fixtures, by requiring a 

particular ballast efficiency in this regulation, metal halide ballast manufacturers will also 

be affected by new and amended standards. Because fixture and ballast markets are 

served by separate groups of manufacturers, DOE presents impacts on metal halide lamp 

fixture manufacturers and metal halide ballast manufacturers separately.

a. Manufacturer Production Costs

Manufacturing a higher-efficiency product is typically more expensive than 

manufacturing a baseline product due to the use of components that are more costly than 

baseline components. The changes in the MPCs of the analyzed equipment can affect the 

revenues, gross margins, and cash flows of the manufacturer, making these equipment 

cost data key GRIM inputs for DOE’s analysis. DOE employed one of two methods to 

derive these per-unit production costs. DOE was able to establish a BOM for those 

ballasts it tore down. DOE then converted the BOMs at each efficiency level into 

corresponding MPCs composed of labor, materials, and overhead expenses using its 

engineering cost model. When DOE was not able to generate a BOM for a given ballast, 

DOE estimated the per-unit production costs based on the relationship between teardown 

data and manufacturer-supplied MSPs. DOE included a cost adder for indoor electronic 

ballasts to account for the additional cost of including a 120 V auxiliary tap in some 

models. DOE also developed fixture MPCs for several different fixture types using either 

a teardown analysis or retail price scaling. With these costs for several common fixture 

types, DOE created a single “hybrid” fixture for each of the five representative wattages, 

reflecting the weighted average of the common fixture types. DOE included a cost adder 

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for all fixtures that use electronic ballasts to account for thermal management and a cost 

adder for outdoor fixtures that use electronic ballasts to account for voltage transient 

protection. For a complete description these cost adders, see section V.C.12 of this 

NOPR. In addition, DOE used teardown cost data to disaggregate the ballast and fixture 

MPCs into material, labor, and overhead costs.

b. Base Case Shipment ForecastsProjections

Changes in sales volumes and efficiencies over time can significantly affect 

manufacturer finances. The GRIM estimates manufacturer revenues based on total unit 

shipment forecastsprojections and the distribution of shipments by efficiency level. For 

this analysis, the GRIM uses the NIA’s annual shipment forecastsprojections from 

20112013 to 20442045, the end of the analysis period. The shipments analysis also 

estimated the distribution of fixture efficiencies in the base case for all equipment classes.

DOE employed two scenarios that affect base case shipments over the analysis 

period (20152016 through 2044):2045): a low-shipment scenario and a high.-shipment 

scenario. In the low-shipment scenario, DOE reviewed trends in fixture replacement 

technologies and forecastedprojected a decline in shipments over the analysis period. In 

the high-shipment scenario, the decline in metal halide lamp fixture shipments is not as 

large as in the low-shipment scenario. Manufacturers earn greater revenue under the 

high-shipment scenario compared to the low-shipment scenario. See chapter 10 of the 

NOPR TSD for additional details on shipments.

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c. Standards Case Shipment ForecastsProjections

In addition to the two shipment scenarios affecting base case shipments, DOE 

modeled a roll-up scenario to estimate the standards case efficiency distributions. See 

chapter 10 of the NOPR TSD for more information on the standards case shipment 

scenarios.

d. Markup Scenarios

As discussed above, MSPs include direct manufacturing production costs (i.e., 

labor, material, and overhead estimated in DOE’s MPCs) and all non-production costs 

(i.e., selling, general and administrative expenses (SG&A), R&D, and interest), along 

with profit. To calculate the MSPs in the GRIM, DOE applied markups to the MPCs 

estimated in the engineering analysis for each equipment class and efficiency level. 

Modifying these markups in the standards cases yields different sets of impacts on 

manufacturers. For the MIA, DOE modeled two standards case markup scenarios to 

represent the uncertainty regarding impacts on prices and profitability: (1) a flat markup 

scenario, and (2) a ‘preservation of operating profit’ markup scenario. These scenarios 

lead to different markups values, which, when multiplied by the MPCs, result in varying 

revenue and cash flow impacts.

The flat markup scenario assumes that the cost of goods sold for each product is 

marked up by a flat percentage to cover SG&A expenses, R&D expenses, and profit. The 

flat markup scenario uses the baseline manufacturer markup (1.47 for ballasts and 1.58 

for fixtures, as discussed in chapter 5 of the NOPR TSD) for all fixture equipment classes 

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in both the base case and the standards case. This scenario represents the upper bound of 

industry profitability in the standards case because it is designed so that manufacturers 

can fully pass through additional costs due to standards to their customers. To derive the 

flat markup percentage, DOE evaluated publicly available financial information for 

manufacturers of metal halide ballasts or fixtures. DOE also requested feedback on this 

value during manufacturer interviews.

During interviews, manufacturers expressed skepticism that they would be able to 

mark up higher equipment costs in the standards case to the same degree as in the base 

case. In recognition of this concern, DOE also modeled a scenario called the 

‘preservation of operating profit’ markup scenario. In this scenario, markups in the 

standards case are lowered such that manufacturers are only able to maintain their total 

base case operating profit in absolute dollars, despite higher product costs and 

investments. This scenario represents the lower bound of industry profitability following 

new and amended energy conservation standards because the resulting higher production 

costs and investments do not yield any additional operating profits. DOE implemented 

this scenario in the GRIM by lowering the manufacturer markups at each TSL to yield 

approximately the same earnings before interest and taxes in the standards case, in the 

year after the compliance date in 2017, as in the base case.

e. Product and Capital Conversion Costs

New and amended energy conservation standards will cause manufacturers to 

incur conversion costs to bring their production facilities and product designs into 

189
compliance. For the MIA, DOE classified these conversion costs into two major groups: 

(1) product conversion costs and (2) capital conversion costs. Product conversion costs 

are investments in research, development, testing, marketing, and other non-capitalized 

costs necessary to make product designs comply with the new and amended energy 

conservation standards. Capital conversion costs are investments in property, plant, and 

equipment necessary to adapt or change existing production facilities such that new 

product designs can be fabricated and assembled.

NEMA expressed concern about the costs (in time and dollars) that manufacturers 

may incur due to this rulemaking, specifically with respect to product redesigns and 

product testing. NEMA disagreed with DOE’s assumption in the preliminary analysis that 

ballast redesigns would not cause fixture redesigns. NEMA argued that DOE should 

account for fixture redesign costs for both magnetic and electronic ballast efficiency 

levels and provided estimates of these costs. (NEMA, No. 34 at p. 7, 21) Acuity and OSI 

agreed that fixture manufacturers would face increased costs due to additional 

engineering, testing, and material costs. (Acuity, Public Meeting Transcript, No. 33 at p. 

79; OSI, No. 27 at p. 6)

For today’s NOPR, DOE has revised its assumption about additional fixture costs 

and believes that empty fixture costs are likely to increase for standards requiring 

electronic ballasts, as described in section V.C.12, because of the need to incorporate 

thermal protection and voltage transient protection. Because the use of electronic ballasts 

could necessitate fixture redesigns, DOE includes the costs of these fixture redesigns in 

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its product and capital conversion costs. DOE has taken into account the feedback and 

estimates provided by NEMA in its analysis, as well as the input from individual 

manufacturers during confidential manufacturer interviews. DOE’s methodology for 

developing product and capital conversion cost estimates is described below and in 

chapter 13 of the NOPR TSD. DOE requests comment on the methodology applied to 

determine the product and capital conversion costs. 

Several stakeholders commented that the costs to develop and test electronic 

ballasts are higher than for magnetic ballasts. (NEMA, No 34 at p. 8; OSI, No. 27 at p. 6) 

Cooper noted that the cost of UL certification when switching from magnetic to 

electronic ballasts falls into this category. (Cooper, Public Meeting Transcript, No. 33 at 

p. 76) Acuity added that long lead times accentuate the cost of UL certification and make 

it more difficult for manufacturers to quickly bring new products to market. (Acuity, 

Public Meeting Transcript, No. 33 at p. 79) DOE agrees that the engineering, testing, and 

certification costs for electronic ballasts may be significant and has included these costs 

in today’s analysis, as described in what follows.

Ballast Industry Conversion Costs

DOE’s interviews with ballast manufacturers revealed that they expect the need to 

develop new and improved circuit designs—as opposed to the purchase of new capital 

equipment—will account for most of the conversion costs at each TSL. Due to the 

flexible nature of most ballast production equipment and DOE’s assumption that the 

stack height of magnetic ballasts will not increase, manufacturers do not expect new and 

Comment [AGA18]: Revision requested by 

OIRA

191
amended standards to strand (make obsolete in advance of complete depreciation) a 

significant share of their production assets. As opposed to other more capital-intensive 

appliance manufacturers, much of the expenses required to achieve higher efficiency 

levels would occur through research and development, engineering, and testing efforts.

DOE based its estimates of the product conversion costs that would be required to 

meet each TSL on information obtained from manufacturer interviews and catalog data 

on the number and efficiency of models that each major manufacturer supports. DOE 

estimated the product development costs manufacturers would incur for each model that 

would need to be converted based on the necessary engineering and testing resources 

required to redesign each model. DOE assumed higher R&D and testing costs for levels 

requiring electronic ballasts compared to magnetic ballasts. Testing costs include internal 

testing, UL testing, additional certifications, pilot runs, and product training. DOE then 

multiplied these per-model cost estimates for each interviewed manufacturer by the total 

number of ballast models that would need to be converted at each efficiency level in each 

wattage bin, based on information from manufacturer catalogs and interviews, to estimate 

the total costproduct conversion costs.

To separate total product conversion costs into indoor and outdoor equipment 

classes, DOE assigned costs based on the percentage of indoor or outdoor shipments in 

the NIA. Finally, DOE scaled these costs to account for the market share of the 

companies not interviewed. DOE’s estimates of the product conversion costs for metal 

192
halide ballasts affected by this rulemaking can be found in section VI.B.2, as follows and 

in chapter 13 of the NOPR TSD.

As discussed above, DOE also estimated the capital conversion costs ballast 

manufacturers would incur to comply with the potential new and amended energy 

conservation standards represented by each TSL. During interviews, DOE asked 

manufacturers to estimate the capital expenditures required to expand the production of 

higher-efficiency products. These estimates included the required tooling and plant 

changes that would be necessary if product lines meeting the proposed standard did not 

currently exist.

DOE estimated capital conversion costs, like product conversion costs, based on 

interviews with manufacturers. Some manufacturers anticipated minimal to no 

conversion costs because of the flexibility of their existing equipment or because they 

source certain ballast types rather than produce them in-house. Other manufacturers 

expected greater capital conversion costs because they would need to acquire new 

stamping dies for higher-efficiency magnetic ballasts and/or wave solder machines for 

electronic ballasts. In general, DOE’s view is that significant changes to existing 

production lines and equipment would not be necessary in response to new or amended 

standards. It is therefore unlikely that most manufacturers would require high levels of 

capital expenditures compared to ordinary capital additions or replacements.

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DOE scaled its estimated conversion costs based on interviews to account for the 

market share of the companies not interviewed. DOE’s estimates of the capital 

conversion costs for metal halide ballasts can be found in section VI.B.2, as follows and 

in chapter 13 of the NOPR TSD.

Fixture Industry Conversion Costs

To estimate conversion costs for fixture manufacturers, DOE again based its 

estimates on manufacturer interviews and industry research. DOE doubts that the stack 

height of magnetic ballasts will increase in response to new and amended standards. As 

such, DOE assumed that fixture manufacturers would be able to use higher-efficiency 

magnetic ballasts without incurring redesign or capital costs. Even if higher-efficiency 

levels can be met with magnetic ballasts, DOE expects manufacturers will incur one-time 

non-capital expenses at these levels associated with testing, literature changes, and 

marketing costs. These costs are included in DOE’s product conversion cost estimates.

At efficiency levels requiring electronic ballasts, DOE expects that fixture 

manufacturers may face more significant conversion costs. Manufacturers will have to 

consider thermal protection in their product designs because more-efficient electronic 

ballasts have lower tolerances for high temperatures than magnetic ballasts do. DOE 

estimated product conversion costs for fixture manufacturers by multiplying the number 

of product families in each wattage bin by the expected cost of fixture redesign and 

testing. DOE then multiplied these totals by the percentage of fixtures that would need to 

be redesigned at each efficiency level.

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DOE employed a similar methodology to estimate fixture capital conversion costs 

at efficiency levels associated with electronic ballasts. Based on manufacturer interviews, 

DOE estimated platform tooling and equipment costs, such as costs for die castings, 

bracketing, and extrusions, and multiplied these costs by the number of fixtures affected 

by the standard.

To separate total product and capital conversion costs for fixture manufacturers 

into indoor and outdoor equipment classes, DOE assigned costs based on the percentage 

of indoor and outdoor fixtures each interviewed manufacturer offers. DOE’s estimates of 

the product and capital conversion costs for metal halide lamp fixtures addressed in this 

rulemaking can be found in section VI.B.2, as follows and in chapter 13 of the NOPR 

TSD.

3. Discussion of Comments

During the April 2011 public meeting, interested parties commented on the 

assumptions and results of the preliminary TSD. DOE addresses those comments below 

relating to the compliance period, the opportunity cost of investments, and impacts on 

competition.

a. Compliance Period

NEMA stated that fixture manufacturers may be unable to meet the compliance 

date of standards for all products. NEMA believes that it could take one year to redesign 

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the ballasts, one year to test and certify the ballasts, and one year to handle marketing of 

fixture phase-outs. NEMA said that this entire process may be difficult and burdensome 

given the scope of the rulemaking. (NEMA, No. 34 at p. 15) OSI also noted its concern 

about the compliance period, stating that any change in the standard must provide 

adequate time for the ballast OEMs to develop, test, and begin producing the additional 

ballast types needed to provide a complete line of electronic metal halide ballasts. Fixture 

OEMs would, in turn, need adequate time to redesign their products. (OSI, No. 27 at p. 6)

At the same time, OSI stated that ballast OEMs could provide bench-top 

temperature-rise data to help reduce the UL testing requirements and costs for the fixture 

OEMs. OSI also stated that several ballast manufacturers are already manufacturing 

electronic metal halide ballasts and are developing additional products to broaden their 

product offerings. OSI has plans to expand production capacity to supply market needs. 

On the fixture side, several manufacturers are already developing fixtures using 

electronic metal halide ballasts, and these manufacturers will be able to expand their 

fixture offering as more ballast types become available. (OSI, No. 27 at p. 6, 7)

DOE’s view is that the three year compliance period is sufficient for this 

rulemaking. As NEMA stated, it may take ballast manufacturers a year to redesign their 

ballasts. At that point, DOE expects ballast manufacturers to coordinate with their 

customers (fixture manufacturers), as suggested by OSI, and provide them with the 

necessary specifications, such as the ballast footprint and temperature data, enabling the 

fixture manufacturers to begin redesigning their fixtures where necessary. It is 

196
unreasonable to expect that ballast manufacturers would ignore the needs of their 

customers by waiting the full three years to provide fixture manufacturers with 

information about their redesigned products. Furthermore, DOE takes into account the 

additional engineering resources that may be necessary to complete the product redesigns 

in its estimates for product conversion costs.

DOE acknowledges that fixture manufacturers and ballast manufacturers may 

need to coordinate production to comply with a MHLF energy conservation standard. 

However, EISA 2007 specifies a compliance date of January 1, 2015, and DOE proposes 

to adopt this date in today’s NOPR. (42 U.S.C. 6295(hh)(2)(B)) DOE requests comment 

on the impact and feasibility of the compliance date for manufacturers.

b. Opportunity Cost of Investments

Several manufacturers argued that developing products to meet new and amended 

energy conservation standards has an opportunity cost due to the limited resources at 

their disposal. Manufacturers are currently focusing on new technologies such as solidstate lighting and controls with greater potential energy savings than mature technologies 

such as HID. New and amended standards for metal halide lamp fixtures could divert 

finite resources away from new product development, at a significant cost to the 

manufacturers. (NEMA, No. 34 at p. 7-8; Philips, Public Meeting Transcript, No. 33 at p. 

81; Georgia Power, No. 28 at p.1) Manufacturers may also choose not to convert their 

products and abandon the market because of the high opportunity cost. This could 

effectively eliminate the metal halide market and negate any potential energy savings 

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from MHLF and HID lamp standards as well. (Philips, Public Meeting Transcript, No. 33 

at p. 132; NEMA, No 34 at p. 16)

DOE recognizes the opportunity cost associated with any investment, and agrees 

that manufacturers would need to spend capital to meet today’s standards that they would 

not have to spend in the base case. As a result, manufacturers must determine the extent 

to which they will balance investment in the metal halide market with investment in 

emerging technologies. The companies will have to weigh tradeoffs between deferring 

investments and deploying additional capital. DOE includes the costs of meeting today’s 

proposed standard in its analysis.

c. Impact on Competition

NEMA stated that manufacturers who produce only magnetic ballasts would be at 

a disadvantage should DOE set a standard that requires the use of electronic ballasts. 

NEMA believed that magnetic ballast manufacturers would not be able to move to 

electronic ballast production because of the increased cost and complexity of electronic 

ballast designs and because of the different engineering specializations required. (NEMA, 

No. 34 at p. 16) OSI stated, however, that no manufacturers produce magnetic ballasts as 

their only product type, and many of those that offer magnetic ballasts also manufacture 

LED power supplies and drivers, which require the same or greater technology 

knowledge to develop and manufacture as electronic ballasts do. (OSI, No. 27 at p. 5)

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DOE agrees with NEMA that manufacturers with no experience producing 

electronic ballasts would face a steeper learning curve than those with experience. DOE 

doubts that competition will be significantly affected, however. Electronic ballasts are 

widely used throughout the industry, particularly at lower wattages. Additionally, as 

suggested by OSI, DOE has not identified any manufacturers that produce only magnetic 

metal halide ballasts.

4. Manufacturer Interviews

DOE interviewed manufacturers representing more than 65 percent of metal 

halide lamp fixture sales and 90 percent of metal halide ballast sales. These NOPR 

interviews were in addition to the preliminary interviews DOE conducted as part of the 

engineering analysis. The information gathered during these interviews enabled DOE to 

tailor the GRIM to reflect the unique financial characteristics of the ballast and fixture 

industries. All interviews provided information that DOE used to evaluate the impacts of 

potential new and amended energy conservation standards on manufacturer cash flows, 

manufacturing capacities, and employment levels. Appendix 13A of the NOPR TSD 

contains the interview guides DOE used to conduct the MIA interviews.

During the manufacturer interviews, DOE asked manufacturers to describe their 

major concerns about this rulemaking. The following sections describe the most 

significant issues identified by manufacturers. DOE also included additional concerns in 

chapter 13 of the NOPR TSD.

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a. Ability to Recoup Investments

Several manufacturers worried that new and amended energy conservation 

standards would force them to invest while their market was shrinking. The increasing 

market penetration of emerging technologies could strand these investments, particularly 

as metal halide lamp fixture standards hasten the switch to emerging technologies by 

narrowing the difference between MHLF and emerging technology purchase prices. If the 

standard threatens to accelerate the ongoing migration to new technology, manufacturers 

would be more likely to abandon their metal halide product lines.

To address the emerging technologies issues discussed by manufacturers, DOE 

included several shipment scenarios in both the NIA and the GRIM. See chapter 10 and 

chapter 13 of the NOPR TSD for a discussion of the shipment scenarios used in the 

respective analyses. DOE is seeking comment on whether manufacturers’ ability to 

recoup investment, combined with the opportunity cost of investment would encourage 

manufacturers to exit the metal halide lamp fixture market.

b. Efficiency Metric Used

Some manufacturers disagreed over which metric should be used to regulate 

efficiency for metal halide lamp fixtures. Manufacturers agreed that ballast efficiency is 

the most straightforward metric to use and the simplest for compliance purposes, but they 

noted that it ignores opportunities for energy savings from lamps and the fixture 

itself.fixtures themselves. At the same time, some manufacturers did not favor a lamp and

ballast metric because a lamp and ballast metric could confer a competitive advantage to 

Comment [AGA19]: Revision requested by 

OIRA

200
those manufacturers who produce both metal halide lamps and ballasts. Lastly, several 

manufacturers opposed the use of a fixture efficiency metric.

In today’s notice, DOE proposes a ballast efficiency metric for the reasons 

described in section III.B. DOE notes that it is concurrently conducting a rulemaking for 

HID lamps, including metal halide lamps, which will examine the lamp efficiency 

component of the metal halide system.

c. Maintenance of 150 W Exemption

Nearly all manufacturers said that DOE should maintain its exemption for 150 W 

only fixtures rated for wet (e.g., outdoor) locations and containing ballasts rated to 

operate in air temperatures higher than 50 °C. Manufacturers stated that it is costprohibitive to meet EISA 2007 standard levels with magnetic ballasts, and electronic 

ballasts are currently less reliable for outdoor applications. Furthermore, manufacturers 

acknowledged that this exemption created energy savings by pushing 

consumerscustomers of the more-expensive 175 W ballasts to the less-expensive 150 W 

magnetic ballasts. Manufacturers contended consumersthat customers would revert back 

to the 175 W productsequipment if the exemption were not maintained because of the 

significant price increase caused by bringing the 150 W ballast into compliance. This cost 

increase would cause consumerscustomers to revert to 175 W, they said, thereby negating 

any potential energy savings that could have been achieved by regulating 150 W 

products.

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DOE, however, is proposing not to maintain the 150 W exemption in today’s 

notice for the reasons detailed in section III.A.1.

J. Employment Impact Analysis

DOE considers employment impacts in the domestic economy as one factor in 

selecting a standard. Employment impacts consist of direct and indirect impacts. Direct 

employment impacts—which are not considered here—are any changes in the number of 

employees working for manufacturers of the equipment that is the subject of this 

rulemaking, their suppliers, and related service firms. Indirect employment impacts—the 

subject of this section—are changes in employment within the larger economy that occur 

due to the shift in expenditures and capital investment caused by the purchase and 

operation of more-efficient equipment. The MIA addresses the direct employment 

impacts that concern metal halide lamp fixture manufacturers in section VI.B.2.

The indirect employment impacts of standards consist of the net jobs created or 

eliminated in the national economy, outside of the manufacturing sector being regulated, 

because of: (1) reduced spending on energy by end-users; (2) reduced spending on new 

energy supplies by the utility industry; (3) increased spending on new productsequipment

to which the new standards apply; and (4) the effects of those three factors throughout the 

economy. DOE expects the net monetary savings from standards to be redirected to other 

forms of economic activity, and expects these shifts in spending and economic activity to 

affect the demand for labor in the short term, as explained as follows.

Field Code Changed

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One method for assessing the possible effects of such shifts in economic activity 

on the demand for labor is to compare sector employment statistics developed by the 

Labor Department’s Bureau of Labor Statistics (BLS). (Data on industry employment, 

hours, labor compensation, value of production, and the implicit price deflator for output 

for these industries are available upon request by calling the Division of Industry 

Productivity Studies (202-691-5618) or by sending a request by e-mail to 

dipsweb@bls.gov. These data are also available at

www.bls.gov/news.release/prin1.nr0.htm. The BLS regularly publishes its estimates of 

the number of jobs per million dollars of economic activity in different sectors of the 

economy, as well as the jobs created elsewhere in the economy by this same economic 

activity. Data from the BLS indicate that expenditures in the utility sector generally 

create fewer jobs (both directly and indirectly) than expenditures in other sectors of the 

economy. There are many reasons for these differences, including wage differences and 

the fact that the utility sector is more capital-intensive and less labor-intensive than other 

sectors.48

Energy conservation standards reduce consumercustomer utility bills. Because 

reduced consumercustomer expenditures for energy likely lead to increased expenditures 

in other sectors of the economy, the general effect of efficiency standards is to shift 

economic activity from a less labor-intensive sector (i.e., the utility sector) to more laborintensive sectors (e.g., the retail and manufacturing sectors). Thus, based on the BLS data 

alone, the Department believes that net national employment will increase due to shifts in 

48 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional InputOutput Modeling System (RIMS II), Washington, DC., U.S. Department of Commerce, 1992.

203

 
economic activity resulting from new and amended standards for metal halide lamp 

fixtures.

In developing today’s proposed standards, DOE estimated indirect national 

employment impacts using an input/output model of the U.S. economy called Impact of 

Sector Energy Technologies (ImSET), version 3.1.1. ImSET is a spreadsheet model of 

the U.S. economy that focuses on 187 sectors most relevant to industrial, commercial, 

and residential building energy use.49 ImSET is a special-purpose version of the “U.S. 

Benchmark National Input-Output” (I–O) model, designed to estimate the national 

employment and income effects of energy-saving technologies. The ImSET software 

includes a computer-based I–O model with structural coefficients to characterize 

economic flows among the 187 sectors. ImSET’s national economic I–O structure is 

based on a 19972002 U.S. benchmark table,50 specially aggregated to the 187 sectors. 

DOE estimated changes in expenditures using the NIA spreadsheet. Using ImSET, DOE 

estimated the net national, indirect employment impacts on employment by sector of 

potential new efficiency standards for metal halide ballasts. For more details on the 

employment impact analysis, see chapter 14 of the NOPR TSD.

DOE notes that ImSET is not a general equilibrium projection model, and 

understands the uncertainties involved in projecting employment impacts, especially 

49 Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies (PNNL18412 Pacific Northwest National Laboratory) (20082009). Available at 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf. 50 Lawson, Ann M., Kurt S. Bersani, Mahnaz Fahim-NaderStewart, R.L., J.B. Stone, and Jiemin Guo, 

“M.L. Streitwieser, “U.S. Benchmark Input-Output Accounts of the U.S. Economy, 1997, 2002,” Survey of 

Current Business (Dec. 2002) pp. 19–117Oct. 2007).

204

 
changes in the later years of the analysis.51 Because ImSET does not incorporate price 

changes, the employment effects predicted by ImSET may over-estimate actual job 

impacts over the long run for this rule. Because ImSET predicts small job impacts 

resulting from this rule, regardless of these uncertainties, the actual job impacts are likely 

to be negligible in the overall economy. DOE may consider the use of other modeling 

approaches for examining long-run employment impacts.

DOE also notes that the employment impacts estimated with ImSET for the entire 

economy differ from the employment impacts in the lighting manufacturing sector 

estimated in NOPR TSD chapter 13 using the GRIM. The methodologies used and the 

sectors analyzed in the ImSET and GRIM models are different.

K. Utility Impact Analysis

The utility impact analysis includes estimates of theseveral important effects on 

the utility industry of the adoptingadoption of new or amended standards on the utility 

industry. For this analysis, DOE used the NEMS-BT model to generate forecasts of 

electricity consumption, electricity generation by plant type, and electric generating 

capacity by plant type, that would result from each considered TSL. DOE obtained the 

energy savings inputs associated with efficiency improvements to considered products 

from the NIA. DOE conducts the utility impact analysis as a scenario that departs from 

the latest AEO Reference Case. In the analysis for today’s rule, the estimated impacts of 

51 Scott, M., J.M. Roop, R.W. Schultz, D.M. Anderson, K.A. Cort, “The Impact of DOE Building 

Technology Energy Efficiency Programs on U.S. Employment, Income, and Investment.” Energy 

Economics (Sep. 2008).

Comment [AGA20]: START HERE

205

 
a standardstandards are estimated to be the differences between values forecasted by 

NEMS-BT and the values in the AEO2011 reference case.AEO2013 Reference Case.

Chapter 15 of the NOPR TSD describes the utility impact analysis.

DOE recognizes that the aggregate economic benefits from avoided construction 

of new generating capacity and infrastructure are potentially large. However, there may 

be negative effects on some of the actors involved in electricity supply, particularly 

power plant providers and fuel suppliers. There is also uncertainty about the extent to 

which the benefits for electricity users from reduced electricity prices would be a transfer 

from actors involved in electricity supply to electricity consumers. DOE also takes under 

advisement the guidance provided by the Office of Management and Budget (OMB) to 

Federal agencies on identifying and measuring benefits and costs in its regulatory 

analyses (OMB Circular A-4, section E, September 17, 2003). Specifically, at page 38, 

Circular A-4 instructs that transfers should be excluded from the estimates of the benefits 

and costs of a regulation. DOE applied this approach for the utility impact analysis in this 

proposed rule.

DOE is continuing to investigate the extent to which projected changes in 

electricity prices that result from standards represent a net economic gain to the nation. 

DOE included the estimated effects of adopted standards on electricity prices and the 

cumulative NPV of resulting savings in electricity expenditures in the TSD. DOE also 

included representative costs of avoided electricity generation capacity by fuel type, 

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although these costs are provided for illustrative purposes only. For more details on the 

utility impact analysis, see chapter 15 of the NOPR TSD.

B. Environmental Assessment

Pursuant to the National Environmental Policy Act of 1969 and the requirements 

of 42 U.S.C. 6295(o)(2)(B)(i)(VI), DOE has prepared a draft environmental assessment 

(EA) of the impacts of the potential standards for metal halide lamp fixtures in today’s 

proposed rule, which it has included as chapter 16 of the NOPR TSD.

In the EA, DOE estimated the reduction in power sector emissions of CO2, NOx, 

and Hg using the NEMS-BT computer model. In the EA, NEMS-BT is run similarly to 

the AEO NEMS, except that metal halide lamp fixture energy use is reduced by the 

amount of energy saved (by fuel type) due to each TSL. The inputs of national energy 

savings come from the NIA spreadsheet model, while the output is the forecasted 

physical emissions. The net benefit of each TSL in today’s proposed rule is the difference 

between the forecasted emissions estimated by NEMS-BT at each TSL and the AEO2011

Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. For today’s 

NOPR, DOE used the AEO2011. For the final rule, DOE intends to revise the emissions 

analysis using the most current version of NEMS.

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L. Emissions Analysis

In the emissions analysis, DOE estimated the reduction in power sector emissions 

of CO2, NOx, SO2, and Hg from potential energy conservation standards for metal halide 

lamp fixtures. In addition to estimating impacts of standards on power sector emissions, 

DOE estimated emissions impacts in production activities that provide the energy inputs 

to power plants. These are referred to as “upstream” emissions. In accordance with the 

FFC Statement of Policy (76 FR 51281 (August 18, 2011)), this FFC analysis includes 

impacts on emissions of methane (CH4) and nitrous oxide (N2O), both of which are 

recognized as greenhouse gases. 

To estimate impacts on the environment, DOE conducted the emissions analysis 

using emissions factors that were derived from data in AEO2013, supplemented by data 

from other sources. DOE developed separate emissions factors for power sector 

emissions and upstream emissions. The method that DOE used to derive emissions 

factors is described in chapter 16 of the NOPR TSD.

EIA prepares the Annual Energy Outlook using NEMS. Each annual version of 

NEMS incorporates the projected impacts of existing air quality regulations on emissions. 

AEO2013 generally represents current legislation and environmental regulations, 

including recent government actions, for which implementing regulations were available 

as of December 31, 2012.

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SO2 emissions from affected electricity-generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs, and DOE has preliminarily 

determined that these programs create uncertainty about the potential amended standards’ 

impact on SO2 emissions. Title IV of the Clean Air Act sets an annual emissions cap on 

SO2 for affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). 

SO2 emissions from 28 eastern states and D.C. arewere also limited under the Clean Air 

Interstate Rule (CAIR; 70 FR 25162 (May 12, 2005)), which created an allowance-based 

trading program. Although CAIR was remanded to the U.S. Environmental Protection 

Agency (EPA) by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit) (but it remained in effect. See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 

2008)), it remained in effect temporarily, consistent with the D.C. Circuit’s earlier 

opinion in); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2010, 

EPA issued the Transport Rule proposal, a replacement for CAIR (75 FR 45210 (Aug. 2, 

2010)), and On July 6, 2011 EPA issued the final Transport Rule, entitleda replacement 

for CAIR, the Cross-State Air Pollution Rule. (CSAPR). 76 FR 48208 (AugustAug. 8, 

2011). (www.epa.gov/crossstaterule/). Because the AEO 2011 NEMSOn August 21, 

2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). The court ordered EPA to 

continue administering CAIR. The AEO2013 emissions factors used for today’s NOPR 

assumes the implementation of CAIR, DOE has not been able to take into account the 

effects of the Transport Rule for this rulemaking.52assume that CAIR remains a binding 

regulation through 2040.

52 DOE notes that future iterations of the NEMS-BT model will incorporate any changes necessitated by 

209

 
The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Under existing 

EPA regulations, any excess SO2 emissions allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to 

permit offsetting increases in SO2 emissions by any regulated EGU. However, if the 

amended standards resulted in a permanent increase in the quantity of unused emissions 

allowances, In past rulemakings, DOE recognized that there would be an overall 

reduction in SO2 emissions from the standards. While there remains somewas uncertainty 

about the ultimate effects of efficiency standards on SO2 emissions covered by the 

existing cap-and-trade system, the NEMS-BT modeling system that DOE uses to forecast 

emissions reductions currently indicatesbut it concluded that no physicalnegligible

reductions in power sector SO2 emissions would occur for SO2as a result of standards.

As discussed above, Beginning in 2015, however, SO2 emissions will fall as a 

result of the AEOMercury and Air Toxics Standards (MATS) for power plants, which 

were announced by EPA on December 21, 2011 NEMS . 77 FR 9304 (Feb. 16, 2012). In 

the final MATS rule, EPA established a standard for hydrogen chloride as a surrogate for 

acid gas hazardous air pollutants (HAP), and also established a standard for SO2 (a nonHAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The 

same controls are used for today’s NOPRto reduce HAP and non-HAP acid gas; thus, 

SO2 emissions will be reduced as a result of the control technologies installed on coalissuance of the Transport Rule.

210

 
fired power plants to comply with the MATS requirements for acid gas. AEO2013

assumes the implementation of CAIR, whichthat, in order to continue operating, coal 

plants must have either flue gas desulfurization or dry sorbent injection systems installed 

by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when 

electricity demand decreases (e.g., as a result of energy efficiency standards). Emissions 

will be far below the cap that would be established by CSAPR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be 

needed or used to permit offsetting increases in SO2 emissions by any regulated EGU. 

Therefore, DOE believes that efficiency standards will reduce SO2 emissions in 2015 and 

beyond.

CSAPR established a cap on NOx emissions in 28 eastern States and the District 

of Columbia. With CAIR in effect, the Energy conservation standards for metal halide 

lamp fixtures are are expected to have little or no physical effect on NOx emissions in 

those States covered by CAIR, for the same reasons that they may have little effect on 

SO2 emissions. CSAPR because excess NOx emissions allowances resulting from the 

lower electricity demand could be used to permit offsetting increases in NOx emissions.

However, the proposed standards would be expected to reduce NOx emissions in the 22 

States not affected by CAIR. For these 22 states, DOE is using the NEMS-BT to 

estimatethe caps, so DOE estimated NOx emissions reductions from the standards 

considered in today’s NOPR for these States.

211
Similar to emissions of SO2 and NOx, future emissions of Hg would have been 

subject to emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule 

(CAMR). 70 FR 28606 (May 18, 2005). CAMR would have permanently capped 

emissions of mercury for new and existing coal-fired power plants in all states by 2010. 

However, on February 8, 2008, the D.C. Circuit issued a decision in New Jersey v. 

Environmental Protection Agency, 517 F.3d 574The MATS limit mercury emissions 

from power plants, but they do not include emissions caps and, as such, DOE’s energy 

conservation standards would likely reduce Hg emissions. DOE estimated mercury 

emissions reduction using NEMS-BT based on AEO2013, which incorporates the MATS. 

(D.C. Cir. 2008), in which it vacated CAMR. EPA has decided to develop 

emissions standards for power plants under Section 112 of the Clean Air Act, consistent 

with the D.C. Circuit’s opinion on CAMR. See . Pending EPA’s forthcoming revisions to 

the rule, DOE is excluding CAMR from its environmental assessment. In the absence of 

CAMR, a DOE standard would likely reduce Hg emissions and DOE used NEMS-BT to 

estimate these reductions. However, DOE continues to review the impact of rules that 

reduce energy consumption on Hg emissions, and may revise its assessment of Hg 

emission reductions in future rulemakings.

L.M. Monetizing Carbon Dioxide and Other Emissions Impacts

As part of the development of this proposed rule, DOE considered the estimated 

monetary benefits likely to result from the reduced emissions of CO2 and NOX that are 

expected to result from each of the TSLs considered. In order to make this calculation,

similar to the calculation of the NPV of consumercustomer benefit, DOE considered the 

212
reduced emissions expected to result over the lifetime of products shipped in the 

forecastprojection period for each TSL. This section summarizes the basis for the 

monetary values used for each of these emissions and presents the values considered in 

this rulemaking.

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon 

(SCC) that was developed by an interagency process. A summary of the basis for these 

values is provided below, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 1617 of the NOPR TSD.

1. Social Cost of Carbon

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon

dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.

Under section 1(b) of E.O. 12866, agencies must, to the extent permitted by law, 

“assess both the costs and the benefits of the intended regulation and, recognizing that 

some costs and benefits are difficult to quantify, propose or adopt a regulation only upon 

213
a reasoned determination that the benefits of the intended regulation justify its costs.” The 

purpose of the SCC estimates presented here is to allow agencies to incorporate the 

monetized social benefits of reducing CO2 emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed these SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of CO2. 

214
When attempting to assess the incremental economic impacts of CO2 emissions, 

the analyst faces a number of serious challenges. A recent report from the National 

Research Council53 points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about (1) future emissions of GHGs, (2) the effects 

of past and future emissions on the climate system, (3) the impact of changes in climate 

on the physical and biological environment, and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and 

monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics and should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing carbon dioxide emissions. 

Consistent with the directive in Executive Order 12866 quoted above, the purpose of the 

SCC estimates presented here is to make it possible for Federal agencies to incorporate 

the social benefits from reducing carbon dioxide emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions.CO2 emissions. Most Federal regulatory actions can be expected to have 

marginal impacts on global emissions. For such policies, the agency can estimate the 

benefits from reduced (or costs from increased) emissions in any future year by 

multiplying the change in emissions in that year by the SCC value appropriate for that 

year. The net present value of the benefits can then be calculated by multiplying each of 

these future benefits by an appropriate discount factor and summing across all affected 

53 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press: Washington, DC (2009).

215

 
years. This approach assumes that the marginal damages from increased emissions are 

constant for small departures from the baseline emissions path, an approximation that is 

reasonable for policies that have effects on emissions that are small relative to cumulative 

global carbon dioxideCO2 emissions. For policies that have a large (non-marginal) impact 

on global cumulative emissions, there is a separate question of whether the SCC is an 

appropriate tool for calculating the benefits of reduced emissions. This concern is not 

applicable to this notice, and DOE does not attempt to answer that question herehowever.

At the time of the preparation of this notice, the most recent interagency estimates 

of the potential global benefits resulting from reduced CO2 emissions in 2010, expressed 

in 2010$, were $4.9, $22.3, $36.5, and $67.6 per metric ton avoided. For emissions 

reductions that occur in later years, these values grow in real terms over time. 

Additionally, the interagency group determined that a range of values from 7 percent to 

23 percent should be used to adjust the global SCC to calculate domestic effects,54

although preference is given to consideration of the global benefits of reducing CO2

emissions. 

It is important to emphasize that the interagency process is committed to updating 

these estimates as the science and economic understanding of climate change and its 

impacts on society improves over time. Specifically, the interagency group has set a 

54 It is recognized that this calculation for domestic values is approximate, provisional, and highly 

speculative. There is no a priori reason why domestic benefits should be a constant fraction of net global 

damages over time.

216

 
preliminary goal of revisiting the SCC values within 2 years or at such time as 

substantially updated models become available, and to continue to support research in 

this area. In the meantime, the interagency group will continue to explore the issues 

raised by this analysis and consider public comments as part of the ongoing interagency 

process.

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

To date,Past economic analyses for Federal regulations have used a wide range of 

values to estimate the benefits associated with reducing CO2 emissions. In the finalThe

model year 2011 CAFE Corporate Average Fuel Economy final rule, the U.S. 

Department of Transportation (DOT) used both a “domestic” SCC value of $2 per metric 

ton of CO2 and a “global” SCC value of $33 per metric ton of CO2 for 2007 emission 

reductions (in 2007$), increasing both values at 2.4 percent per year.55 DOT It also 

included a sensitivity analysis at $80 per metric ton of CO2. See Average Fuel Economy 

Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 (March 30, 

2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks,56 The proposed rule for Model 

Years 2011-2015 at 3-90 (Oct. 2008) (Available at: ). A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon 

55 Throughout this section, references to tons of CO2 refer to metric tons. 56 See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 

(March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

www.nhtsa.gov/fuel-economy).

217

 
dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per

metric ton of CO2 (in 2006$) for 2011 emission reductions (with a range of $0−$14 for 

sensitivity analysis), also increasing at 2.4 percent per year. See Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 FR 24352 

(May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate 

Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-

2015 at 3-58 (June 2008) (Available at: ).57 A regulation for packaged terminal air 

conditioners and packaged terminal heat pumps finalized by DOE in October of 2008 

used a domestic SCC range of $0 to $20 per metric ton CO2 for 2007 emission reductions 

(in 2007$). 73 FR 58772, 58814 (Oct. 7, 2008) In addition, EPA’s 2008 Advance Notice 

of Proposed Rulemaking on Regulating Greenhouse Gas Emissions Under the Clean Air 

Act identified what it described as “very preliminary” SCC estimates subject to revision. 

73 FR 44354 (July 30, 2008). EPA’s global mean values were $68 and $40 per metric ton 

CO2 for discount rates of approximately 2 percent and 3 percent, respectively (in 2006$ 

for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing CO2emissions. To ensure consistency in 

57 See Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 

FR 24352 (May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) 

(Available at: www.nhtsa.gov/fuel-economy).

218

 
how benefits are evaluated across agencies, the Administration sought to develop a 

transparent and defensible method, specifically designed for the rulemaking process, to 

quantify avoided climate change damages from reduced CO2 emissions. The interagency 

group did not undertake any original analysis. Instead, it combined SCC estimates from 

the existing literature to use as interim values until a more comprehensive analysis could 

be conducted. The outcome of the preliminary assessment by the interagency group was a 

set of five interim values: global SCC estimates for 2007 (in 2006$) of $55, $33, $19, 

$10, and $5 per ton of CO2. These interim values represent the first sustained interagency 

effort within the U.S. government to develop an SCC for use in regulatory analysis. The 

results of this preliminary effort were presented in several proposed and final rules and 

were offered for public comment in connection with proposed rules, including the joint 

EPA-DOT fuel economy and CO2 tailpipe emission proposed rules.

c. Current Approach and Key Assumptions

After the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates, which were considered for this 

proposed rule. Specifically,. The group considered public comments and further explored 

the technical literature in relevant fields. The interagency group relied on three integrated 

assessment models (IAMs) commonly used to estimate the SCC: the FUND, DICE, and 

PAGE models.58 These models are frequently cited in the peer-reviewed literature and 

were used in the last assessment of the Intergovernmental Panel on Climate Change. Each 

model was given equal weight in the SCC values that were developed. The SCC values 

58 The models are described in appendix 16A of the TSD.

219

 
used for today’s notice were generated using the most recent versions of the three 

integrated assessment models that have been published in the peer-reviewed literature.59

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

The interagency group selected four sets of SCC values for use in regulatory 

analyses. 60 Three values are based on the average SCC from three integrated assessment 

models, at discount rates of 2.5, 3, and 5 percent. The fourth value, which represents the 

95th percentile SCC estimate across all three models at a 3-percent discount rate, is 

included to represent higher-than-expected impacts from temperature change further out 

59 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866, Technical Model 

Update for the Social Cost of Carbon (SCC). Interagency Working Group on Social Cost of Carbon, United 

States Government, May 2013. 60 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government, 2010.

220

 
in the tails of the SCC distribution. For emissions (or emission reductions) that occur in 

later years, these valuesThe values estimated for 2010 grow in real terms over time, as 

depicted in Table V.8. Additionally, the interagency group determined that a range of 

values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although preference is given to consideration of the global benefits of 

reducing CO2 emissions.

Table V.8 Social Cost of CO2Annual SCC Values from 2010 Interagency Report, 

2010–2050 (in 2007 dollars per metric ton CO2)

Discount Rate

5%

Avg.

3%

Avg.

2.5%

Avg.

3%

95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

Table V.9 shows the updated sets of SCC estimates in five year increments from 

2010 to 2050. Appendix 17B of the NOPR TSD provides the full set of values, as well as 

the 2013 draft report from the interagency group. The central value that emerges is the 

average SCC across models at the 3 percent discount rate. However, for purposes of 

capturing the uncertainties involved in regulatory impact analysis, the interagency group 

emphasizes the importance of including all four sets of SCC values.

221
Table V.9 Annual SCC Values from 2013 Interagency Update, 2010–2050 (in 2007 

dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 33 52 90

2015 12 38 58 109

2020 12 43 65 129

2025 14 48 70 144

2030 16 52 76 159

2035 19 57 81 176

2040 21 62 87 192

2045 24 66 92 206

2050 27 71 98 221

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizesrecognized that the existing models are imperfect and incomplete. The 

National Research Council report mentioned above points out that there is tension 

between the goal of producing quantified estimates of the economic damages from an 

incremental ton of carbonCO2 emissions and the limits of existing efforts to model these 

effects. There are a number of concerns and problems that should be addressed by the 

research community, including research programs housed in many of the Federal 

agencies participating in the interagency process to estimate the SCC.

DOE recognizes the uncertainties embedded in the estimates of the SCC used for 

cost-benefit analyses. As such, DOE and others in the U.S. Government intend The 

interagency group intends to periodically review and reconsider those estimates to reflect 

222
increasing knowledge of the science and economics of climate impacts, as well as 

improvements in modeling. In this context, statements recognizing the limitations of the 

analysis and calling for further research take on exceptional significance.

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the most recent values identified byfrom the 2013 interagency 

processreport , adjusted to 20102012$ using the GDPGross Domestic Product price 

deflator. For each of the four cases specified, the values used for emissions in 20102015

were $412.9, $22.3, $36.540.8, $62.2, and $67.6117 per metric ton avoided (values 

expressed in 2010$).61 To monetize2012$).62 DOE derived values after 2050 using the 

growth rate for the 2040-2050 period in the interagency update.

DOE multiplied the CO2 emissions reductions expected to result from new and 

amended standards for metal halide lamp fixtures, DOE used the values identified in 

Table A1 of the “Social Cost of Carbonreduction estimated for Regulatory Impact 

Analysis Under Executive Order 12866,” which is reprintedeach year by the SCC value 

for that year in appendix 16A of the NOPR TSD, appropriately adjusted to 2010$.each of 

the four cases. To calculate a present value of the stream of monetary values, DOE 

discounted the values in each of the four cases using the specific discount rate that had 

been used to obtain the SCC values in each case.

61 Table V.5 presents SCC values through 2050. For DOE’s calculation, it derived values after 2050 using 

the 3-percent per year escalation rate used by the interagency group.

62 The interagency report presents SCC values through 2050. DOE derived values after 2050 using the 3-

percent per year escalation rate used by the interagency group.

223

 
2. Valuation of Other Emissions Reductions

DOE investigated the potential monetary benefit of reduced NOx emissions from 

the TSLs it considered. As noted above, DOE has taken into account how new or 

amended energy conservation standards would reduce NOx emissions in those 22 states 

that are not affected by the CAIRCSAPR. DOE estimated the monetized value of NOx

emissions reductions resulting from each of the TSLs considered for today’s NOPR based 

on environmental damage estimates found in the relevant scientific literature. Available 

estimates suggest a very wide range of monetary values, ranging from $370 per ton to 

$3,800 per ton of NOx from stationary sources, measured in 2001$ (equivalent to a range 

of $450ranging from $468 to $4,623809 per ton in 20102012$).63 In accordance with 

OMB guidance, 64 DOE conducted two calculations ofcalculated the monetary benefits 

derived using each of the economic values used for NOX, one using a and real discount 

raterates of 3 percent and another using a real discount rate of 7 percent.65 

DOE is aware of multiple agency efforts to determine the appropriate range of 

values used in evaluating the potential economic benefits of reduced Hg emissions. DOE 

has decided to await further guidance regarding consistent valuation and reporting of Hg 

emissions before it once again monetizes Hg emissions in its rulemakings.

63 For additional information, refer to U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities, Washington, DC. 64 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 65 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).

224

 
DOE did not monetize Hg emission reductions because it is currently evaluating 

estimates of the value of Hg emissions.

VI. Analytical Results

A. Trial Standard Levels

DOE analyzed the benefits and burdens of a number of TSLs for the metal halide 

lamp fixtures that are the subject of today’s proposed rule. Table VI.1 presents the trial 

standard levels and the corresponding equipment class ELs for representative equipment 

classes.

66 See the engineering analysis in section V.C.9 of this NOPR for a more detailed 

discussion of the efficiency levels.

In thisthe following section, DOE presents the analytical results for the TSLs of 

the equipment classes that DOE analyzed directly. DOE scaled the TSLsELs for these 

representative equipment classes to create TSLsELs for other equipment classes that were 

not directly analyzed as set forth in chapter 5 of the NOPR TSD. For more details on the 

representative equipment classes, please see section V.C.2.

Table VI.1 Trial Standard Levels

R

ep

. 

W

at

ta

ge

T

S

L 

1

TSL 2

T

S

L

3

T

S

L 

3

TSL4TSL 4

T

S

L

5

T

S

L 

5

T

S

L

6

T

S

L

7

T

S

L

8

70 

W 

In

do

E

L

1

EL2

E

L

2

E

L

3

E

L

3

E

L

3

E

L

3

EL4 

66 See section V.C.3 for more information on the chosen representative wattages.

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

225

 
or

EL2

70 

W O

ut

do

or

EL1

EL2

EL2

EL3 EL4

15

0 

W 

In

do

or

EL1

EL2

EL3

EL4

EL4

EL3

EL4

|EL4

250

150

W 

Indo

orO

ut

do

or

BaseEL1BaseEL2

BaseBaseBase

EL4

EL4 EL4

40

0 WIndoor

Base

Base Base Base

Base

Base

Base

EL4

1000

250

W 

In

do

or

EL1+DS

EL2 +DS

EL2+DS

EL2 +DS

EL

2 +DSEL4

EL

2 +DS

EL

2 +DS

EL

2 +DS

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

226
70

250

W O

ut

do

or

EL1

EL2

EL2

EL2

EL3EL2

EL4

EL4

150

400

W O

utdo

or

In

do

or

EL1

EL2

EL3EL2

EL3EL2

EL4

EL3EL4EL4

25

0 WOutdoor

Base

Base Base Base

Base

Base

Base

EL4

40

0 

W O

ut

do

or

BaseEL1BaseEL2BaseBaseBase

EL2

EL2 EL4

10

00 

W O

utdo

EL1+DS*

EL2+DS

EL2+DS

EL2+DS

EL2+DS

EL

2 +DS

EL

2 +DS

EL

2 +DS

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

227
or

In

do

or

10

00 

W 

O

ut

do

or

E

L

1

+

D

S

EL2+DS

E

L

2

+

D

S

EL2+DS EL2+DS

*DS is a design standard that bans the use of probe-start ballasts in 

new metal halide lamp fixtures.

TSL1 represents EL1 for each equipment class with a positive NPV at EL1. TSL 

1 haswould set energy conservation standards at EL1 for the indoor and outdoor 

equipment classes forfixtures at 70 W,

67 150 W, 250 W, 400 W, and 1000 W fixtures, 

and at the baseline efficiency for the indoor and outdoor 250 W and 400 W fixtures. 

Standards included in TSL 1 typically can be satisfied by magnetic ballasts with midgrade steel and copper windings. These ballasts are commercially available except for the 

150 W ballasts which arein indoor and outdoor 70 W, 250 W, and 1000 W fixtures, with 

the rest being modeled. TSL 1 includes a design standard for indoor and outdoor 1000 W 

fixtures that prohibits the sale of probe-start ballasts in new fixtures. TSL 1 sets the same 

standards for indoor and outdoor representative equipment classes at the same wattage.

TSL 2 represents the max tech magnetic ballast EL for each equipment class. TSL 

2 would set energy conservation standards at EL2 for the indoor and outdoor fixtures at 

70 W, 150 W, 250 W, 400 W, and 1000 W fixtures, and baseline efficiency. EL2 is the 

max tech EL for the indoor and outdoor 2501000 W and 400 W fixtures. Standards 

67 The nomenclature 70 W indoor fixture refers to the ≥50 W and ≤100 W indoor equipment class. 70 W is 

the representative wattage for the equipment class as discussed in section V.C.3. A similar shorthand 

naming convention is used for other equipment classes.

228

 
included in TSL 2 typically can be satisfied by fixtures that contain magnetic ballasts 

with high-grade core steel and copper windings. These ballasts are modeled, except for 

the 1000 W ballasts, which are commercially available. TSL 2 includes a design standard 

for the indoor and outdoor 1000 W fixtures whichthat prohibits the sale of probe-start 

ballasts in new fixtures. TSL 2 sets the same standards for indoor and outdoor 

representative equipment classes at the same wattage.

TSL 3 represents the maximum energy savings achievable with maximum 

positive NPV with the requirement that the same efficiency levels for fixtures operating 

indoors and outdoors be analyzed. TSL 3 would set energy conservation standards at EL2 

for 70 and 1000 W indoor and outdoor fixtures, EL3 for the at 70 W, 250 W, 400 W, and 

1000 W, and EL4 for indoor and outdoor 150 W fixtures, and the baseline for the 250 W 

and 400 W fixtures at 150 W. EL4 is the max tech EL for indoor and outdoor fixtures at 

150 W, and EL2 is the max tech EL for indoor and outdoor fixtures at 1000 W. Standards 

included in TSL 3 typically can be satisfied by fixtures that contain magnetic ballasts 

with high-grade core steel and copper windings or standard grade electronic ballasts. 

These ballasts are modeled, except for the 150 W fixtures, which require max tech

electronic ballasts with high-grade electronic components. The 150 W and 1000 W 

ballasts which are commercially available., while the rest are modeled. TSL 3 includes a 

design standard for the indoor and outdoor 1000 W fixtures that prohibits the sale of 

probe-start ballasts in new fixtures. TSL 3 sets the same standards for indoor and outdoor 

representative equipment classes at the same wattage.

229
TSL 4 represents the maximum energy savings achievable with a positive NPV 

for each equipment class, considering indoor and outdoor fixtures separately. TSL4 

would set energy conservation standards at EL2 for the 70 Windoor and outdoor 250 W, 

400 W, and 1000 W fixtures and indoor and outdoor70 W fixtures, EL3 for the 70 W 

indoor and 150 W outdoor fixtures, EL4 for the indoor 150 W 70 W fixtures, and the 

baselineEL4 for the 250 W and 400 W indoor and outdoor fixtures150 W fixtures. EL4 is 

the max tech EL for indoor and outdoor fixtures at 150 W, and EL2 is the max tech EL 

for indoor and outdoor fixtures at 1000 W. Standards included in TSL 4 typically can be 

satisfied by fixtures that contain magnetic ballasts with high-grade core steel and copper 

windings or , except for 70 W outdoor fixtures, which require standard-grade electronic 

ballasts except for the indoor , and 150 W fixtures, which require max tech electronic 

ballasts with high-grade electronic ballasts. Ballastscomponents. The ballasts for indoor 

and outdoor 150 W and 1000 W fixtures and outdoor 70 W fixtures are commercially 

available except for the outdoor 70 W ballast which is, and the rest are modeled. TSL 4 

includes a design standard for indoor and outdoor 1000 W fixtures that prohibits the sale 

of probe-start ballasts in new fixtures. 

TSL 5 represents all of the max tech efficiency levels, which would set energy 

conservation standards at EL3EL4 for indoor and outdoor 70 W fixtures, EL4 for indoor 

and outdoor, 150 W, baseline for the indoor and outdoor, 250 W, and 400 W fixtures, and 

EL2 for the indoor and outdoor 1000 W fixtures. Standards included in TSL 5 typically 

can be satisfied by fixtures that contain the maximum technologically feasible (max tech) 

electronic ballasts with high-grade electronic components, except for 70 W fixtures 

230
which require standard grade electronic ballasts and 1000 W fixtures which require highgrade core steel and copper windings. These ballasts are all commercially available. TSL 

5 includes a design standard for indoor and outdoor 1000 W fixtures that prohibits the 

sale of probe start ballasts in new fixtures. TSL 5 sets the same standards for indoor and 

outdoor equipment classes of the same wattage.

TSL 6 would set energy conservation standards at EL2 for the outdoor 70 W 

fixtures, EL3 for the indoor 70 W fixtures, EL3 for the indoor and outdoor 150 W 

fixtures, EL4 for the 250 W indoor fixtures, EL4 for the indoor 250 W fixtures, baseline 

for the outdoor 250 W fixtures, baseline for the indoor and outdoor 400 W fixtures, and 

EL2 for the indoor and outdoor 1000 W fixtures. TSL 6 requires standard grade 

electronic ballasts for the indoor 70 W and indoor and outdoor 150 W fixtures and max 

tech electronic ballasts for the indoor 250 W fixtures. The outdoor 70 W and 400 W 

fixtures and indoor and outdoor 1000 W fixtures typically use high-grade electrical steel 

and copper winding to reach the TSL 6 standard. Ballasts are all commercially available 

except the outdoor 70 W and 400 W ballasts which are modeled. TSL 6 includes a design 

standard for indoor and outdoor 1000 W fixtures that prohibits the sale of probe start

ballasts in new fixtures.

TSL 7 would set energy conservation standards at EL3 for the indoor 70 W 

fixtures, EL4 for the indoor and outdoor 150 W and outdoor 70 W fixtures, EL2 for the 

outdoor 400 W and indoor and outdoor 1000 W fixtures, and baseline for the indoor 400 

W and outdoor 250 W fixtures. At TSL7, fixtures typically contain the maximum 

231
technologically feasible (max tech) electronic ballasts with high-grade electronic 

components for indoor and outdoor 150 W, outdoor 70 W, and indoor 250 W fixtures, 

and standard efficiency electronic ballasts with standard-grade electronic components for 

indoor 70 W fixtures. These ballasts are all commercially available except the outdoor 

400 W ballasts which are modelled. TSL 7 includes a design standard for indoor and 

outdoor 1000 W fixtures that prohibits the sale of probe start ballasts in new fixtures in 

addition to typically requiring magnetic ballasts to use high-grade core steel and copper 

windings.

TSL 8 represents all of the maximum technologically feasible (max tech) 

efficiency levels, which would set energy conservation standards at EL4 for the indoor 

and outdoor 70, 150, 250, and 400 W fixtures, and EL2 for the indoor and outdoor 1000 

W fixtures. Standards included in TSL 8, require fixtures to contain the max tech 

electronic ballasts with high-grade electronic components for indoor and outdoor 70, 150, 

250, and 400 W fixtures. High-grade core steel and copper windings are typically used in 

the ballasts included in 1000 W fixtures. Ballasts are all Commercially available. ballasts 

meet TSL 85 for all equipment classes. TSL 5 would require high-frequency electronic 

ballasts for the 400 W indoor and outdoor fixtures, which have limited compatibility with 

CMH technology. See section V.C.8. TSL 8 for additional detail.TSL 5 includes a design 

standard for indoor and outdoor 1000 W fixtures that prohibits the sale of probe-start 

ballasts in new fixtures. TSL 85 sets the same standards for indoor and outdoor 

representative equipment classes at the same wattage.

232
DOE requests comment on these proposed trial standard levels.

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual ConsumersCustomers

a. Life-Cycle Cost and Payback Period

ConsumersCustomers affected by new or amended standards usually experience 

higher purchase prices and lower operating costs. Generally, these effects on individual 

consumerscustomers are best summarized by changes in LCCs and PBP. DOE calculated 

the LCC and PBP values for the potential standard levels considered in this rulemaking to 

provide key inputs for each TSL. These values are reported by equipment class in Table 

VI.2 through Table VI.13. Each table includes the average total LCC and the average 

LCC savings, as well as the fraction of equipment consumerscustomers for which the 

LCC will either decrease (net benefit) or increase (net cost) relative to the baseline case.

The last column in each table contains the median PBPs for the consumercustomer

purchasing a design compliant with the TSL. 

The results for each TSL are presented relative to the energy use in the baseline 

case (no new or amended standards), based on energy consumption under conditions of 

actual equipment use. As discussed in section IV.D.2, the rebuttable presumption PBP is 

based on test values under conditions prescribed by the DOE test procedures, as required 

by EPCA. (42 U.S.C. 6295(o)(2)(B)(iii))

Table VI.2 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Indoor, Magnetic Baseline): LCC and PBP Results

233
Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Baseline 535.19537.

80

1,274.19379.

32

1,657.38

917.12 -- -- -- --

1 1 536.38539.

03

1,243.93345.

26

1,633.89

884.28 23.4932.84 0.000 100.0 0.585

2, 3, 4 2 549.19552.

28

1,227.94326.

43

1,634.33

878.71 23.0538.41 0.40 99.6100.0 4.542

4, 5,

6, 7-- 3 552.05555.25

1,188.82379.

56

1,609.21

934.80 48.-17.68 25.424 74.676 4.373.3

85 4 565.03568.

68

1,182.30374.

61

1,617.72

943.29

39.66-

26.16 36.128 63.972 7.095.4

Table VI.3 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Indoor, Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3, 4, 

5, 6, 7 Baseline / 3 552.05555.25

1,188.82379.

56

1,609.21

934.80 -- -- -- --

85 4 565.03568.

68

1,182.30374.

61

1,617.72

943.29 -8.5148 99.396 0.74 35.9832.3

Table VI.4 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Outdoor, Magnetic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

234
Net

Cost

Net 

Benefit

Baseline 525.71527.

98

1,274.19844.

61

1,732.63

2,372.59 -- -- -- --

1 1 526.85529.

16

1,243.93803.

94

1,708.52

2,333.09 24.1139.50 0.0 100.0 0.616

2, 3,

4, 6 2 539.12541.86

1,227.94784.

29

1,708.33

2,326.15 24.3046.44 30.0 97100.0 4.874

54 3 576.41580.

46

1,188.82722.

54

1,717.25

2,303.00 15.3869.59 71.942 28.158 13.3712.8

7, 85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 7.2963.77 77.943 22.157 15.2914.6

Table VI.5 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Outdoor, Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3, 4, 

5, 7 Baseline / 3 576.41580.46

1,188.82722.

54

1,717.25

2,303.00 -- -- -- --

85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 -8.095.82 98.584 1.516 33.1044.7

Table VI.6 ProductEquipment Class 2 - 150 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Baseline 674.40657.

04

1,943.832,11

0.32

2,388.17

767.36 -- -- -- --

1 1 690.08673.

27

1,915.372,07

5.60

2,380.77

748.87 7.4018.50 14.21 85.899 8.237.2

235
2 2 697.61681.

07

1,891.302,04

6.61

2,368.51

727.68 19.6639.68 3.80 96.2100 6.565.8

3, 6-- 3 693.41676.

72

1,815.622,06

3.23

2,304.70

739.95 83.4727.41 9.915 90.185 3.162.4

3,4,5

7, 8 4 712.04696.00

1,811.442,06

1.22

2,320.90

757.23 67.2610.14 23.6 76.477 6.044.7

Table VI.7 ProductEquipment Class 2 - 150 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Baseline 659.08641.

19

1,943.832,68

1.81

2,473.55

3,322.99 -- -- -- --

1 1 674.11656.

74

1,915.372,64

5.59

2,465.77

3,302.33 7.7720.66 30.10 69.9100 9.088.3

2 2 681.32664.

20

1,891.302,61

4.09

2,453.29

3,278.30 20.2644.70 16.20 83.8100 7.196.6

3, 4, 6-- 3 711.85695.

81

1,815.622,49

9.35

2,424.59

3,195.16

48.96127.8

4 48.216 51.884 7.9.40

3, 4, 5, 7, 8 4 729.70714.

28

1,811.442,49

6.20

2,440.53

3,210.48

33.02112.5

1 63.026 37.074 12.1110.5

Table VI.8 ProductEquipment Class 3 - 250 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2,

3, 4, 5 Baseline 722.66710.86

2,469.69485.

37

2,878.17

3,196.24 -- -- -- --

--1 1 745734.37 2,445.58455.

32

2,881.78

3,189.69 -3.616.55 72.536 27.564 14.4512.4

236
--2, 3, 4 2 760.46749.

99

2,427.68433.

12

2,882.61

3,183.11 -4.4413.12 68.531 31.569 13.7711.8

-- 3 799.78790.

69

2,370.34485.

61

2,880.37

3,276.30 -2.2080.07 81.752 18.348 15.3114.4

6, 7, 85 4 792.79783.

45

2,359.97472.

23

2,864.28

3,255.68

13.89-

59.44 70.044 30.056 13.1811.5

Table VI.9 ProductEquipment Class 3 - 250 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3

4, 5, 6, 7 Baseline 702.83690.34

2,469.693,13

2.65

2,961.06

3,822.99 -- -- -- --

--1 1 724.58712.

86

2,445.583,10

3.40

2,964.19

3,816.26 -3.136.73 75.820 24.280 16.0714.8

--2, 3, 4 2 739.04727.

82

2,427.683,08

1.42

2,964.69

3,809.24 -3.6313.75 72.915 27.185 15.3114.0

-- 3 811.27802.

58

2,370.34996.

28

2,996.95

3,798.86

-

35.8924.13 92.565 7.535 19.6128.0

85 4 804.57795.

64

2,359.97981.

26

2,980.92

3,776.91

-

19.8546.08 88.454 11.646 18.6721.4

Table VI.10 ProductEquipment Class 4 - 400 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3

4, 5, 6, 7 Baseline 802.10784.44

3,229.77453.

98

3,581.67

4,238.41 -- -- -- --

--1 1 839.39823.

04

3,191.57406.

28

3,588.77

4,229.31 -79.10 75.340 24.760 15.0112.8

237
--2, 3, 4 2 857.54841.

82

3,160.57368.

36

3,581.82

4,210.18 -0.1528.23 57.018 43.082 12.1810.5

-- 3 934.05921.

01

3,068.38389.

35

3,589.31

4,310.36 -7.6471.95 79.249 20.851 16.6813.8

85 4 974.01962.

37

3,050.99375.

11

3,617.04

4,337.48

-

35.3799.07 86.661 13.439 19.3716.2

Table VI.11 ProductEquipment Class 4 - 400 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 

3, 4, 5-- Baseline 779.26760.80

3,229.774,17

3.10

3,652.39

4,933.90 -- -- -- --

--1 1 814.99797.

78

3,191.574,12

6.96

3,658.71

4,924.74 -6.319.16 77.522 22.578 16.7115.4

6, 72, 3, 4 2 832.37815.

77

3,160.574,08

7.66

3,651.32

4,903.43 1.0730.47 64.07 36.093 13.5212.3

-- 3 940.22927.

40

3,068.38958.

53

3,692.66

4,885.93

-

40.2747.97 88.456 11.644 21.353

85 4 978.50967.

02

3,050.99940.

38

3,719.78

4,907.40

-

67.3926.49 91.063 9.037 23.1924.4

Table VI.12 ProductEquipment Class 4 -5 -- 1000 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

-- Baseline 1,161.9714

3.88

7,819.6011,6

57.30

8,12,801.

18712.86 -- -- -- --

-- 1 1,202.5318

5.86

7,795.0311,6

19.06

8,728.351

2,804.91

-

15.483.73 95.162 4.938 18.1716.3

1 1 + DS* 1,223.6720

7.74

7,795.0311,1

22.24

8,453.231

2,329.98

259.6347

1.20 0.0 100.0 2.351.8

238
-- 2 1,216.1719

9.97

7,765.2611,5

70.62

8,712.431

2,770.60 0.4330.58 68.012 32.088 11.149.7

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,237.30221.85

7,765.2611,0

77.12

8,439.281

2,298.97

273.5850

2.21 0.0 100.0 2.650

* DS = Design standard requiring that all ballasts sold in new fixtures to be pulse sold shall not contain a 

probe-start ballast.

Table VI.13 ProductEquipment Class 4 -5 -- 1000 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

-- Baseline 1,121.0510

1.52

7,819.609,85

4.56

7,468.911

0,956.08 -- -- -- --

-- 1 1,159.9014

1.74

7,795.039,82

3.86

7,487.851

0,965.59

-

18.959.52 94.767 5.333 24.459

1 1 + DS* 1,180.1516

2.70

7,795.039,40

8.20

7,249.851

0,570.89

219.0638

5.18 0.0 100.0 2.897

-- 2 1,172.9715

5.26

7,765.269,78

3.72

7,475.731

0,938.98

-

6.8317.10 78.618 21.482 14.445

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,193176.22

7,765.269,37

0.84

7,239.451

0,547.05

229.4640

9.02 0.10 99.9100.0 3.260

* DS = Design standard requiring that all ballasts sold in new fixtures to be pulse sold shall not contain a 

probe-start ballast.

b. Consumer Sub-GroupCustomer Subgroup Analysis

Using the LCC spreadsheet model, DOE determined the impacteffect of the trial 

standard levels on the following consumercustomer sub-groups: utilities, owners of 

transportation facilities, and warehouse owners. DOE adjusted particular inputs to the 

LCC model to reflect conditions faced by the identified subgroups. For utilities, DOE 

assumed that maintenance costs would be higher than average assumed maintenance 

costs. This is because utilities have to maintain more equipment than the other subgroups

239
do. DOE assumed that owners of transportation facilities face higher annual operating 

hours than the average used in the main LCC analysis. For warehouse owners, DOE 

assumed lower annual operating hours than average used in the main LCC analysis.

Table VI.14 through Table VI.25 show the LCC effects and PBPs for identified 

sub-groups that purchase metal halide lamp fixtures. In general, the average LCC savings 

for the identified subgroups at the considered efficiency levels are not significantly 

different from the average for all consumerscustomers.

Table VI.14 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Indoor, Magnetic Baseline): LCC Subgroup Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

Baseline 647.69650.

30

1,274.19632.

71

1,980.83

2,283.01 -- -- -- --

1 1 648.88651.

53

1,243.93598.

65

1,957.34

2,250.17

23.4932.8

4 0.0 100.0 0.575

2, 3, 4 2 661.69664.

78

1,227.94579.

82

1,957.78

2,244.60

23.0538.4

1 0.10 99.1100.0 4.512

4, 5,

6, 7-- 3 664.55667.75

1,188.82663.

46

1,938.69

2,331.20

42.14-

48.19 34.435 65.6 4.133.5

85 4 677.53681.

18

1,182.30658.

51

1,947.20

2,339.68

33.63-

56.67 43.736 56.364 6.875.8

Sub-GroupSubgroup: Transportation Facility Owners

Baseline 535.19537.

80

1,274.19428.

88

2,0371,9

66.68 -- -- -- --

1 1 536.38539.

03

1,243.93392.

23

2,011.98

1,931.26

25.7035.4

1 0.0 100.0 0.535

240
2, 3, 4 2 549.19552.

28

1,227.94371.

90

2,011.34

1,924.18

26.3542.4

9 0.0 100.0 4.183.9

4, 5,

6, 7-- 3 552.05555.25

1,188.82413.

15

2,016.60

1,968.39

21.08-

1.72 22.126 77.974 4.143.0

85 4 565.03568.

68

1,182.30407.

13

2,025.99

1,975.80

11.69-

9.13 33.929 66.171 6.705.0

Sub-GroupSubgroup: Warehouse Owners

Baseline 535.19537.

80

1,274.19372.

08

1,633.25

909.88 -- -- -- --

1 1 536.38539.

03

1,243.93338.

45

1,610.54

877.47

22.7132.4

0 0.0 100.0 0.604

2, 3, 4 2 549.19552.

28

1,227.94319.

92

1,611.14

872.20

22.1137.6

8 0.10 99.9100.0 3.4.69

4, 5,

6, 7-- 3 552.05555.25

1,188.82373.

94

1,598.59

929.19

34.66-

19.31 18.814 81.286 4.121.9

85 4 565.03568.

68

1,182.30369.

17

1,607.44

937.85

25.82-

27.97 29.815 70.285 6.743.2

Table VI.15 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Indoor, Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

1, 2, 3, 4, 

5, 6, 7 Baseline / 3 664.55667.75

1,188.82663.

46

1,938.69

2,331.20 -- -- -- --

85 4 677.53681.

18

1,182.30658.

51

1,947.20

2,339.68 -8.5148 99.596 0.54 36.3032.4

Sub-GroupSubgroup: Transportation Facility Owners

1, 2, 3, 4, 

5, 6, 7 Baseline / 3 552.05555.25

1,188.82413.

15

2,016.60

1,968.39 -- -- -- --

85 4 565.03568.

68

1,182.30407.

13

2,025.99

1,975.80 -9.397.41 99.495 0.65 34.6931.3

Sub-GroupSubgroup: Warehouse Owners

1, 2, 3, 4, 

5, 6, 7 Baseline / 3 552.05555.25

1,188.82373.

94

1,598.59

929.19 -- -- -- --

85 4 565.03568.

68

1,182.30369.

17

1,607.44

937.85 -8.8566 99.698 0.42 36.6321.9

241
Table VI.16 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Outdoor, Magnetic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

Baseline 638.21640.

48

1,274.192,20

5.61

2,079.20

846.10 -- -- -- --

1 1 639.35641.

66

1,243.932,16

4.94

2,055.08

806.60

24.1139.5

0 0.0 100.0 0.616

2, 3,

4, 6 2 651.62654.36

1,227.942,14

5.30

2,054.89

799.66

24.3046.4

4 30.0 97100.0 4.874

54 3 688.91692.

96

1,188.822,09

0.08

2,070.45

783.04 8.7463.06 79.946 20.154 11.8216.9

7, 85 4 701.34705.

83

1,182.302,08

3.03

2,078.55

788.86 0.6557.23 83.648 16.452 13.7118.7

Sub-GroupSugroup: Transportation Facility Owners

Baseline 525.71527.

98

1,274.19844.

61

1,732.63

2,372.59 -- -- -- --

1 1 526.85529.

16

1,243.93803.

94

1,708.52

2,333.09

24.1139.5

0 0.0 100.0 0.616

2, 3,

4, 6 2 539.12541.86

1,227.94784.

29

1,708.33

2,326.15

24.3046.4

4 30.0 97100.0 4.874

54 3 576.41580.

46

1,188.82722.

54

1,717.25

2,303.00

15.3869.5

9 71.946 28.154 13.3816.9

7, 85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 7.2963.77 77.948 22.152 15.3118.7

Sub-GroupSubgroup: Warehouse Owners

Baseline 525.71527.

98

1,274.19844.

61

1,732.63

2,372.59 -- -- -- --

1 1 526.85529.

16

1,243.93803.

94

1,708.52

2,333.09

24.1139.5

0 0.0 100.0 0.616

2, 3,

4, 6 2 539.12541.86

1,227.94784.

29

1,708.33

2,326.15

24.3046.4

4 30.0 97100.0 4.874

54 3 576.41580.

46

1,188.82722.

54

1,717.25

2,303.00

15.3869.5

9 71.938 28.162 13.3812.4

242
7, 85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 7.2963.77 77.941 22.159 15.3114.2

Table VI.17 ProductEquipment Class 1 - 70 Watt Metal Halide Lamp Fixtures 

(Outdoor, Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

1, 2, 3, 4, 

5, 7 Baseline / 3 688.91692.96

1,188.822,09

0.08

2,070.45

783.04 -- -- -- --

85 4 701.34705.

83

1,182.302,08

3.03

2,078.55

788.86 -8.095.82 98.585 1.515 33.1844.3

Sub-GroupSubgroup: Transportation Facility Owners

1, 2, 3, 4, 

5, 7 Baseline / 3 576.41580.46

1,188.82722.

54

1,717.25

2,303.00 -- -- -- --

85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 -8.095.82 98.595 1.5 33.1831.0

Sub-GroupSubgroup: Warehouse Owners

1, 2, 3, 4, 

5, 7 Baseline / 3 576.41580.46

1,188.82722.

54

1,717.25

2,303.00 -- -- -- --

85 4 588.84593.

33

1,182.30715.

50

1,725.34

2,308.82 -8.095.82 98.585 1.515 33.1844.3

Table VI.18 ProductEquipment Class 2 - 150 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

Baseline 809.40792.

04

1,943.832,41

6.48

2,775.78

3,208.52 -- -- -- --

243
1 1 825.08808.

27

1,915.372,38

1.76

2,768.38

3,190.03 7.4018.50 12.1 87.999 8.177.2

2 2 832.61816.

07

1,891.302,35

2.77

2,756.12

3,168.84

19.6639.6

8 2.20 97.8100 6.515.8

3, 6-- 3 828.41811.

72

1,815.622,40

4.29

2,699.55

3,216.01

76.23-

7.48 17.629 82.471 3.332.7

3, 4, 5

7, 8 4 847.04831.00

1,811.442,40

2.28

2,715.75

3,233.28

60.03-

24.76 32.034 68.066 6.305.2

Sub-GroupSubgroup: Transportation Facility Owners

Baseline 674.40657.

04

1,943.832,22

5.70

2,924.69

882.74 -- -- -- --

1 1 690.08673.

27

1,915.372,18

7.50

2,914.54

860.77

10.1521.9

7 6.1 93.999 7.486.8

2 2 697.61681.

07

1,891.302,15

5.69

2,899.96

836.76

24.7345.9

8 0.8 99.2100 5.944

3, 6-- 3 693.41676.

72

1,815.622,17

3.66

2,867.74

850.38

56.9532.3

6 3.212 96.888 2.692

3, 4, 5

7, 8 4 712.04696.00

1,811.442,17

1.29

2,885.28

867.29

39.4015.4

5 14.120 85.980 5.234.4

Sub-GroupSubgroup: Warehouse Owners

Baseline 674.40657.

04

1,943.832,09

8.07

2,352.49

755.11 -- -- -- --

1 1 690.08673.

27

1,915.372,06

3.78

2,345.42

737.05 7.0718.06 13.0 87.0100 5.8.42

2 2 697.61681.

07

1,891.302,03

5.14

2,333.57

716.20

18.9338.9

1 2.0 98.0100 6.714.7

3, 6-- 3 693.41676.

72

1,815.622,05

3.01

2,285.43

729.73

67.0625.3

7 7.48 92.6 1.3.15

3, 4, 5

7, 8 4 712.04696.00

1,811.442,05

1.17

2,301.95

747.17 50.557.93 21.512 78.588 2.6.09

Table VI.19 ProductEquipment Class 2 - 150 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

244
Baseline 794.08776.

19

1,943.833,11

5.02

2,889.42

3,891.20 -- -- -- --

1 1 809.11791.

74

1,915.373,07

8.80

2,881.65

3,870.54 7.7720.66 30.20 69.8100 9.088.3

2 2 816.32799.

20

1,8913,047.3

0

2,869.17

3,846.51

20.2644.7

0 16.20 83.8100 7.206.5

3, 4, 6-- 3 846.85830.

81

1,815.622,94

0.40

2,848.43

3,771.21

40.99120.

00 59.833 40.267 9.722

3, 4, 5, 7, 8 4 864.70849.

28

1,811.442,93

7.25

2,864.37

3,786.53

25.05104.

67 70.738 29.362 12.152

Sub-GroupSubgroup: Transportation Facility Owners

Baseline 659.08641.

19

1,943.832,68

1.81

2,473.55

3,322.99 -- -- -- --

1 1 674.11656.

74

1,915.372,64

5.59

2,465.77

3,302.33 7.7720.66 30.20 69.8100 9.088.3

2 2 681.32664.

20

1,891.302,61

4.09

2,453.29

3,278.30

20.2644.7

0 16.20 83.8100 7.206.5

3, 4, 6-- 3 711.85695.

81

1,815.622,49

9.35

2,424.59

3,195.16

48.96127.

84 48.233 51.867 9.412

3, 4, 5, 7, 8 4 729.70714.

28

1,811.442,49

6.20

2,440.53

3,210.48

33.02112.

51 63.038 37.062 12.112

Sub-GroupSubgroup: Warehouse Owners

Baseline 659.08641.

19

1,943.832,68

1.81

2,473.55

3,322.99 -- -- -- --

1 1 674.11656.

74

1,915.372,64

5.59

2,465.77

3,302.33 7.7720.66 30.20 69.8100 9.088.3

2 2 681.32664.

20

1,891.302,61

4.09

2,453.29

3,278.30

20.2644.7

0 16.20 83.8100 7.206.5

3, 4, 6-- 3 711.85695.

81

1,815.622,49

9.35

2,424.59

3,195.16

48.96127.

84 48.216 51.884 9.417.7

3, 4, 5, 7, 8 4 729.70714.

28

1,811.442,49

6.20

2,440.53

3,210.48

33.02112.

51 63.025 37.075 12.1110.3

Table VI.20 ProductEquipment Class 3 - 250 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

245
Sub-GroupSubgroup: Utilities

1, 2,

3, 4, 5 Baseline 857.66845.86

2,469.69706.

30

3,265.78

552.16 -- -- -- --

--1 1 880869.37 2,445.58676.

24

3,269.40

545.61 -3.616.55 71.836 28.264 14.3112.4

--2, 3, 4 2 895.46884.

99

2,427.68654.

05

3,270.22

539.04

-

4.4413.12 67.730 32.370 13.6511.9

-- 3 934.78925.

69

2,370.34741.

43

3,275.22

667.13

-

9.44114.9

6

85.557 14.543 13.8016.9

6, 7, 85 4 927.79918.

45

2,359.97728.

05

3,259.13

646.50

6.66-

94.34 76.749 23.351 12.5813.0

Sub-GroupSubgroup: Transportation Facility Owners

1, 2,

3, 4, 5 Baseline 722.66710.86

2,469.69918.

78

3,464.82

629.64 -- -- -- --

--1 1 745734.37 2,445.58885.

59

3,466.08

619.96 -1.259.69 64.329 35.771 13.2011.8

--2, 3, 4 2 760.46749.

99

2,427.68861.

10

3,465.16

611.09

-

0.3318.56 59.524 40.576 12.5811.2

-- 3 799.78790.

69

2,370.34918.

08

3,503.26

708.78

-

38.4479.1

3

75.050 25.050 13.9314.3

6, 7, 85 4 792.79783.

45

2,359.97903.

52

3,485.53

686.97

-

20.7057.3

2

62.243 37.857 12.0211.1

Sub-GroupSubgroup: Warehouse Owners

1, 2,

3, 4, 5 Baseline 722.66710.86

2,469.69466.

57

2,829.50

3,177.44 -- -- -- --

--1 1 745734.37 2,445.58436.

94

2,833.18

3,171.31 -3.686.13 74.017 26.083 14.7010.1

--2, 3, 4 2 760.46749.

99

2,427.68415.

04

2,834.09

3,165.03

-

4.5912.40 69.915 30.185 14.019.6

-- 3 799.78790.

69

2,370.34468.

82

2,848.71

3,259.52

-

19.2182.0

8

83.526 16.574 16.006.7

6, 7, 85 4 792.79783.

45

2,359.97455.

53

2,832.79

3,238.98

-

3.2961.54 72.922 27.178 13.695.6

Table VI.21 ProductEquipment Class 3 - 250 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings MedianPayback 

246
Level

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Period

years

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

1, 2, 3

4, 5, 6, 7 Baseline 837.83825.34

2,469.693,47

2.93

3,376.94

4,298.27 -- -- -- --

--1 1 859.58847.

86

3,443.682,44

5.58

3,380.07

4,291.54 -3.136.73 75.820 24.280 16.0714.8

--2, 3, 4 2 874.04862.

82

2,427.683,42

1.70

3,380.57

4,284.52

-

3.6313.75 72.916 27.184 15.3114.1

-- 3 946.27937.

58

2,370.343,34

4.40

3,420.79

4,281.98

-

43.8516.2

9

94.772 5.328 14.8939.8

85 4 939.57930.

64

2,359.973,32

9.38

3,404.76

4,260.03

-

27.8238.2

5

91.461 8.639 15.9628.2

Sub-GroupSubgroup: Transportation Facility Owners

1, 2, 3

4, 5, 6, 7 Baseline 702.83690.34

2,469.693,13

2.65

2,961.06

3,822.99 -- -- -- --

--1 1 712.86724.

58

2,445.583,10

3.40

2,964.19

3,816.26 -3.136.73 75.820 24.280 16.0714.8

--2, 3, 4 2 739.04727.

82

2,427.683,08

1.42

2,964.69

3,809.24

-

3.6313.75 72.916 27.184 15.3114.1

-- 3 811.27802.

58

2,370.34996.

28

2,996.95

3,798.86

-

35.8924.1

3

92.572 7.528 19.6539.8

85 4 804.57795.

64

2,359.97981.

26

2,980.92

3,776.91

-

19.8546.0

8

88.461 11.639 18.6828.2

Sub-GroupSubgroup: Warehouse Owners

1, 2, 3

4, 5, 6, 7 Baseline 702.83690.34

2,469.693,13

2.65

2,961.06

3,822.99 -- -- -- --

--1 1 724.58712.

86

2,445.583,10

3.40

2,964.19

3,816.26 -3.136.73 75.820 24.280 16.0714.8

--2, 3, 4 2 739.04727.

82

2,427.683,08

1.42

2,964.69

3,809.24

-

3.6313.75 72.916 27.184 15.3114.1

-- 3 811.27802.

58

2,370.34996.

28

2,996.95

3,798.86

-

35.8924.1

3

92.564 7.536 19.6527.1

85 4 804.57795.

64

2,359.97981.

26

2,980.92

3,776.91

-

19.8546.0

8

88.454 11.646 18.6820.7

247
Table VI.22 ProductEquipment Class 4 - 400 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

1, 2, 3

4, 5, 6, 7 Baseline 952.10934.44

3,229.77649.

31

3,948.50

4,583.74 -- -- -- --

--1 1 989.39973.

04

3,191.57601.

60

3,955.60

4,574.64 -79.10 74.740 25.360 14.8712.9

--2, 3, 4 2 1,007.5499

1.82

3,160.57563.

69

3,948.65

4,555.51

-

0.1528.23 56.018 44.082 12.0710.5

-- 3 1,084.0507

1.01

3,068.38623.

45

3,964.19

4,694.47

-

15.68110.

72

83.356 16.744 17.3315.5

85 4 1,124.0111

2.37

3,050.99609.

21

3,991.91

4,721.58

-

43.41137.

84

89.366 10.734 20.0618.2

Sub-GroupSubgroup: Transportation Facility Owners

1, 2, 3

4, 5, 6, 7 Baseline 802.10784.44

3,229.77880.

58

3,823.43

4,665.01 -- -- -- --

--1 1 839.39823.

04

3,191.57827.

87

3,826.79

4,650.91

-

3.3614.10 67.834 32.266 13.7212.2

--2, 3, 4 2 857.54841.

82

3,160.57786.

15

3,816.83

4,627.97 6.5937.04 45.414 54.686 11.1210.0

-- 3 934.05921.

01

3,068.38808.

34

3,865.91

4,729.36

-

42.4964.3

4

72.448 27.652 15.2213.4

85 4 974.01962.

37

3,050.99792.

38

3,895.72

4,754.75

-

72.2989.7

4

81.458 18.642 17.7915.9

Sub-GroupSubgroup: Warehouse Owners

1, 2, 3

4, 5, 6, 7 Baseline 802.10784.44

3,229.77423.

90

3,349.51

4,208.33 -- -- -- --

--1 1 839.39823.

04

3,191.57376.

86

3,356.69

4,199.90 -7.188.43 76.920 23.180 15.2610.4

--2, 3, 4 2 857.54841.

82

3,160.57339.

44

3,350.07

4,181.25

-

0.5627.08 58.49 41.691 12.428.5

248
-- 3 934.05921.

01

3,068.38362.

34

3,376.24

4,283.36

-

26.7375.0

2

81.525 18.575 17.377.5

85 4 974.01962.

37

3,050.99348.

56

3,404.83

4,310.93

-

55.32102.

59

88.630 11.470 20.258.9

Table VI.23 ProductEquipment Class 4 - 400 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

1, 2, 

3, 4, 5-- Baseline 929.26910.80

3,229.774,46

2.71

4,043.68

5,373.51 -- -- -- --

--1 1 964.99947.

78

3,1914,416.5

7

4,049.99

5,364.35 -6.319.16 77.523 22.577 16.7215.4

6, 72, 3, 4 2 982.37965.

77

3,160.574,37

7.27

4,042.61

5,343.04 1.0730.47 64.07 36.093 13.5312.4

-- 3 1,090.2207

7.40

3,068.384,25

6.85

4,092.80

5,334.25

-

49.1239.2

6

91.061 9.039 20.5624.5

85 4 1,128.5011

7.02

3,050.994,23

8.70

4,119.92

5,355.73

-

76.2417.7

9

92.868 7.232 22.4727.7

Sub-GroupSubgroup: Transportation Facility Owners

1, 2, 

3, 4, 5-- Baseline 760.80 4,173.10 4,933.90 -- -- -- --

--1 1 779.26797.

78

3,229.774,12

6.96

3,652.39

4,924.74 -6.319.16 77.523 22.577 16.7215.4

6, 72, 3, 4 2 814.99815.

77

3,191.574,08

7.66

3,658.71

4,903.43 1.0730.47 64.07 36.093 13.5312.4

-- 3 832.37927.

40

3,160.57958.

53

3,651.32

4,885.93

-

40.2747.9

7

88.361 11.739 21.3924.5

85 4 940.22967.

02 3,068940.38 3,692.664,907.40

-

67.3926.4

9

90.968 9.132 23.2127.7

Sub-GroupSubgroup: Warehouse Owners

249
1, 2, 

3, 4, 5-- Baseline 779.26760.80

3,229.774,17

3.10

3,652.39

4,933.90 -- -- -- --

--1 1 814.99797.

78

3,191.574,12

6.96

3,658.71

4,924.74 -6.319.16 77.523 22.577 16.7215.4

6, 72, 3, 4 2 832.37815.

77

3,160.574,08

7.66

3,651.32

4,903.43 1.0730.47 64.07 36.093 13.5312.4

-- 3 940.22927.

40

3,068.38958.

53

3,692.66

4,885.93

-

40.2747.9

7

88.355 11.745 21.390

85 4 978.50967.

02

3,050.99940.

38

3,719.78

4,907.40

-

67.3926.4

9

90.962 9.138 23.2124.1

Table VI.24 ProductEquipment Class 4 -5 -- 1000 Watt Metal Halide Lamp Fixtures 

(Indoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

20102012

$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

-- Baseline 7,819.601,

353.88

9,504.0712,4

20.47

7,819.601

3,774.35 -- -- -- --

1 1 + DS* 7,795.031,

417.74

9,244.4411,8

85.42

7,795.031

3,303.15

259.6347

1.20 0.0 100.0 2.301.8

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 7,765.261,431.85

9,230.4911,8

40.29

7,765.261

3,272.15

273.5850

2.21 0.0 100.0 2.600

Sub-GroupSubgroup: Transportation Facility Owners

-- Baseline 1,161.9714

3.88

7,819.6013,4

79.99

10,355.83

14,623.87 -- -- -- --

1 1 + DS* 1,223.6720

7.74

7,795.0312,8

35.48

10,015.54

14,043.22

340.2958

0.65 0.0 100.0 1.855

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,237.30221.85

7,765.2612,7

80.37

9,995.751

4,002.23

360.0862

1.64 0.0 100.0 2.091.7

Sub-GroupSubgroup: Warehouse Owners

-- Baseline 1,161.9714

3.88

7,819.6011,6

57.30

8,712.861

2,801.18 -- -- -- --

1 1 + DS* 1,223.6720

7.74

7,795.0311,1

22.24

8,453.231

2,329.98

259.6347

1.20 0.0 100.0 2.301.4

250
2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,237.30221.85

7,765.2611,0

77.12

8,439.281

2,298.97

273.5850

2.21 0.0 100.0 2.601.6

* DS = Design standard requiring all ballasts sold in new fixtures to be pulse sold shall not contain a probestart ballast.

Table VI.25 ProductEquipment Class 4 -5 -- 1000 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

20102012$ Life-Cycle Cost Savings

Median

Payback

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2010201

2$

Percent of 

ConsumersCusto

mers that 

Experience

Net

Cost

Net 

Benefit

Sub-GroupSubgroup: Utilities

-- Baseline 1,331.0531

1.52

7,819.6010,5

28.44

8,115.831

1,839.96 -- -- -- --

1 1 + DS* 1,390.1537

2.70

7,795.0310,0

82.08

7,89611,4

54.77

219.0638

5.18 0.0 100.0 2.896

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,403386.22

7,765.2610,0

44.72

7,886.371

1,430.93

229.4640

9.02 0.10 99.9100.0 3.260

Sub-GroupSubgroup: Transportation Facility Owners

-- Baseline 1,121.0510

1.52

7,819.609,85

4.56

7,468.911

0,956.08 -- -- -- --

1 1 + DS* 1,180.1516

2.70

7,795.039,40

8.20

7,249.851

0,570.89

219.0638

5.18 0.0 100.0 2.896

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,193176.22

7,765.269,37

0.84

7,239.451

0,547.05

229.4640

9.02 0.10 99.9100.0 3.260

Sub-GroupSubgroup: Warehouse Owners

-- Baseline 1,121.0510

1.52

7,819.609,85

4.56

7,468.911

0,956.08 -- -- -- --

1 1 + DS* 1,180.1516

2.70

7,795.039,40

8.20

7,249.851

0,570.89

219.0638

5.18 0.0 100.0 2.896

2, 3, 4, 5,

6, 7, 8, 9 2 + DS* 1,193176.22

7,765.269,37

0.84

7,239.451

0,547.05

229.4640

9.02 0.10 99.9100.0 3.260

* DS = Design standard requiring that all ballasts sold in new fixtures to be pulse sold shall not contain a 

probe-start ballast.

251
c. Rebuttable Presumption Payback

As discussed in section IV.D.2, EPCA provides a rebuttable presumption that an 

energy conservation standard is economically justified if the increased purchase cost for 

equipment that meets the standard is less than three times the value of the first-year 

energy savings resulting from the standard. DOE’s LCC and PBP analysis generates 

values for calculating the PBP for consumerscustomers affected by potential energy 

conservation standards. This includes the 3-year PBP contemplated under the rebuttable 

presumption test discussed in section IV.D.2. DOE, however, routinely conducts an 

economic analysis that considers the full range of impacts—including those on 

consumers, manufacturers, the nation, and the environment—as required under 42 U.S.C. 

6295(o)(2)(B)(i).

For this proposed rule, DOE calculated a rebuttable presumption PBP for each 

TSL. DOE used discrete values rather than distributions for inputs and, as required by 

EPCA, based the calculations on using the applicable DOE test procedures for metal 

halide lamp fixtures. DOE then calculated a single rebuttable presumption payback value, 

rather than a distribution of PBPs, for each TSL. Table VI.26 shows the rebuttable 

presumption PBPs that are less than 3 years. 

While DOE examined the rebuttable-presumption criterion, it also conducted a 

more detailed analysis of the economic impacts of these levels to determine whether the 

proposed standard levels are economically justified pursuant to 42 U.S.C. 

252
6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to evaluate the 

economic justification for a potential standard level (thereby supporting or rebutting the 

results of any preliminary determination of economic justification).

Table VI.26 Fixture Efficiency Levels with a Rebuttable Payback Period of Less 

Than Three Years 

Equipment Class Efficiency

Level

Mean Payback 

Period

years

Efficiency

Level

70 W (indoor, magnetic baseline) 1 0.555

3 2.95

70 W (outdoor, magnetic baseline) 1 0.575

150 W (indoor) 3 2.11

1000 W (indoor) 1 + DS* 2.161.7

2 + DS* 2.421.9

1000 W (outdoor) 1 + DS* 2.674

2 + DS* 2.7

* DS = Design standard requiring that all ballasts sold in new fixtures to be 

pulse shall not contain a probe-start. ballast

2. Economic Impacts on Manufacturers

DOE performed an MIA to estimate the impact of new and amended energy 

conservation standards on manufacturers of metal halide lamp fixtures and metal halide 

ballasts. The section below describes the expected impacts on manufacturers at each TSL. 

Chapter 13 of the NOPR TSD explains the analysis in further detail.

a. Industry Cash-Flow Analysis Results

The tables below depict the financial impacts (represented by changes in INPV) 

of new and amended energy standards on manufacturers as well as the conversion costs 

that DOE estimates manufacturers would incur at each TSL. DOE breaks out the impacts 

on manufacturers of ballasts and fixtures separately. Within each industry, DOE presents 

Split Cells

Split Cells

Merged Cells

253
the results for all equipment classes in one group because most equipment classes are 

generally made by the same manufacturers. To evaluate the range of cash flow impacts 

on the ballast and fixture industries, DOE modeled four different scenarios using 

different assumptions for markups and shipments that correspond to the range of 

anticipated market responses to new and amended standards. Each scenario results in a 

unique set of cash flows and corresponding industry values at each TSL.

Two of these market response scenarios are presented below, corresponding to the 

outer bounds of a range of market responses that DOE anticipates could occur in the 

standards case. In the following discussion, the INPV results refer to the difference in 

industry value between the base case and the standards case that result from the sum of 

discounted cash flows from the base year (20112013) through the end of the analysis 

period. The results also discuss the difference in cash flow between the base case and the 

standards case in the year before the compliance date.2015. This figure represents the 

size of the required conversion costs relative to the cash flow generated by the industry in 

the absence of new and amended energy conservation standards.

Cash-Flow Analysis Results by TSL for Metal Halide Ballasts

To assess the upper (less severe) end of the range of potential impacts on metal 

halide ballast manufacturers, DOE modeled a flat markup scenario. The flat markup 

scenario assumes that in the standards case, manufacturers would be able to pass along all 

the higher production costs required for more efficient products to their customers. 

Specifically, the industry would be able to maintain its average base case gross margin, as 

254
a percentage of revenue, despite the higher product costs in the standards case. In general, 

the larger the product price increases, the less likely manufacturers are to achieve the 

cash flow from operations calculated in this scenario because it is less likely that 

manufacturers would be able to fully markup these larger cost increases.

DOE also used the high-shipment scenario to assess the upper bound of impacts. 

Under the high-shipment scenario, base case shipments of metal halide lamp fixtures 

decrease at a slower rate over the analysis period compared to the low-shipment scenario.

Of all the scenario combinations analyzed in the MIA, the flat markup and high-shipment 

scenario provides the best conditions for cash flow generation—the annual shipment 

volume and the ability to preserve gross margins are greatest. Thus, this scenario set 

yields the greatest modeled industry profitability.

To assess the lower (more severe) end of the range of potential impacts on the 

metal halide ballast industry, DOE modeled the ‘preservation of operating profit’ markup 

scenario. The scenario represents the lower end of the range of potential impacts on 

manufacturers because no additional operating profit is earned on the higher production 

costs, eroding profit margins as a percentage of total revenue.

DOE also used the low-shipment scenario to assess the lower bound of impacts. 

Under the low-shipment scenario, metal halide lamp fixture shipments decrease at a 

faster rate over the analysis period compared to the high-shipment scenario. Of all the 

scenarios analyzed in the MIA, this combination of scenarios (‘preservation of operating 

255
profit’ markup and low-shipment) most restricts manufacturers’ ability to pass on costs to 

consumerscustomers and assumes the lowest level of shipments. Thus, this scenario set 

estimates the largest manufacturer impacts.

Table VI.27 Manufacturer Impact Analysis for Metal Halide Ballasts — Flat 

Markup and High-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5 6 7 8

INPV (20112012$ 

millions) 252123 251123 

2

5

0

1

2

6

2

4

9

1

2

7

2

5

0

1

2

7

2

5

1

1

5

9

2

5

6

2

5

9

2

9

1

Change in 

INPV

(20112012$ 

millions) -

(1.

2)

(2.

2)

(2

.9

)

(2.1)

(0.8 )

3

.

3

4

.

1

5

4

.

7

.

4

36.538.

7

(%) -

-

0

.

5

7

%

-

0.

9

%

-

1

.

2

%

.

7

3

.

7

-

0

3

.

8

%

-

0

.

3

%

2

9

.

8

1

.

6

%

2

.

9

%

1

5

.

4

%

Product 

Conversion 

Costs

(20112012$ 

millions) - 59 

7 7 8 8 1

0

1

2 1813 1

4

2

0

Capital 

Conversion 

Costs

(20112012$ 

millions) -

5 9 8 7 6

10 

8

1

7

6

1

6

1

4 7

Total 

Conversion 

Costs

(20112012$ 

millions) - 1019 

1

6

3

0

1

5

2

9

1

5

2

8

1

4

2

6

2

0

2

0

2

4

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256
Table VI.28 Manufacturer Impact Analysis for Metal Halide Ballasts —

Preservation of Operating Profit Markup and Low-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5 678

INPV (20112012$ 

millions) 235103 22886 

22

27

7

2

2

3

7

7

2

2

4

7

9

2

2

4

7

9

2

1

8

2

1

8

2

1

5

Change in INPV

(20112012$ 

millions) - (7.417.1)

(12

.52

6.8

)

(

1

1

.

6

2

5

.

9

)

(

1

1

.

3

2

4

.

8

)

(

1

0

.

5

2

4

.

1

)

(

1

6

.

6

)

(

1

6

.

5

)

(

2

0

.

3

)

(%) -

-

3.116.

6%

-5.3% -

4

2

5

.

9

%

-

4

.

8

%

-

4

.

5

%

-

7

2

5

.

0

%

-

7

2

4

.

0

%

-

8.6

%23

.3

Product 

Conversion 

Costs

(20112012$ 

millions) - 59 

7 7 881

0 12

1

8

1

3

1

4 20

Capital 

Conversion 

Costs

(20112012$ 

millions) -

5 9 8 7 6 1

0

8

1

7

616 1

4 7

Total 

Conversion 

Costs

(20112012$ 

millions) - 1019 1630

1

5

2

9

1

5

2

8

1

4

2

6

2

0

2

0

2

4

TSL 1 is EL1 for sixall ten equipment classes (the 70 W indoor and outdoor, 150 

W indoor and outdoor, and 1000 W indoor and outdoor fixtures) and baseline for four 

equipment classes (the 250 W indoor and outdoor and, 400 W indoor and outdoor, and 

1000 W indoor and outdoor fixtures). At TSL 1, DOE estimates impacts on INPV range 

from -$1.2$0.8 million to -$7.417.1 million, or a change in INPV of -0.57 percent to -

3.116.6 percent. At TSL 1, industry free cash flow (operating cash flow minus capital 

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257
expenditures) under the low-shipment scenario is estimated to decrease by approximately 

2568 percent to $10.03.4 million, compared to the base case value of $13.310.7 million in 

the year leading up to the proposed energy conservation standards.2015. Under the highshipment scenario, industry free cash flow is estimated to decrease by approximately 

2569 percent to $9.93.3 million, compared to the base case value of $13.210.6 million in 

the year leading up to the proposed energy conservation standards2015.

Impacts on INPV are slightly positive to moderately negative at TSL 1. TSL 1 

requires the use of more efficient magnetic ballasts for the 70 W indoor and outdoor, 150 

W indoor and outdoor, 250 W indoor and outdoor, 400 W indoor and outdoor, and 1000 

W indoor and outdoor equipment classes. DOE projects that in 2015, the year in which 

compliance with any new and amended standards is proposed to be required,2016 100 

percent of 70 W indoor shipments, 45 percent of 150 W indoor shipments, 814 percent of 

250 W indoor shipments, 23 percent of 400 W indoor shipments, 10 percent of 1000 W 

indoor shipments, 2030 percent of 70 W outdoor shipments, 0zero percent of 150 W 

outdoor shipments, 10 percent of 250 W outdoor shipments, 10 percent of 400 W 

outdoor, and 6 percent of 1000 W outdoor shipments would meet TSL 1 or higher in the 

base case.

Conversion costs are expected to be moderate at TSL 1. DOE expects ballast 

manufacturers to incur $59 million in product conversion costs for model redesigns and 

testing and $510 million in capital conversion costs for equipment such as stamping dies 

to process more efficient steel cores.

258
At TSL 1, under the flat markup scenario the shipment-weighted average MPC 

increases by 925 percent relative to the base case MPC. Under the flat markup scenario, 

Manufacturers are able to fully pass on this cost increase to consumers.customers under 

this scenario. Additionally, under the high-shipment scenario, shipments are 191 percent 

higher than shipments under the low-shipment scenario byin the endlast year of the 

analysis period. Thus, manufacturers generate the most revenue under this combination 

(flat markup and high-shipment) of scenarios. The moderate price increase applied to a 

large quantity of shipments mitigates the impact of the $1019 million in conversion costs 

estimated at TSL 1, resulting in slightly negativepositive impacts at TSL 1 under the flat 

markup and high-shipment scenarios.

Under the ‘preservation of operating profit’ markup scenario, manufacturers earn 

the same operating profit as would be earned in the base case in 2016 (the year following 

the compliance date of new and amended standards),2017, but manufacturers do not earn 

additional profit from their investments. The 922 percent MPC increase is outweighed by 

a lower average markup of 1.4644 in the ‘preservation of operating profit’ markup 

scenario (compared to the flat markup scenario markup of 1.47) and $1019 million in 

conversion costs, resulting in greater negative impacts at TSL 1 under this scenario. On a 

percentage basis, the low-shipment scenario exacerbates these impacts relative to the 

high-shipment scenario because the base case INPV against which the absolute change in 

INPV is compared is 716 percent lower in the low shipment scenario compared to the 

high shipment scenario.

259
TSL 2 is EL1EL2 for sixall ten equipment classes (the 70 W indoor and outdoor, 

150 W indoor and outdoor, 250 W indoor and outdoor, 400 W indoor and outdoor, and 

1000 W indoor and outdoor fixtures) and baseline for four equipment classes (the 250 W 

indoor and outdoor and 400 W indoor and outdoor fixtures).). At TSL 2, DOE estimates 

impacts on INPV to range from -$2.2$3.3 million to -$12.526.8 million, or a change in 

INPV of -0.2.7 percent to -25.9 percent to -5.3 percent.. At this proposed level, industry 

free cash flow under the low-shipment scenario is estimated to decrease by approximately 

42106 percent to $-$0.7.8 million, compared to the base case value of $13.310.7 million 

in the year leading up to the proposed energy conservation standards2015. Under the 

high-shipment scenario, industry free cash flow is estimated to decrease by 

approximately 42108 percent to $7.7-$0.8 million, compared to the base case value of 

$13.210.6 million in the year leading up to the proposed energy conservation 

standards2015.

TSL 2 is the highest efficiency level the engineering analysis assumes 

manufacturers can meet with magnetic ballasts for the 70 W, 150 W, and 1000 W 

equipment classes. At TSL 2, no standards are amended for the 250 W and 400 Wall

equipment classes. DOE projects that in 20152016, 100 percent of 70 W indoor 

shipments, 45 percent of 150 W indoor shipments, 410 percent of 250 W indoor, 15 

percent of 400 W indoor, 5 percent of 1000 W indoor shipments, no 70 W and 150 W 

outdoor shipments, and 3 percent of 1000 W outdoor shipments would meet TSL 2 or 

higher in the base case. No shipments from the 70 W outdoor, 150 W outdoor, 250 W 

260
outdoor, and 400 W outdoor equipment classes would meet TSL 2 or higher in the base 

case. At TSL 2, product conversion costs rise to $712 million and capital conversion 

costs rise to $917 million as manufacturers need to purchase additional equipment and 

tooling to upgrade magnetic production lines.

At TSL 2, under the flat markup scenario the shipment-weighted average MPC 

increases 1440 percent over the base case MPC. Under the flat markupIn this scenario,

INPV impacts are slightly negativepositive because the $16 million in conversion costs 

outweighs manufacturers’ ability to pass on the higher equipment costs to 

consumers.customers outweighs the $30 million in conversion costs. Under the 

‘preservation of operating profit’ markup scenario, the 35 percent MPC increase is 

outweighed by a lower average markup decreases to 1.45 because of manufacturers’ 

inability to earn additional profits from the investments necessary to meet TSL 2 (as 

explained above),of 1.42 and $30 million in conversion costs, resulting in moderately 

negative INPV impacts at TSL 2.

TSL 3 includes, for the first time, EL3EL4 for two equipment classes (the 150 W 

indoor and outdoor fixtures),) and EL2 for fourthe other eight equipment classes (the 70 

W indoor and outdoor, 250 W indoor and outdoor, 400 W indoor and outdoor, and 1000 

W indoor and outdoor fixtures), and baseline for four equipment classes (the 250 W 

indoor and outdoor and 400 W indoor and outdoor fixtures).). At TSL 3, DOE estimates 

impacts on INPV to range from -$2$4.5 million to -$25.9 million to -$11.6 million, or a 

change in INPV of -1.23.7 percent to -4.925.0 percent. At this proposed level, industry 

261
free cash flow under the low-shipment scenario is estimated to decrease by approximately 

38102 percent to $8-$0.2 million, compared to the base case value of $13.310.7 million 

in the year leading up to the proposed energy conservation standards2015. Under the 

high-shipment scenario, industry free cash flow is estimated to decrease by 

approximately 39104 percent to $8.1-$0.4 million, compared to the base case value of 

$13.210.6 million in the year leading up to the proposed energy conservation 

standards2015.

The technology changes from TSL 2 to TSL 3 is the first TSL at which are that 

manufacturers must use max tech level electronic ballasts are necessary (EL3) to meet the 

required efficiencies for the 150 W indoor and outdoor equipment classes at TSL 3. This 

has a negligible effect on total conversion costs, which slightly decreases to $29 million. 

DOE projects that 4 percent ofno 150 W indoor and no 150 Wor outdoor shipments 

would meet TSL 3 or higher in 20152016 in the base case. DOE expects product 

conversion costs to remain at $7increase slightly to $13 million. and capital conversion 

costs willto decrease from $9slightly to $16 million at TSL 2 to $8 million .

At TSL 3, however, because several manufacturers stated that their equipment for 

the production of electronic ballasts is flexible and able to handle additional production, 

compared to the tooling costs that would have been necessary to upgrade magnetic 150 

W lines at TSL 2.

262
The shipment-weighted average MPC increases 12 percent at TSL 3 compared to 

the base case. under the flat markup scenario, the $15 million in conversion costs and 

higher working capital requirements outweigh the the shipment-weighted average MPC 

increases 40 percent over the base case MPC. In this scenario the additional revenues 

earned from passing on these costshigher MPC costs outweigh the $29 million in 

conversion costs and higher working capital requirements, resulting in slightly 

negativepositive INPV impacts. Under the ‘preservation of operating profitprofit’ markup 

scenario, the 35 percent MPC increase is outweighed by a lower average markup 

decreases to 1.45of 1.42 and $29 million in conversion costs, resulting in INPV results 

remaining moderately negative impactsat TSL 3.

TSL 4 includes, for the first time,is EL4 for two equipment classes (the 150 W 

indoor and outdoor fixtures), EL3 for one equipment class (the 150 W indoor 70 W 

outdoor fixtures), and EL2 for the remaining seven equipment classes (the 70 W indoor 

fixtures) and EL3 for two equipment classes (the 70, 250 W indoor and 150 W outdoor 

fixtures). It is EL2 for three equipment classes (the 70, 400 W indoor and outdoor

fixtures, and 1000 W indoor and outdoor fixtures) and baseline for four equipment 

classes (the 250 W indoor and outdoor and 400 W indoor and outdoor fixtures). At TSL 

4, DOE estimates impacts on INPV to range from -$2.1$4.7 million to -$11.324.8

million, or a change in INPV of -03.8 percent to -4.824.0 percent. At this proposed level, 

industry free cash flow under the low-shipment scenario is estimated to decrease by 

approximately 3797 percent to $8.40.3 million, compared to the base case value of 

$13.310.7 million in the year leading up to the proposed energy conservation 

263
standards2015. Under the high-shipment scenario, industry free cash flow is estimated to 

decrease by approximately 3898 percent to $80.2 million, compared to the base case 

value of $13.210.6 million in the year leading up to the proposed energy conservation 

standards2015.

The technology changes from TSL 3 to TSL 4 are that manufacturers must use 

electronic ballasts for the 70 W indoor equipment class and use max-tech level electronic 

ballasts for the 150 W indoor outdoor equipment class at TSL 4. This has a negligible 

effect on DOE projects that no 70 W outdoor shipments would meet TSL 4 or higher in 

2016 in the base case. Total conversion costs, which remain at $15 decrease from $29

million at TSL 3 to $28 million at TSL 4, because of the flexibility of electronic ballast 

production within the lighting manufacturing industry.

At TSL 4, under the flat markup scenario the shipment-weighted average MPC 

increases 39 percent over the base case MPC. In this scenario the additional revenues 

earned from passing on these higher MPC costs outweigh the $28 million in conversion 

costs, resulting in slightly positive impacts on INPV. Under the ‘preservation of operating 

profit’ markup scenario, the 34 percent MPC increase is outweighed by a lower average 

markup of 1.42 and $28 million in conversion costs, resulting in INPV results remaining 

moderately negative at TSL 4.

TSL 5 is EL4 for eight equipment classes (the 70 W indoor and outdoor fixtures, 

150 W indoor and outdoor fixtures, 250 W indoor and outdoor fixtures, and 400 W 

264
indoor and outdoor fixtures) and EL2 for two equipment classes (the 1000 W indoor and 

outdoor fixtures). At TSL 5, DOE estimates impacts on INPV to range from $36.5 

million to -$24.1 million, or a change in INPV of 29.8 percent to -23.3 percent. At this 

proposed level, industry free cash flow under the low-shipment scenario is estimated to 

decrease by approximately 83 percent to $1.8 million, compared to the base case value of 

$10.7 million in 2015. Under the high-shipment scenario, industry free cash flow is 

estimated to decrease by approximately 84 percent to $1.7 million, compared to the base 

case value of $10.6 million in 2015.

At TSL 5, the stringency of standards increases to max tech ballasts for the 70 W 

indoor and outdoor, 250 W indoor and outdoor, and 400 W outdoor equipment classes 

compared to TSL 4. DOE projects that 931 percent of 70 W indoor and no 150 W indoor 

shipments would meet TSL 45 or higher in 20152016 in the base case. DOE expectsNo 

shipments from the 70 W outdoor, 250 W indoor or outdoor, and 400 W indoor or 

outdoor equipment classes would meet TSL 5 or higher in the base case. As a result,

product conversion costs increase to rise to $8$20 million because of the higher cost of 

redesigning and testing electronic ballasts for the 70 W indoor equipment class.need to 

redesign and test additional models, and capital conversion costs will decrease from $8 

million at TSL 3 to $7 million at TSL 4, however, because several manufacturers stated 

that their equipment fordue to the flexibility of electronic ballast production of electronic 

ballasts is flexible and able to handle additional production, compared to the tooling costs 

that would have been necessary to upgrade magnetic 70 W lines at TSL 3.

265
At TSL 4,5, under the flat markup scenario the shipment-weighted average MPC 

increases 1376 percent over the base case MPC. Under the flat markup scenario, the $15 

million in conversion costs and higher working capital requirements outweigh the In this 

scenario the additional revenues earned from passing on these costshigher MPC costs 

outweigh the decreased conversion costs of $26 million, resulting in slightly negativea 

significantly positive impact on INPV impacts. Under the ‘preservation of operating 

profit’ markup scenario, INPV results remain moderately negative at TSL 4 because of 

the lower markup of 1.45.

TSL 5 is EL4 for two equipment classes (the 150 W indoor and outdoor fixtures), 

EL3 for two equipment classes (the 70 W indoor and outdoor fixtures), EL2 for two 

equipment classes (the 1000 W indoor and outdoor fixtures) and baseline for four 

equipment classes (the 250 W indoor and outdoor and 400 W indoor and outdoor 

fixtures). At TSL 5, DOE estimates impacts on INPV to range from -$0.8 million to -

$10.5 million, or a change in INPV of -0.3the 67 percent to -4.5 percent. At this proposed 

level, industry free cash flow under the low shipment scenario is estimated to decrease by 

approximately 34 percent to $8.8 million, compared to the base case value of $13.3 

million in the year leading up to the proposed energy conservation standards. Under the 

high shipment scenario, industry free cash flow is estimated to decrease by approximately 

35 percent to $8.6 million, compared to the base case value of $13.2 million in the year 

leading up to the proposed energy conservation standards.

266
The technology changes from TSL 4 to TSL 5 are that manufacturers must use 

electronic ballasts for the 70 W outdoor equipment class and use max-tech level 

electronic ballasts for the 150 W outdoor equipment class at TSL 5. This decreases total 

conversion costs, which fall from $15 million at TSL 4 to $14 million at TSL 5, because 

of the flexibility of electronic production.

At TSL 5, the shipment-weighted average MPC increases 13 percent over the 

base case MPC, similar to TSL 4. Under the flat markup scenario, the additional revenue 

does not outweigh the lower conversion costs, resulting in slightly negative impacts on 

INPV. Under the ‘preservation of operating profit’ markup scenario, INPV results remain 

moderately negative at TSL 5 because of the lower markup of 1.45.

TSL 6 is EL4 for one equipment class (the 250 W indoor fixtures), EL3 for three 

equipment classes (the 70 W indoor and 150 W indoor and outdoor fixtures), EL2 for 

four equipment classes (the 70 W outdoor, 400 W outdoor, and 1000 W indoor and 

outdoor fixtures), and baseline for two equipment classes (the 250 W outdoor and 400 W 

indoor fixtures). At TSL 6, DOE estimates impacts on INPV to range from $4.1 million 

to -$16.6 million, or a change in INPV of 1.6 percent to -7.0 percent. At this proposed 

level, industry free cash flow under the low shipment scenario is estimated to decrease by 

approximately 50 percent to $6.7 million, compared to the base case value of $13.3 

million in the year leading up to the proposed energy conservation standards. Under the 

high shipment scenario, industry free cash flow is estimated to decrease by approximately 

267
51 percent to $6.5 million, compared to the base case value of $13.2 million in the year 

leading up to the proposed energy conservation standards.

At TSL 6, the stringency of standards increases for the 250 W indoor and 400 W 

outdoor equipment classes and decreases for the 150 W indoor and outdoor and 70 W 

outdoor equipment classes compared to TSL 5. For the 150 W equipment classes, 

manufacturers no longer need max-tech level electronic ballasts to meet the required 

efficiencies, and for the 70 W indoor equipment class, manufacturers no longer need to 

use electronic ballasts to meet the required efficiencies. For the 250 W indoor equipment 

class, manufacturers need max-tech level electronic ballasts, and for the 400 W outdoor 

equipment class, manufacturers need to use the highest efficiency magnetic ballasts. DOE 

projects that no 250 W indoor or 400 W outdoor shipments would meet TSL 6 or higher 

in 2015 in the base case. As a result, product conversion costs increase to $10 million 

because of the need to redesign and test additional models and capital conversion costs 

increase to $10 million.

At TSL 6, the shipment-weighted average MPC increases 28 percent over the 

base case MPC. Under the flat markup scenario, the revenue increase outweighs the 

increased conversion costs of $20 million, resulting in a positive impact on INPV. Under 

the ‘preservation of operating profit’ markup scenario, impacts are slightly more negative 

at TSL 6 compared to TSL 5 because manufacturers earn a lower average markup of 

1.43.

268
TSL 7 is EL4 for four equipment classes (the 70 W outdoor, 150 W indoor and 

outdoor, and 250 W indoor fixtures), EL3 for one equipment class (the 70 W indoor 

fixtures), EL2 for three equipment classes (the 400 W outdoor and 1000 W indoor and 

outdoor fixtures), and baseline for two equipment classes (the 250 W outdoor and 400 W 

indoor fixtures). At TSL 7, DOE estimates impacts on INPV to range from $7.4 million 

to -$16.5 million, or a change in INPV of 2.9 percent to -16.5 percent. At this proposed 

level, industry free cash flow under the low shipment scenario is estimated to decrease by 

approximately 49 percent to $6.8 million, compared to the base case value of $13.3 

million in the year leading up to the proposed energy conservation standards. Under the 

high shipment scenario, industry free cash flow is estimated to decrease by approximately 

49 percent to $6.7 million, compared to the base case value of $13.2 million in the year 

leading up to the proposed energy conservation standards.

The requirements at TSL 7 differ from those for TSL 6 for the 70 W outdoor and 

150 W indoor and outdoor equipment classes. For the 70 W outdoor and 150 W 

equipment classes, manufacturers need max-tech level electronic ballasts. DOE projects 

that no 70 W outdoor or 150 W indoor and outdoor shipments would meet TSL 7 or 

higher in 2015 in the base case. The net effect of these changes is an increase in product 

conversion costs to $12 million because of additional redesigns and testing and a 

decrease in capital conversion costs to $8 million because of the flexibility of electronic 

ballast production lines.

269
At TSL 7, the shipment-weighted average MPC increases 32 percent over the 

base case MPC. Under the flat markup scenario, revenue increases from TSL 6 to TSL 7 

due to a larger MPC increase while the conversion costs remain at $20 million. This 

yields greater positive impacts at TSL 7 than at TSL 6. Under the preservation of 

operating profit markup scenario, impacts remain moderately negative because of the 

lower average markup of 1.42.

TSL 8 is EL4 for eight equipment classes (the 70 W indoor and outdoor, 150 W 

indoor and outdoor, 250 W indoor and outdoor, and 400 W indoor and outdoor fixtures) 

and EL2 for two equipment classes (the 1000 W indoor and outdoor fixtures). At TSL 8, 

DOE estimates impacts on INPV to range from $38.7 million to -$20.3 million, or a 

change in INPV of 15.4 percent to -8.6 percent. At this proposed level, industry free cash 

flow under the low shipment scenario is estimated to decrease by approximately 55 

percent to $6.1 million, compared to the base case value of $13.3 million in the year 

leading up to the proposed energy conservation standards. Under the high shipment 

scenario, industry free cash flow is estimated to decrease by approximately 55 percent to 

$5.9 million, compared to the base case value of $13.2 million in the year leading up to 

the proposed energy conservation standards.

TSL 8 represents the max-tech level for all equipment classes: high-efficiency 

electronic ballasts for the 70 W, 250 W, and 400 W equipment classes and high 

efficiency magnetic pulse start ballasts for the 1000 W equipment classes. DOE 

anticipates that no shipments would meet TSL 8 in 2015 in the base case for these 

270
equipment classes. The increased stringency of the 400 W equipment classes drives an 

increase in product conversion costs to $18 million while capital conversion costs decline 

to $6 million.

At TSL 8, the shipment-weighted average MPC increases 77 percent over the 

base case MPC. Under the flat markup scenario, impacts are significantly more positive 

at TSL 8 compared to TSL 7 because the increased revenue greatly outweighs the 

increase in conversion costs. Under the preservation of operating profit markup scenario, 

the increased conversion costs of $24 million cause marginally worse impacts because 

manufacturers cannot fully pass on increased product costs, as evidenced by theis 

outweighed by a lower average markup of 1.39 and $26 million in conversion costs, 

resulting in INPV results remaining moderately negative at TSL 5.

Cash Flow Analysis Results by TSL for Metal Halide Lamp Fixtures

DOE incorporated the same scenarios to represent the upper and lower bounds of 

industry impacts for metal halide lamp fixtures as for metal halide ballasts: the flat 

markup scenario with the high-shipment scenario and the ‘preservation of operating 

profit’ markup scenario with the low-shipment scenario. Note that the TSLs below 

represent the same sets of efficiency levels as discussed above in the description of 

impacts on ballast manufacturers.

271
Table VI.29 Manufacturer Impact Analysis for Metal Halide Lamp Fixtures — Flat 

Markup and High-Shipment Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5 6 7 8

INPV (20112012$ 

millions) 616630 628667 637694 634695 632703

6

4

4

7

4

1

6

4

6

6

6

0

7

2

2

Change in 

INPV

(20112012$ 

millions) - 12.437.0 

20.

6

1763

.9 16.464.8 27.573.6

3

0

1

1

1

.

3

4

4

.

3

10

6.

3

(%) - 5.9% 10.2.

0%

10.3.

3%

2.9

%

2

1

1

.

7

%

4

.

5

%

4

.

9

%

7

.

2

%

17.3%7

Product 

Conversion 

Costs

(20112012$ 

millions) - 23 23 79 813

1

2

6

2

1

5

2

0

5

7

Capital 

Conversion 

Costs

(20112012$ 

millions) - 0 0 56 710

1

1

7

5

1

6

2

2

6

9

Total 

Conversion 

Costs

(20112012$ 

millions) - 23 23 1215

16

23

3

0

1

3

7

4

2

12

6

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Table VI.30 Manufacturer Impact Analysis for Metal Halide Lamp Fixtures —

Preservation of Operating Profit Markup and Low-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5 6 7 8

INPV (20112012$ 

millions) 544540 542534 541532

5

3

3

5

2

3

5

3

0

5

2

4 5

1

6

5

0

6

4

2

3

436

Change in 

INPV

(20112012$ 

millions) -

(2.

0)

(36.1

)

(10.

8)

(13.

6)

(208.

1)

(

2

8

.

1

1

7

.

3

)

(3

8.

6)

(

1

0

7

2

3

.

8

)

(116.9)

(%) -

-

0.41.

1%

-

0.6

%

-

2.0

%

-

21.5

%

-

3.7%

2

-

5

.

2

%

4

.

4

-

7

.

1

%

2

1

.

6

-

19.8

%

Product 

Conversion 

Costs

(20112012$ 

millions) - 23 23 79

8

1

3

1

2

6

2

1

5

2

0

5

7

Capital 

Conversion 

Costs

(20112012$ 

millions) - 0 0 56

7

1

0

1

1

7

5

1

6

2

2

6

9

Total 

Conversion 

Costs

(20112012$ 

millions) - 23 23

1

2

1

5

16

2

3

3

0

1

3

7

4

2

12

6

At TSL 1, DOE estimates impacts on INPV to range from $12.4 million to -

$237.0 million to -$6.1 million, or a change in INPV of 2.05.9 percent to -0.41.1 percent. 

At TSL 1, industry free cash flow under the low-shipment scenario is estimated to 

decrease by approximately 12 percent to $58.17 million, compared to the base case value 

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273
of $58.659.8 million in the year leading up to the proposed energy conservation 

standards2015. Under the high-shipment scenario, industry free cash flow is estimated to 

decrease by approximately 12 percent to $57.358.0 million, compared to the base case 

value of $57.859.1 million in the year leading up to the proposed energy conservation 

standards2015.

DOE expects minimal conversion costs for fixture manufacturers at TSL 1. 

Fixture manufacturers would incur $23 million in product conversion costs for the testing 

of redesigned ballasts. Because the stack height of magnetic ballasts is not expected to 

change in response to the standards, fixture manufacturers would not incur any capital 

conversion costs at magnetic ballast levels such as TSL 1.

At TSL 1, under the flat markup scenario the shipment-weighted average MPC 

increases by 412 percent from the base case MPC. In this scenario manufacturers 

maximize revenue under the flat markup scenario and the high shipment scenario.since 

they are able to fully pass on this cost increase to customers. The moderate price increase 

applied to a large quantity of shipments outweighs the impact of the $23 million in 

conversion costs for TSL 1, resulting in moderately positive impacts at TSL 1 under the 

flat markup and high-shipment scenarios.

Under the ‘preservation of operating profit’ markup scenario, the 410 percent 

MPC increase is outweighed by a lower average markup of 1.5756 (compared to the flat 

manufacturer markup of 1.58) and $23 million in conversion costs, resulting in slightly 

274
negative impacts at TSL 1. These impacts increase on a percentage basis under the lowshipment scenario relative to the high-shipment scenario because the base case INPV 

against which changes are compared is 1214 percent lower.

At TSL 2, DOE estimates impacts on INPV to range from $20.663.9 million to -

$38.1 million, or a change in INPV of 3.310.2 percent to -0.61.5 percent. At this 

proposed level, industry free cash flow under the low-shipment scenario is estimated to 

decrease by approximately 12 percent to $58.17 million, compared to the base case value 

of $58.659.8 million in the year leading up to the proposed energy conservation 

standards.2015. Under the high-shipment scenario, industry free cash flow is estimated to 

decrease by approximately 12 percent to $57.358.0 million, compared to the base case 

value of $57.859.1 million in the year leading up to the proposed energy conservation 

standards2015.

At TSL 2, DOE expects conversion costs to remain low at $23 million for the 

testing of redesigned ballasts and catalog updates. Under the flat markup scenario the 

shipment-weighted average MPC increases 719 percent over the base case MPC. Under 

the flat markupIn this scenario, the INPV impacts are positive because the ability to pass 

on the higher equipment costs to consumerscustomers outweighs the $23 million in 

estimated conversion costs. Under the ‘preservation of operating profit’ markup scenario, 

the 15 percent MPC increase is outweighed by a lower average markup decreases to 

1.56of 1.53 and $3 million in conversion costs, resulting in slightly negative INPV 

impacts at TSL 2.

275
At TSL 3, DOE estimates impacts on INPV to range from $64.8 million to -$17.9 

million to -$10.83 million, or a change in INPV of 2.9 percent to -2.010.3 percent. to -3.2 

percent. At this proposed level, industry free cash flow under the low-shipment scenario 

is estimated to decrease by approximately 79 percent to $54.62 million, compared to the 

base case value of $58.659.8 million in the year leading up to the proposed energy 

conservation standards.2015. Under the high-shipment scenario, industry free cash flow 

is estimated to decrease by approximately 79 percent to $53.85 million, compared to the 

base case value of $57.859.1 million in the year leading up to the proposed energy 

conservation standards2015. DOE expects product conversion costs to increase to $79

million because of the additional cost of redesigning fixtures for thermal protection to 

accommodate 150 W indoor and outdoor electronic ballasts. Manufacturers would also 

incur an estimated $56 million in capital costs for 150 W indoor fixture changes.

At TSL 3, the shipment-weighted average MPC increases 8 percent over the base 

case MPC. Even though the electronic ballast used at TSL 3 is less expensive than the 

magnetic ballast used at TSL 2, the electronic fixture cost increases at TSL 3for the 150 

W indoor and outdoor equipment classes because of fixture adders for thermal protection 

and voltage transient protection. Under the flat markup scenario, the increase in revenue 

outweighs the $12 million in estimated conversion costs, resulting in moderately positive 

impacts at TSL 3. Under the ‘preservation of operating profit’ markup scenario, INPV 

results are moderately negative at TSL 3 because of the lower markup of 1.56 and the 

increase in total conversion costs to $12 million.

276
At TSL 4, DOE estimates impacts on INPV to range from $16.4 million to -$13.6 

million, or a change in INPV of 2.7 percent to -2.5 percent. At this proposed level, 

industry free cash flow under the low shipment scenario is estimated to decrease by 

approximately 9 percent to $53.3 million, compared to the base case value of $58.6 

million in the year leading up to the proposed energy conservation standards. Under the 

high shipment scenario, industry free cash flow is estimated to decrease by approximately 

9 percent to $52.5 million, compared to the base case value of $57.8 million in the year 

leading up to the proposed energy conservation standards. DOE expects product 

conversion costs to increase to $8 million because of the additional cost of redesigning 

fixtures for thermal protection to accommodate 70 W indoor electronic ballasts. 

Manufacturers would also incur an estimated $7 million in capital costs for 70 W indoor 

fixture changes.

At TSL 4, the shipment-weighted average MPC increases 8 percent over the base 

case MPC. Even though the electronic ballast used at TSL 4 is less expensive than the 

magnetic ballast used at TSL 3 for the 70 W indoor equipment class, the electronic 

fixture cost increases at TSL 4 for the 70 W equipment class because of fixture adders for 

thermal protection and voltage transient protection. Under the flat markup scenario, the 

shipment-weighted average MPC increases 21 percent over the base case MPC. This 

increase in revenue outweighs the increase of $15 million in conversion costs, resulting in 

moderately positive impacts at TSL 43. Under the ‘preservation of operating profit’ 

markup scenario, INPV results are moderately negative at TSL 4 because of the 17 

277
percent MPC increase is outweighed by a lower average markup of 1.5653 and the 

increase$15 million in total conversion costs to $16 million, resulting in slightly negative 

INPV impacts at TSL 3.

At TSL 54, DOE estimates impacts on INPV to range from $27.573.6 million to -

$20.123.8 million, or a change in INPV of 4.5 percent to -311.7 percent to -4.4 percent. 

At this proposed level, industry free cash flow under the low-shipment scenario is 

estimated to decrease by approximately 1314 percent to $50.951.4 million, compared to 

the base case value of $58.659.8 million in the year leading up to the proposed energy 

conservation standards.2015. Under the high-shipment scenario, industry free cash flow 

is estimated to decrease by approximately 1314 percent to $50.17 million, compared to 

the base case value of $57.859.1 million in the year leading up to the proposed energy 

conservation standards2015.

The technology changes from TSL 43 to TSL 54 are that manufacturers must use 

electronic ballasts to meet the required efficiencies for the 70 W outdoor fixture class and 

must use max-tech level electronic ballasts to meet the required efficiencies for the 150 

W outdoor fixture class at TSL 5.at TSL 4. This increases the product conversion costs 

from $89 million at TSL 43 to $1213 million at TSL 54 and increases the capital 

conversion costs from $76 million at TSL 43 to $1110 million at TSL 54.

At TSL 5,4, under the flat markup scenario the shipment-weighted average MPC 

increases 1326 percent over the base case MPC. Under the flat markupIn this scenario,

278
the additional revenue results in slightly more positive impacts on INPV. at TSL 4 

compared to TSL 3. Under the ‘preservation of operating profit’ markup scenario, 

impacts are the 21 percent MPC increase is outweighed by a lower average markup of 

1.52 and $23 million in conversion costs, resulting in slightly more negative INPV 

impacts at TSL 54 compared to TSL 4 because the conversion costs increase from $16 

million at TSL 4 to $23 million at TSL 53.

At TSL 65, DOE estimates impacts on INPV to range from $30111.3 million to -

$28.1116.9 million, or a change in INPV of 4.917.7 percent to -5.221.6 percent. At this 

proposed level, industry free cash flow under the low-shipment scenario is estimated to 

decrease by approximately 1889 percent to $48.3 million, compared to the base case 

value of $58.6.5 million, compared to the base case value of $59.8 million in the year 

leading up to the proposed energy conservation standards2015. Under the high-shipment 

scenario, industry free cash flow is estimated to decrease by approximately 1890 percent 

to $47.5.8 million, compared to the base case value of $57.859.1 million in the year 

leading up to the proposed energy conservation standards2015.

At TSL 65, product conversion costs significantly increase to $1562 million as 

manufacturers must redesign the 250 W indoor and 400 W outdoor fixturesall equipment 

classes to accommodate the most efficient electronic ballasts. Capital conversion costs 

also significantly increase to $1675 million because of the need for additional equipment 

and tooling, such as new castings, to incorporate thermal protection in all equipment 

classes.

279
At TSL 6,5, under the flat markup scenario the shipment-weighted average MPC 

increases 1657 percent over the base case MPC. Under the flat markupIn this scenario,

the revenue increase from TSL 54 to TSL 6 5 outweighs the increase in conversion costs 

to $30of $137 million, resulting in slightly greater positive impacts on INPV. at TSL 5 

compared to TSL 4. Under the ‘preservation of operating profit’ markup scenario, 

impacts are more negative at TSL 6 compared to TSL 5 because manufacturers earn the 

46 percent MPC increase is outweighed by a lower average markup of 1.54.

At TSL 7, DOE estimates impacts on INPV to range from $44.347 and $137

million to -$38.6 million, or a change in INPV of 7.2 percent to -7.1 percent. At this 

proposed level, industry free cash flow under the low shipment scenario is estimated to 

decrease by approximately 24 percent to $44.3 million, compared to the base case value

of $58.6 million in the year leading up to the proposed energy conservation standards. 

Under the high shipment scenario, industry free cash flow is estimated to decrease by 

approximately 25 percent to $43.5 million, compared to the base case value of $57.8 

million in the year leading up to the proposed energy conservation standards. The net 

effect of the changes at TSL 7 is an increase in product conversion costs to $20 million 

because of additional redesigns and testing and an increase in capital conversion costs to 

$22 million because of equipment and tooling purchases.

At TSL 7, the shipment-weighted average MPC increases 23 percent over the 

base case MPC. Under the flat markup scenario, the significant revenue increase from 

280
TSL 6 to TSL 7 yields greater positive impacts at TSL 7 despite the large increase in 

conversion costs. Under the ‘preservation of operating profit’ markup scenario, impacts 

are more negative because of the lower average markup of 1.53 and increase in 

conversion costs to $42 million at TSL 7.

At TSL 8, DOE estimates impacts on INPV to range from $106.3 million to -

$107.8 million, or a change in INPV of 17.3 percent to -19.8 percent. At this proposed 

level, industry free cash flow under the low shipment scenario is estimated to decrease by 

approximately 75 percent to $14.9 million, compared to the base case value of $58.6 

million in the year leading up to the proposed energy conservation standards. Under the 

high shipment scenario, industry free cash flow is estimated to decrease by approximately 

76 percent to $14.1 million, compared to the base case value of $57.8 million in the year 

leading up to the proposed energy conservation standards. At TSL 8, manufacturers must 

use max-tech level ballasts for the 70 W, 150 W, 250 W, 400 W, and 1000 W equipment 

classes, driving product and capital conversion costs of $57 million and $69 million, 

respectively.

At TSL 8, the shipment-weighted average MPC increases 57 percent over the 

base case MPC. Under the flat markup scenario, impacts are , resulting in significantly 

more positive compared to TSL 7 because the significant increase in revenue outweighs 

the very large increase in conversion costs of $126 million at TSL 8. Under the 

‘preservation of operating profit’ markup scenario, the significant increase in conversion 

costs cause much more severe impacts on INPV because manufacturers cannot fully pass 

281
on increased costs, as evidenced by the lower average markup of 1.48negative INPV 

impacts at TSL 5 compared to TSL 4.

b. Impacts on Employment

DOE quantitatively assessed the impacts of potential new and amended energy 

conservation standards on direct employment. DOE used the GRIM to estimate the 

domestic labor expenditures and number of domestic production workers in the base case 

and at each TSL from 20112013 to 20442045. DOE used statistical data from the most 

recent U.S. Census Bureau’s 2009 Annual Survey of Manufacturers (ASM), the results of 

the engineering analysis, and interviews with manufacturers to determine the inputs 

necessary to calculate industry-wide labor expenditures and domestic employment levels. 

Labor expenditures involved with the manufacture of the product are a function of the 

labor intensity of the product, the sales volume, and an assumption that wages remain 

fixed in real terms over time.

In the GRIM, DOE used the labor content of each product and the manufacturing 

production costs to estimate the annual labor expenditures in the industry. DOE used 

Census data and interviews with manufacturers to estimate the portion of the total labor 

expenditures that is attributable to domestic labor.

The production worker estimates in this section cover only workers up to the linesupervisor level who are directly involved in fabricating and assembling a product within 

an OEM facility. Workers performing services that are closely associated with production 

282
operations, such as material handing with a forklift, are also included as production labor. 

DOE’s estimates account for only production workers who manufacture the specific 

products covered by this rulemaking. For example, a worker on a fluorescent lamp ballast 

line would not be included with the estimate of the number of metal halide ballast or 

fixture workers.

The employment impacts shown in the tables below represent the potential 

production employment that could result following new and amended energy 

conservation standards. The upper bound of the results estimates the maximum change in 

the number of production workers that could occur after compliance with new and 

amended energy conservation standards is required when assuming that manufacturers 

would continue to produce the same scope of covered productsequipment in the same 

production facilities. It also assumes that domestic production does not shift to lowerlabor-cost countries. Because there is a real risk of manufacturers evaluating sourcing 

decisions in response to new and amended energy conservation standards, the lower 

bound of the employment results includes the estimated total number of U.S. production 

workers in the industry who could lose their jobs if all existing production were moved 

outside of the U.S. While the results present a range of employment impacts following 

2016, the compliance date of new and amended energy conservation standards, the 

discussionsections below also includes ainclude qualitative discussiondiscussions of the 

likelihood of negative employment impacts at the various TSLs. Finally, the employment 

impacts shown are independent of the employment impacts from the broader U.S. 

economy, which are documented in chapter 14 of the NOPR TSD.

283
Employment Impacts for Metal Halide Ballasts

Based on 2009 ASM data and interviews with manufacturers, DOE estimates that 

less than 5040 domestic production workers would be involved in manufacturing metal 

halide ballasts in 2015.2016, as the vast majority of metal halide ballasts are 

manufactured abroad. DOE’s view is that manufacturers could face moderate positive 

impacts on domestic employment levels because increasing equipment costs at each TSL 

would result in higher labor expenditures per unit, causing manufacturers to hire more 

workers to meet demand for metal halide ballasts, assuming that production remains in 

domestic facilities. Many manufacturers, however, do not expect a significant change in 

total employment at their facilities. Although manufacturers are concerned that higher 

prices for metal halide ballasts will drive consumerscustomers to alternate technologies, 

most manufacturers offer these alternate technologies and can shift their employees from 

metal halide ballast production to production of other technologies in their facilities. 

Most manufacturers believe that domestic employment will only be significantly 

adversely affected if consumerscustomers shift to foreign imports, causing the total 

lighting market share of the major domestic manufacturers to decrease.

Employment Impacts for Metal Halide Lamp Fixtures

Using 2009 ASM data and interviews with manufacturers, DOE estimates that 

approximately 60 percent of the metal halide lamp fixtures sold in the United States are 

manufactured domestically. With this assumption, DOE estimates that, in the absence of 

new and amended energy conservation standards, there would be between 515519 and 

284
519525 domestic production workers involved in manufacturing metal halide lamp 

fixtures in 20152016. The tables below show the range of the impacts of potential new 

and amended energy conservation standards on U.S. production workers in the metal 

halide lamp fixture industry.

Table VI.31 Potential Changes in the Total Number of Domestic Metal Halide Lamp 

Fixture Production Workers in 20152016 (Flat Markup and High-Shipment 

Scenario)

Base 

Case Trial Standard Level

1 2 3 4 5 6 7 8

Total Number of Domestic 

Production Workers in 

20152016

(without changes in 

production locations)

515525 536588 550626 544625 545630 553684

5

7

7

5

9

3

6

7

2

Potential Changes in 

Domestic Production 

Workers in 20152016*

-

21 -

(51563 

- (525)

35 -

(51510

1 -

(525)

29 -

(51510

0 -

(525)

30 -

(51510

5 -

(525)

38 -

(51515

9 -

(525)

6

2

-

(

5

1

5

)

7

8

-

(

5

1

5

)

1

5

7

-

(

5

1

5

) * DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers

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Table VI.32 Potential Changes in the Total Number of Domestic Metal Halide Lamp 

Fixture Production Workers in 20152016 (Preservation of Operating Profit Markup 

and Low-Shipment Scenario)

Base 

Case Trial Standard Level

1 2 3 4 5 6 7 8

Total Number of Domestic 

Production Workers in 

20152016

(without changes in 

production locations)

519 538581 549619 544618 545623 554676 

5

7

3

5

8

7

6

5

7

Potential Changes in 

Domestic Production 

Workers in 20152016*

- 1962 -

(519)

30100 -

(519)

2599 -

(519)

26104 -

(519)

35157 -

(519)

5

4

-

(

5

1

9

)

6

8

-

(

5

1

9

)

1

3

8

-

(

5

1

9

) * DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

At the upper end of the range, all examined TSLs show slight to moderate 

positive impacts on domestic employment levels. The increasing equipment cost at each 

higher TSL would result in higher labor expenditures per unit, causing manufacturers to 

hire more workers to meet demand levels of metal halide fixtures, assuming that 

production remains in domestic facilities. Many manufacturers, however, do not expect a 

significant change in total employment at their facilities. Although manufacturers are 

concerned that higher prices for metal halide lamp fixtures will drive 

consumerscustomers to alternate technologies, most manufacturers offer these alternate 

technologies and can shift their employees from metal halide lamp fixture production to 

production of other technologies in their facilities. As with ballast manufacturers, most 

fixture manufacturers believe that domestic employment will only be significantly 

adversely affected if consumerscustomers shift to foreign imports, causing the total 

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286
lighting market share of the major domestic manufacturers to decrease. Because of the 

potentially high cost of shipping fixtures from overseas, many manufacturers believe that 

this shift is unlikely to occur. This is particularly true for the significant portion of the 

market served by small manufacturers, for whom the per-unit shipping costs of sourcing 

products would be even greater because of the lower volumes that they sell.

Based on the above, DOE does not expect the proposed energy conservation 

standards for metal halide lamp fixtures, at TSL 3, to have a significant negative impact 

on direct domestic employment levels. DOE notes that domestic employment levels 

could be negatively affected in the event that small fixture businesses choose to exit the 

market due to standards. However, discussions with small manufacturers indicated that 

most small businesses will be able to adapt to new and amended regulations. The impacts 

on small businesses are discussed in section VII.B.

c. Impacts on Manufacturing Capacity

Both ballast and fixture manufacturers stated that they do not anticipate any 

capacity constraints at efficiency levels that can be met with magnetic ballasts. If the 

production of higher , which are the efficiency levels being proposed for eight of the 10 

equipment classes in today’s NOPR, the two exceptions are the 150W indoor and outdoor 

equipment classes. If the production of higher-efficiency magnetic ballasts decreases the 

throughput on production lines, manufacturers stated that they would be able to add shifts 

on existing lines and maintain capacity.

Comment [AGA21]: Revised at the request of 

OIRA.

Comment [AGA22]: Revised at the request of 

OIRA.

Comment [AGA23]: Revised at the request of 

OIRA.

287
At efficiency levels that require electronic ballasts, however, manufacturers are 

concerned about the current worldwide shortage of electrical components. The 

components most affected by this shortage are high-efficiency parts, for which demand 

would increase even further following new and amended energy conservation standards. 

The increased demand could exacerbate the component shortage, thereby impacting 

manufacturing capacity in the near term, according to manufacturers. The only equipment

classes requiring electronic ballasts that are being proposed in today’s NOPR are the 

150W indoor and outdoor equipment classes. DOE does not anticipate a significant 

increase in demand for electric components due to today’s proposed energy conservation 

standards. While DOE recognizes that the premium component shortage is currently a 

significant issue for manufacturers, DOE views it as a relatively short-term phenomenon 

to which component suppliers will ultimately adjust. According to several manufacturers, 

suppliers have the ability to ramp up production to meet ballast component demand by 

the compliance date of potential new standards, but those suppliers have hesitated to 

invest in additional capacity due to economic uncertainty and skepticism about the 

sustainability of demand. The state of the macroeconomic environment through 

20152016 will likely affect the duration of the premium component shortage. Potential 

mandatory standards, however, could create more certainty for suppliers about the 

eventual demand for these components. Additionally, the premium components at issue 

are not new technologies; rather, they have simply not historically been demanded in 

large quantities by ballast manufacturers.

Comment [AGA24]: Revised at the request of 

OIRA.

Comment [AGA25]: Revised at the request of 

OIRA.

Comment [AGA26]: Revised at the request of 

OIRA.

288
d. Impacts on Sub-GroupsSubgroups of Manufacturers

Using average cost assumptions to develop an industry cash-flow estimate may 

not be adequate for assessing differential impacts among manufacturer subgroups. Small 

manufacturers, niche equipment manufacturers, and manufacturers exhibiting cost 

structures substantially different from the industry average could be affected 

disproportionately. While DOE analyzed the impacts to small businesses in section 

VII.B, however, DOE and did not identify any other adversely impacted subgroups for 

metal halide ballasts or fixtures for this rulemaking based on the results of the industry 

characterization.

e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of recent or impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 

manufacturer can strain profits and lead companies to abandon product lines or markets 

with lower expected future returns than competing products. For these reasons, DOE 

conducts an analysis of cumulative regulatory burden as part of its rulemakings 

pertaining to appliance efficiency.

289
During previous stages of this rulemaking, DOE identified a number of 

requirements, in addition to new and amended energy conservation standards for metal 

halide lamp fixtures, that manufacturers of these products will face for products and 

equipment they manufacture within approximately 3 years prior to and 3 years after the 

anticipated compliance date of the new and amended standards. The following section 

briefly addresses comments DOE received with respect to cumulative regulatory burden 

and summarizes other key related concerns that manufacturers raised during interviews.

Several manufacturers expressed concern about the overall volume of DOE 

energy conservation standards with which they must comply. Most metal halide lamp 

fixture manufacturers also make a full range of lighting products and share engineering 

and other resources with these other internal manufacturing divisions for different 

products (including certification testing for regulatory compliance). Manufacturers 

worried that today’s proposed standards could punish compliant manufacturers while 

potentially driving others to noncompliance, creating an unfair playing field. NEMA 

referenced general service fluorescent lamps, incandescent reflector lamps, fluorescent 

lamp ballasts, and high-intensity discharge lamps as other products subject to DOE 

regulation. (NEMA, No. 34 at p. 17) NEMA and Philips also raised concerns about other 

regulatory actions, including ENERGY STAR standards utilizing separate metrics from 

DOE’s standards and potential outdoor lighting legislation. (NEMA, Public Meeting 

Transcript, No. 33 at p. 16; Philips, Public Meeting Transcript, No. 33 at p. 132; NEMA, 

No. 34 at p. 17) Other regulations noted by manufacturers during interviews include 

California Title 20 and Title 24.

290
DOE discusses these and other requirements in chapter 13 of the NOPR TSD. 

DOE takes into account the cost of compliance with other published Federal energy 

conservation standards in weighing the benefits and burdens of today’s proposed 

rulemaking. DOE does not describe the quantitative impacts of standards that have not 

yet been finalized because any impacts would be speculative. DOE also notes that certain 

standards, such as ENERGY STAR, are optional for manufacturers.

3. National Impact Analysis

a. Significance of Energy Savings

To estimate the For each TSL, DOE projected energy savings through 

2044 attributable to potential standards for metal halide lamp fixtures, DOE compared

purchased in the 30-year period that begins in the year 2016, ending in the year 2045. The 

savings are measured over the entire lifetime of equipment purchased in the 30-year 

period. DOE quantified the energy use of these equipment under the savings attributable 

to each TSL as the difference in energy consumption between each standards case and the 

base case to their anticipated energy use under each TSL.. Table VI.33 presents DOE’s 

forecasts of the nationalestimated primary energy savings for each TSL for the low- and 

high-shipment scenarios, which represent the minimum and maximum energy savings 

resulting from all the scenarios analyzed. Table VI.34 presents the estimated FFC energy 

savings for each considered TSL. Chapter 11 of the NOPR TSD describes these estimates 

in more detail.

291
Table VI.33 Summary of Cumulative National Primary Energy Savings for Metal 

Halide Lamp Fixtures (2015–2044)Fixture Trial Standard Levels for Units Sold in 

2016–2045

Trial 

Standard 

Level

Equipment Class

National Primary Energy Savings

quads

Low-Shipments, 

Roll-Up 

Scenario

HighShipments, Rollup Scenario

1

70 W 0.01 0.01

150 W 0.0203 0.0205

250 W 0.02 0.03

400 W 0.10 0.13

1000 W 0.1227 0.1537

Total 0.1544 0.1858

2

70 W 0.0205 0.0306

150 W 0.0306 0.0309

250 W 0.04 0.06

400 W 0.20 0.27

1000 W 0.1431 0.1642

Total 0.1966 0.2289

3

70 W 0.0205 0.0306

150 W 0.0819 0.0926

250 W 0.04 0.06

400 W 0.20 0.27

1000 W 0.1431 0.1642

Total 0.2479 0.281.06

4

70 W 0.0215 0.0319

150 W 0.0819 0.0926

250 W 0 0

400 W 0 0

1000 W 0.14 0.16

Total 0.24 0.28

5 70 W 0.07 0.09

150 W 0.08 0.10

250 W 0 0

400 W 0 0

1000 W 0.14 0.16

Total 0.29 0.35

6 70 W 0.03 0.03

150 W 0.07 0.09

250 W 0.04 0.0506

400 W 0.0720 0.0827

1000 W 0.1431 0.1642

Total 0.3589 0.411.20

75

70 W 0.0818 0.1024

150 W 0.0819 0.1026

250 W 0.0435 0.0549

400 W 0.0777 01.08

1000 W 0.1431 0.1642

Total 0.411.80 02.49

292
8 70 W 0.09 0.10

150 W 0.08 0.10

250 W 0.15 0.19

400 W 0.33 0.40

1000 W 0.14 0.16

Total 0.79 0.95

Table VI.34 Cumulative National Full-Fuel-Cycle Energy Savings for Metal Halide 

Lamp Fixture Trial Standard Levels for Units Sold in 2016–2045

Trial 

Standard 

Level

Equipment Class

National FFC Energy Savings

quads

Low-Shipments 

Scenario

High-Shipments 

Scenario

1

70 W 0.01 0.01

150 W 0.03 0.05

250 W 0.02 0.03

400 W 0.10 0.13

1000 W 0.28 0.38

Total 0.45 0.59

2

70 W 0.05 0.06

150 W 0.06 0.09

250 W 0.04 0.06

400 W 0.21 0.28

1000 W 0.31 0.42

Total 0.67 0.90

3

70 W 0.05 0.06

150 W 0.19 0.27

250 W 0.04 0.06

400 W 0.21 0.28

1000 W 0.31 0.42

Total 0.80 1.08

4

70 W 0.16 0.20

150 W 0.19 0.27

250 W 0.04 0.06

400 W 0.21 0.28

1000 W 0.31 0.42

Total 0.91 1.22

5

70 W 0.19 0.24

150 W 0.19 0.27

250 W 0.36 0.50

400 W 0.78 1.10

1000 W 0.31 0.42

Total 1.83 2.53

Circular A-4 requires agencies to present analytical results, including separate 

schedules of the monetized benefits and costs that show the type and timing of benefits 

and costs. Circular A-4 also directs agencies to consider the variability of key elements 

293
underlying the estimates of benefits and costs. For this rulemaking, DOE undertook a 

sensitivity analysis using nine rather than 30 years of fixture shipments. The choice of a 

9-year period is a proxy for the timeline in EPCA for the review of certain energy 

conservation standards and potential revision of and compliance with such revised 

standards.68 We would note that the review timeframe established in EPCA generally 

does not overlap with the equipment lifetime, equipment manufacturing cycles or other 

factors specific to metal halide lamp fixtures. Thus, this information is presented for 

informational purposes only and is not indicative of any change in DOE’s analytical 

methodology. The NES results based on a 9-year analytical period are presented in Table 

VI.35. The impacts are counted over the lifetime of fixtures purchased in 2016–2024.

68 EPCA requires DOE to review its standards at least once every 6 years, and requires, for certain 

products, a 3 year period after any new standard is promulgated before compliance is required, except that 

in no case may any new standards be required within 6 years of the compliance date of the previous 

standards. While adding a 6-year review to the 3-year compliance period adds up to 9 years, DOE notes 

that it may undertake reviews at any time within the 6 year period and that the 3-year compliance date may 

yield to the 6-year backstop. 

Comment [AGA27]: Revised at the request of 

OIRA.

Comment [AGA28]: Revised at the request of 

OIRA.

294

 
Table VI.35 Cumulative National Primary Energy Savings for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2016–2024

Trial 

Standard 

Level

Equipment Class National Primary Energy Savings

quads

Low-Shipments 

Scenario

High-Shipments 

Scenario

1

70 W 0.01 0.01

150 W 0.02 0.02

250 W 0.01 0.01

400 W 0.06 0.07

1000 W 0.15 0.16

Total 0.25 0.28

2

70 W 0.03 0.03

150 W 0.03 0.03

250 W 0.02 0.03

400 W 0.11 0.12

1000 W 0.16 0.18

Total 0.36 0.40

3

70 W 0.03 0.03

150 W 0.09 0.10

250 W 0.02 0.03

400 W 0.11 0.12

1000 W 0.16 0.18

Total 0.42 0.46

4

70 W 0.09 0.10

150 W 0.09 0.10

250 W 0.02 0.03

400 W 0.11 0.12

1000 W 0.16 0.18

Total 0.48 0.53

5

70 W 0.11 0.12

150 W 0.09 0.10

250 W 0.17 0.19

400 W 0.36 0.40

1000 W 0.16 0.18

Total 0.89 0.99

b. Net Present Value of ConsumerCustomer Costs and Benefits

DOE estimated the cumulative NPV to the nation of the total costs and savings for 

consumerscustomers that would result from particular standard levelsthe TSLs 

considered for metal halide lamp fixtures. In accordance with the OMB’s guidelines on 

295
regulatory analysis (OMB Circular A-4, section E, September 17, 2003),,

69 DOE 

calculated the NPV using both a 7-percent and a 3-percent real discount rate. The 7-

percent rate is an estimate of the average before-tax rate of return on private capital in the 

U.S. economy, and reflects the returns on real estate and small business capital as well as 

corporate capital. DOE used This discount rate to approximateapproximates the 

opportunity cost of capital in the private sector, because recent (OMB analysis has found 

the average rate of return on capital to be near this rate. In addition, DOE used). The 3-

percent rate to capturereflects the potential effects of standards on private consumption 

(e.g., through higher prices for equipmentproducts and the purchase of reduced 

amountspurchases of energy). This rate represents the rate at which society discounts 

future consumption flows to their present value. This rateIt can be approximated by the 

real rate of return on long-term government debt (i.e., yield on United States Treasury 

notes minus annual rate of change in the Consumer Price Index), which has averaged 

about 3 percent on a pre-tax basis for the lastpast 30 years.

Table VI.36 shows the consumercustomer NPV results for each TSL DOE 

considered for metal halide lamp fixtures, using both a 7-percent and a 3-percent discount 

rate. Similar torates. In each case, the results presented for NES, this table 

presentsimpacts cover the resultslifetime of the two scenarios that represent the 

maximum and minimum NPV resulting from all the scenarios analyzedequipment 

purchased in 2016–2045. See chapter 11 of the NOPR TSD for more detailed NPV 

results.

69 OMB Circular A-4, section E (Sept. 17, 2003). Available at: 

www.whitehouse.gov/omb/circulars_a004_a-4.

296

 
Table VI.36 Summary of Cumulative Net Present Value of Customer Benefits for 

Metal Halide Lamp Fixtures (2015–2044)Fixture Trial Standard Levels for Units 

Sold in 2016–2045

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 20102012$

Low-Shipments, Roll-Up

Scenario

High-Shipments, Roll-up

Scenario

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1

70 W 0.04039 0.07068 0.04042 0.08073

150 W 0.02036 0.07094 0.03044 0.09124

250 W 0.00009 0.00065 0.00012 0.00084

400 W 0.00009 0.00109 0.00014 0.00140

1000 W 0.45596 1.04292 0.53728 1.29680

Total 0.51688 1.18629 0.60840 1.462.100

2

70 W 0.04054 0.11124 0.04060 0.12144

150 W 0.05083 0.16205 0.07104 0.21274

250 W 0.00028 0.00146 0.00038 0.00194

400 W 0.00108 0.00383 0.00140 0.00507

1000 W 0.48636 1.11393 0.57779 1.39815

Total 0.57909 1.382.251 0.681.121 1.722.933

3

70 W 0.04054 0.11124 0.04060 0.12144

150 W 0.16125 0.44408 0.20162 0.57558

250 W 0.00028 0.00146 0.00038 0.00194

400 W 0.00108 0.00383 0.00140 0.00507

1000 W 0.48636 1.11393 0.57779 1.39815

Total 0.68951 1.662.454 0.811.179 2.083.217

4

70 W 0.04029 0.11330 0.04034 0.13406

150 W 0.15125 0.42408 0.18162 0.54558

250 W 0.00028 0.00146 0.00038 0.00194

400 W 0.00108 0.00383 0.00140 0.00507

1000 W 0.48636 1.11393 0.57779 1.39815

Total 0.67927 1.642.660 0.791.153 2.063.479

5

70 W -0.001015 0.14278 -0.0001018 0.16344

150 W 0.12125 0.37408 0.14162 0.48558

250 W -0.00055 0.00287 -0.00050 0.00430

400 W -0.00344 0.00134 -0.00394 0.00256

1000 W 0.48636 1.11393 0.57779 1.39815

Total 0.60347 1.622.500 0.71478 2.033.401

6

70 W 0.04 0.11 0.04 0.13

150 W 0.16 0.44 0.20 0.57

250 W 0.03 0.12 0.04 0.16

400 W 0.02 0.19 0.02 0.25

1000 W 0.48 1.11 0.57 1.39

Total 0.73 1.97 0.87 2.50

7

70 W -0.04 0.10 -0.04 0.11

150 W 0.12 0.37 0.14 0.48

250 W 0.03 0.12 0.04 0.16

400 W 0.02 0.19 0.02 0.25

1000 W 0.48 1.11 0.57 1.39

Total 0.61 1.89 0.73 2.39

297
8

70 W -0.05 0.08 -0.06 0.09

150 W 0.12 0.37 0.15 0.48

250 W -0.04 0.24 -0.04 0.32

400 W -0.39 0.003 -0.45 0.05

1000 W 0.48 1.11 0.56 1.39

Total 0.12 1.80 0.16 2.33

The NPV results based on the afore-mentioned 9-year analytical period are 

presented in Table VI.37. The impacts are counted over the lifetime of fixtures purchased 

in 2016–2024. As mentioned previously, this information is presented for informational 

purposes only and is not indicative of any change in DOE’s analytical methodology or 

decision criteria.

Table VI.37 Net Present Value of Customer Benefits for Metal Halide Lamp Fixture 

Trial Standard Levels for Units Sold in 2016–2024 

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 2012$

Low-Shipments Scenario High-Shipments Scenario

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1

70 W 0.039 0.068 0.042 0.073

150 W 0.023 0.053 0.025 0.058

250 W 0.004 0.037 0.004 0.041

400 W 0.001 0.062 0.001 0.069

1000 W 0.419 0.779 0.457 0.856

Total 0.485 0.999 0.530 1.097

2

70 W 0.047 0.099 0.051 0.107

150 W 0.053 0.113 0.059 0.124

250 W 0.013 0.078 0.015 0.086

400 W 0.061 0.206 0.068 0.227

1000 W 0.445 0.834 0.486 0.916

Total 0.620 1.329 0.678 1.461

3

70 W 0.047 0.099 0.051 0.107

150 W 0.075 0.209 0.082 0.231

250 W 0.013 0.078 0.015 0.086

400 W 0.061 0.206 0.068 0.227

1000 W 0.445 0.834 0.486 0.916

Total 0.642 1.426 0.702 1.567

4

70 W 0.024 0.216 0.025 0.236

150 W 0.075 0.209 0.082 0.231

250 W 0.013 0.078 0.015 0.086

400 W 0.061 0.206 0.068 0.227

1000 W 0.445 0.834 0.486 0.916

Total 0.618 1.542 0.676 1.696

298
5

70 W -0.010 0.178 -0.012 0.194

150 W 0.075 0.209 0.082 0.231

250 W -0.063 0.099 -0.068 0.110

400 W -0.280 -0.027 -0.305 -0.027

1000 W 0.445 0.834 0.486 0.916

Total 0.166 1.292 0.183 1.424

Finally, DOE evaluated the NPV results for both indoor and outdoor fixtures for 

each equipment class. Table VI.38 gives the NPV associated with each equipment class 

broken down into indoor and outdoor fixture environments.

Table VI.38 Net Present Value of Customer Benefits for Metal Halide Lamp Fixture 

Trial Standard Levels for Units Sold in 2016–2045 (Low Shipments, by Fixture 

Environment)

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 2012$

Indoor Fixtures Outdoor Fixtures

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1

70 W 0.000 0.000 0.039 0.068

150 W 0.011 0.028 0.025 0.066

250 W 0.005 0.024 0.004 0.041

400 W 0.007 0.037 0.002 0.072

1000 W 0.183 0.378 0.413 0.914

Total 0.205 0.468 0.483 1.161

2

70 W 0.000 0.000 0.054 0.124

150 W 0.025 0.059 0.058 0.146

250 W 0.012 0.048 0.017 0.098

400 W 0.036 0.115 0.072 0.268

1000 W 0.197 0.411 0.439 0.981

Total 0.269 0.633 0.640 1.618

3

70 W 0.000 0.000 0.054 0.124

150 W 0.019 0.012 0.106 0.396

250 W 0.012 0.048 0.017 0.098

400 W 0.036 0.115 0.072 0.268

1000 W 0.197 0.411 0.439 0.981

Total 0.263 0.586 0.688 1.868

4

70 W 0.000 0.000 0.029 0.330

150 W 0.019 0.012 0.106 0.396

250 W 0.012 0.048 0.017 0.098

400 W 0.036 0.115 0.072 0.268

1000 W 0.197 0.411 0.439 0.981

Total 0.263 0.586 0.664 2.074

5

70 W -0.012 -0.018 -0.003 0.296

150 W 0.019 0.012 0.106 0.396

250 W -0.042 -0.120 -0.012 0.407

400 W -0.148 -0.284 -0.196 0.418

1000 W 0.197 0.411 0.439 0.981

Total 0.013 0.002 0.334 2.499

299
c. Impacts on Employment

DOE estimated the indirect employment impacts of potential standards on the 

economy in general, assuming that energy conservation standards for metal halide lamp 

fixtures will reduce energy bills for fixture users and the resulting net savings towill be 

redirected to other forms of economic activity. DOE used an input/output model of the 

U.S. economy to estimate these effects, including the demand for labor as described in 

section V.H.

The input/output model results suggest that today’s proposed standards are likely 

to increase the net labor demand. The gains, however, would most likely be small relative 

to total national employment, and neither the BLS data nor the input/output model DOE 

uses includes the quality or wage level of the jobs. As shown in Table VI.39, DOE 

estimates that net indirect employment impacts from proposed fixture standards are small 

relative to the national economy.

Table VI.39 Net Change in Jobs from Indirect Employment Effects Under Fixture 

TSLs

Analysis 

Period 

Year

Trial 

Standard 

Level

Net National Change in Jobs

thousands

Low Shipments 

Scenario, Roll-up

High Shipments 

Scenario, Roll-up

20172020 1 0.3410 0.358

2 0.42-30 0.44-36

3 0.5176 0.5473

4 0.52170 0.54168

5 0.61352 0.64346

6 0.08 -0.01

7 0.19 0.11

8 -3.12 -3.73

20202044 1 0.30376 0.45392

2 0.40511 0.59530

Merged Cells

Merged Cells

300
3 0.51791 0.77827

4 0.51 0.78

5 0.62 0.92

64 0.821,091 1.20,142

7 0.95 1.39

85 1.772,336 2.41,445

4. Impact on Utility or Performance of ProductsEquipment

As presented in section V.B of this notice, DOE concluded that none of the TSLs 

considered in this noticethat were analyzed would reduce the utility or performance of the 

products under consideration in this rulemaking. Furthermore, manufacturers of these 

products currently offer ballasts that meet or exceed the proposed standards. (42 U.S.C. 

6295(o)(2)(B)(i)(IV))

5. Impact of Any Lessening of Competition

DOE also considered any lessening of competition that is likely to result from 

new and amended energy conservation standards. The Attorney General determines the 

impact, if any, of any lessening of competition likely to result from a proposed standard, 

and transmits such determination to the Secretary, together with an analysis of the nature 

and extent of such impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))

To assist the Attorney General in making such determination, DOE has provided 

DOJ with copies of this notice and the TSD for review. DOE will consider DOJ’s 

comments on the proposed rule in preparing the final rule, and DOE will publish and 

respond to DOJ’s comments in that document.

Merged Cells

Merged Cells

301
6. Need of the Nation to Conserve Energy

An improvement in the energy efficiency of the equipmentproducts subject to 

today’s rule is likely to improve the security of the nation’s energy system by reducing 

overall demand for energy. Reduced electricity demand may also improve the reliability 

of the electricity system. As a measure of this reduced demand, presents the estimated 

reductionReductions in national electric generating capacity in 2044estimated for the 

TSLs that DOEeach considered in this rulemakingTSL are reported in chapter 14 of the 

NOPR TSD.

Table . Reduction in Electricity Generating Capacity in 2044 Under Fixture TSLs 

Trial Standard Level

Reduction in Electricity Generating 

Capacity

Gigawatts

Low Shipments 

Scenario, Roll-up

High Shipments 

Scenario, Roll-up

1 -0.15 -0.20

2 -0.20 -0.27

3 -0.25 -0.34

4 -0.25 -0.34

5 -0.31 -0.42

6 -0.37 -0.50

7 -0.44 -0.60

8 -0.86 -1.16

Energy savings from new and amended energy conservation standards for fixtures 

could also produce environmental benefits in the form of reduced emissions of air 

pollutants and GHGs associated with electricity production. Table VI.40 and Table VI.41

provide DOE’s estimate of cumulative CO2, NOX, and Hg emissions reductions projected 

to result from the TSLs considered in this rulemaking, for the low and high shipment 

scenarios, respectively. The tables include both power sector emissions and upstream 

emissions. The upstream emissions were calculated using the multipliers discussed in 

302
section V.L.. DOE reports annual CO2, NOX, and Hg emissions reductions for each TSL 

in the environmental assessment ofemissions analysis in chapter 16 the NOPR TSD.

Table VI.40 Summary of Cumulative Emissions Reduction Estimated for Fixture 

TSLs (cumulativePotential Standards for 2015 through 2044Metal Halide Lamp 

Fixtures (Low Shipments Scenario)

Trial Standard Level

Trial Standard LevelCumulative Reduction in Emissions 

(2015 through 2044)

Low 

Shipment

s 

Scenario, 

Roll-up1

Hig

h 

Shi

pm

ent

s 

Sce

nar

io, 

Rol

lup

2 3 4 5

Power Sector Emissions*

CO2

Mt CO2 

(million 

metric 

tons)

NOX

kt25.90

Hg

t38.

85

CO2

Mt46.04

NOX

kt52.32

Hg

t104.72

Inserted Cells

Inserted Cells

Inserted Cells

Deleted Cells

303
1 NOX (thousand 

tons)

181

7.3

9

6 0.2

6.2

2

2131.20 435.41 0.2371.71

2 Hg (tons) 240.06 80.

09 0.3411 280.12

6 0.3024

3 N2O (thousand 

tons) 0.4830 90.

72

0.4

286

35 7

0.3898 2.00

 CH4 (thousand tons) 2.90 4.3

7 5.18 5.89 11.86

4 SO2 (thousand tons)

3036.23

105

4.3

7

064.42 3573.25

714

6.5

3

0.3

9

Upstream Emissions

 CO2 (million metric 

tons) 1.40 2.1

1 2.50 2.84 5.70

 NOX (thousand tons) 19.27 28.

98 34.37 39.08 78.45

5 Hg (tons)

370.001

120

.00

1

0.53001

440

.00

2

9

0.48003

6 N2O (thousand 

tons) 440.01 140

.02 0.6203 510.03

11

0.5606

 CH4 (thousand tons) 116.89 175

.81 208.58 237.15 476.16

7 SO2 (thousand tons) 530

.30

17 0.7

445 620.54 0.6113 0.681.22

Total Emissions

 CO2 (million metric 

tons) 27.30 40.

96 48.53 55.16 110.43

 NOX (thousand tons) 36.66 55.

20 65.57 74.48 150.16

 Hg (tons) 0.06 0.0

9 0.11 0.12 0.24

8 N2O (thousand 

tons) 1020.49 320

.74

1.4

30.

89

120 25

1.3201 2.06

 CH4 (thousand tons) 119.79 180

.18 213.76 243.04 488.01

 SO2 (thousand tons) 36.53 54.

82 64.95 73.85 147.75

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

304
Table VI.41 Cumulative Emissions Reduction for Potential Standards for Metal 

Halide Lamp Fixtures (High Shipments Scenario)

Trial Standard Level

1 2 3 4 5

Power Sector Emissions*

 CO2 (million metric tons) 33.93 51.48 61.61 69.58 143.59

 NOX (thousand tons) 23.50 35.86 43.14 48.58 101.88

 Hg (tons) 0.08 0.12 0.14 0.16 0.34

 N2O (thousand tons) 0.66 1.01 1.22 1.37 2.90

 CH4 (thousand tons) 3.85 5.87 7.04 7.95 16.50

 SO2 (thousand tons) 47.41 71.94 86.07 97.26 200.46

Upstream Emissions

 CO2 (million metric tons) 1.85 2.81 3.37 3.81 7.88

 NOX (thousand tons) 25.44 38.69 46.36 52.37 108.39

 Hg (tons) 0.001 0.002 0.002 0.002 0.004

 N2O (thousand tons) 0.02 0.03 0.03 0.04 0.08

 CH4 (thousand tons) 154.45 234.93 281.50 317.98 658.29

 SO2 (thousand tons) 0.40 0.60 0.72 0.82 1.69

Total Emissions

 CO2 (million metric tons) 35.78 54.29 64.98 73.39 151.47

 NOX (thousand tons) 48.94 74.55 89.50 100.95 210.26

 Hg (tons) 0.08 0.12 0.15 0.16 0.34

 N2O (thousand tons) 0.68 1.04 1.25 1.41 2.98

 CH4 (thousand tons) 158.30 240.80 288.54 325.92 674.79

 SO2 (thousand tons) 47.80 72.54 86.79 98.08 202.14

As discussed in section V.L, DOE did not report SO2 emissions reductions from 

power plants because there is uncertainty about the effect of energy conservation 

standards on the overall level of SO2 emissions in the United States due to SO2new

emissions caps.standards for power plants under the MATS rule. DOE also did not 

include NOx emissions reductionreductions from power plants in states subject to 

CAIRCAIRR because an energy conservation standard would not affect the overall level 

of NOx emissions in those states due to the emissions caps mandated by CAIR.

As part the analysis for this proposed rule, DOE estimated monetary benefits 

likely to result from the reduced emissions of CO2 and NOx that DOE estimated for each 

of the TSLs considered. As discussed in section V.M.1, DOE used values for the SCC 

305
developed by an interagency process. The interagency group selected four sets of SCC 

values for CO2 emissions reductions resulting from that process (for emissionsuse in 

2010, expressed in 2010$) are $4.9/ton (regulatory analyses. Three sets are based on the 

average value from a distribution that uses a 5-percentSCC from three integrated 

assessment models, at discount rate), $22.3/ton (the average value from a distribution that 

uses a 3-rates of 2.5 percent, 3 percent discount rate), $36.5/ton (the average value from a 

distribution that uses a 2.5-, and 5 percent discount rate), and $67.6/ton (. The fourth set, 

which represents the 95th-percentile value from a distribution that usesSCC estimate 

across all three models at a 3-percent discount rate)., is included to represent higher-thanexpected impacts from temperature change further out in the tails of the SCC distribution. 

The four SCC values for CO2 emissions reductions in 2015, expressed in 2012$, are 

$12.9/ton, $40.8/ton, $62.2/ton, and $117.0/ton. These values correspond to the values of 

emission reductions in 2010; the values for later years are higher due to increasing 

damagesemissions-related costs as the magnitude of projected climate change increases. 

For each TSL, DOE calculated the global present values of CO2 emissions reductions, 

using the same discount rate as was used in the studies upon which the dollar-per-ton 

values are based. DOE calculated domestic values as a range from 7 percent to 23 percent 

of the global values.

Table VI.42 and Table VI.43 present the global value of CO2 emissions reductions 

at each TSL for the low and high shipment scenarios, respectively. DOE calculated 

domestic values as a range from 7 percent to 23 percent of the global values, and these 

results are presented in chapter 17 of the NOPR TSD.

306
Table VI.42 Global Present Value of CO2 Emissions Reduction for Potential 

Standards for Metal Halide Lamp Fixtures (Low Shipments Scenario) 

TSL

SCC Scenario*

5% discount 

rate, average

3% discount rate, 

average

2.5% discount 

rate, average

3% discount rate, 

95th percentile

million 2012$

Power Sector Emissions

1 180.6 824.4 1,309.4 2,521.8

2 268.6 1,230.7 1,956.1 3,766.3

3 316.6 1,453.6 2,311.6 4,449.4

4 360.3 1,653.5 2,629.2 5,061.5

5 709.1 3,276.7 5,218.2 10,037.1

Upstream Emissions

1 9.6 44.2 70.3 135.5

2 14.3 66.2 105.3 202.8

3 16.9 78.3 124.6 239.9

4 19.3 89.1 141.8 273.0

5 38.0 177.1 282.3 543.0

Total Emissions

1 190.2 868.7 1,379.7 2,657.2

2 283.0 1,296.9 2,061.5 3,969.1

3 333.5 1,531.9 2,436.2 4,689.3

4 379.5 1,742.6 2,771.0 5,334.5

5 747.2 3,453.8 5,500.6 10,580.1

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 

per metric ton (2012$).

Table VI.43 Global Present Value of CO2 Emissions Reduction for Potential 

Standards for Metal Halide Lamp Fixtures (High Shipments Scenario) 

TSL

SCC Scenario*

5% discount 

rate, average

3% discount rate, 

average

2.5% discount 

rate, average

3% discount rate, 

95th percentile

million 2012$

Power Sector Emissions

1 226.5 1,052.4 1,678.3 3,225.1

2 340.4 1,587.8 2,534.4 4,868.3

3 404.3 1,891.8 3,021.8 5,802.1

4 458.2 2,141.2 3,418.9 6,566.6

5 924.3 4,359.1 6,975.4 13,379.6

Upstream Emissions

1 12.2 56.9 90.9 174.7

2 18.3 86.1 137.6 264.4

3 21.8 102.8 164.3 315.5

4 24.7 116.3 185.9 357.1

5 50.1 237.6 380.6 730.0

Total Emissions

1 238.7 1,109.3 1,769.2 3,399.8

2 358.7 1,674.0 2,672.0 5,132.7

3 426.2 1,994.6 3,186.1 6,117.6

4 482.9 2,257.5 3,604.9 6,923.7

5 974.3 4,596.7 7,356.0 14,109.6

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 

per metric ton (2012$).

307
DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the potential 

resulting damages to the world economy continues to evolve rapidly. Thus, any value 

placed in this rulemaking on reducing CO2 emissions is subject to change. DOE, together 

with other Federal agencies, will continue to review various methodologies for estimating 

the monetary value of reductions in CO2 and other GHG emissions. This ongoing review 

will consider the comments on this subject that are part of the public record for this and 

other rulemakings, as well as other methodological assumptions and issues. However, 

consistent with DOE’s legal obligations, and taking into account the uncertainty involved 

with this particular issue, DOE has included in this NOPR the most recent values and 

analyses resulting from the ongoing interagency review process.

DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOx and Hg emissions reductions anticipated to result from 

amended metal halide lamp fixture standards. Estimated monetary benefits for CO2, NOx,

and HgNOx emission reductions are detailed in chapter 1617 of the NOPR TSD.

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the consumercustomer savings calculated for 

each TSL considered in this proposed rulemaking. The dollar-per-ton values that DOE 

used are discussed in section V.M. Table VI.44 shows an example of presents the 

calculation of the combined NPV, including benefits frompresent value of cumulative 

308
NOX emissions reductions for the case ofeach TSL calculated using the average dollarper-ton values and 7-percent and 3 for fixtures. The CO2 values used in the table 

correspond to the four scenarios for the valuation of CO2 emission reductions presented 

in section .-percent discount rates.

309
Table VI.44 Adding Net Present Value of Consumer Savings to Present Value of 

Monetized Benefits from CO2 and NOX Emissions Reductions at TSL 3Reduction

for Potential Standards for Metal Halide Lamp Fixtures (High Shipments Scenario, 

Roll-up) 

Categ

oryTS

L

Present Value

million 2010$Low Shipments Scenario

Discount RateHigh Shipments Scenario

3% Discount 

Rate 7% Discount Rate 3% Discount Rate 7% Discount Rate

Benefi

ts million 2012$

Operating Cost SavingsPower Sector Emissions 1,078 7%

1 2,21424.4 12.3% 30.9 14.7

CO2

Reduc

tion 

Monet

ized 

Value 

(at 

$4.9/

Metric 

Ton)*

2

11036.3 18.1 46.5% 21.8

CO2

Reduc

tion 

Monet

ized 

Value 

(at 

$22.3/

Metric 

Ton)*

3

55042.8 3%21.2 55.4 25.7

CO2

Reduc

tion 

Monet

ized 

Value

(at 

$36.5/

Metric 

Ton)*

4

92748.7 2.5%24.1 62.7 29.1

5 96.3

CO2 Reduction 

Monetized 

Value 

(at 

$67.6/Metric 

Ton)*46.6

1,679

127.3% 57.2

NOx Reduction Monetized Value 

(at $2,537/Ton)*Upstream Emissions

6 7%

1 1027.2 3%13.6 34.1 16.2

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310
Total 

Monet

ary 

Benefi

ts **2

1,63440.5 7%20.0 51.3 24.0

3 2,77547.7 23.4 60.9 28.3%

Costs 4 54.3 26.6 69.0 32.1

Total 

Incre

mental 

Install

ed 

Costs5

372106.9 7%51.4 139.1 63.0

Total Emissions 592 3%

Net 

Benefi

ts/Cos

ts1

51.6 25.9 65.0 30.9

Includ

ing 

CO

2

and 

NO

x

*

*2

76.8 38.1,263 7%97.8 45.8

3 2,18390.6 44.6 116.3% 53.9

* The 

CO2 

values 

repres

ent 

global 

monet

ized 

values 

(in 

2010$

) of 

the 

social 

cost of 

CO

2

emissi

ons in 

2010 

under 

severa

l 

scenar

ios. 

The 

values 

of 

$4.9, 

$22.3, 

103.0 50.8 131.7 61.2

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311
and $436. 5 per 

metric 

ton 

are the 

averag

es of 

SCC 

distrib

utions 

calcul

ated 

using 5-

percen

t, 3-

percen

t, and 

2.5-

percen

t 

discou

nt 

rates, 

respec

tively. 

The 

value 

of 

$67.6/

t 

repres

ents 

the 

95th

percen

tile of 

the 

SCC 

distrib

ution 

calcul

ated 

using 

a 3-

percen

t 

discou

nt 

rate. 

The 

value 

for 

NO

x

(in 

312
2010$

) is the 

averag

e of 

the 

low 

and 

high 

values 

used 

in 

DOE’

s 

analys

is. See 

sectio

n for 

details .

** 

Total 

benefi

ts for 

both 

the 3-

percen

t and 7-

percen

t cases 

are 

derive

d 

using 

the 

SCC 

value 

calcul

ated at 

a 3-

percen

t 

discou

nt 

rate, 

which 

is 

$22.3/

t in 

2010 

(in 

2010$

).5 203.2 98.1 266.4 120.3

313
The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the customer savings calculated for each TSL 

considered in this rulemaking. Table VI.45 and Table VI.46 present the NPV values that 

result from adding the estimates of the potential economic benefits resulting from 

reduced CO2 and NOX emissions in each of four valuation scenarios to the NPV of 

customer savings calculated for each TSL considered in this rulemaking, at both a 7-

percent and a 3-percent discount rate, and for the low and high shipment scenarios, 

respectively. The CO2 values used in the columns of each table correspond to the four 

scenarios for the valuation of CO2 emission reductions discussed above.

314
Table VI.45 Metal Halide Lamp Fixture TSLs: Net Present Value of Customer 

Savings Combined with Net Present Value of Monetized Benefits from CO2 and 

NOX Emissions Reductions (Low Shipments Scenario)

TSL

Customer NPV at 3% Discount Rate added with:

SCC Value of 

$12.9/metric ton 

CO2

* and Low 

Value for NOX

**

SCC Value of 

$40.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$62.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and High 

Value for NOX

**

billion 2012$

1 1.828 2.549 3.060 4.380

2 2.547 3.624 4.389 6.360

3 2.803 4.076 4.981 7.308

4 3.058 4.506 5.534 8.182

5 3.284 6.157 8.204 13.451

TSL

Customer NPV at 7% Discount Rate added with:

SCC Value of 

$12.9/metric ton 

CO2

* and Low 

Value for NOX

**

SCC Value of 

$40.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$62.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and High 

Value for NOX

**

billion 2012$

1 0.883 1.583 2.094 3.393

2 1.199 2.244 3.008 4.947

3 1.293 2.528 3.432 5.722

4 1.315 2.720 3.749 6.354

5 1.112 3.899 5.946 11.106 * These label values represent the global SCC in 2015, in 2012$. The present values have been calculated 

with scenario-consistent discount rates. ** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per 

ton of NOX emissions. High Value corresponds to $4,809 per ton of NOX emissions.

315
Table VI.46 Metal Halide Lamp Fixture TSLs: Net Present Value of Customer 

Savings Combined with Net Present Value of Monetized Benefits from CO2 and 

NOX Emissions Reductions (High Shipments Scenario)

TSL

Customer NPV at 3% Discount Rate added with:

SCC Value of 

$12.9/metric ton 

CO2

* and Low 

Value for NOX

**

SCC Value of 

$40.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$62.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and High 

Value for NOX

**

billion 2012$

1 2.351 3.275 3.935 5.619

2 3.309 4.705 5.703 8.244

3 3.664 5.328 6.520 9.547

4 3.985 5.868 7.215 10.642

5 4.423 8.264 11.023 17.996

TSL

Customer NPV at 7% Discount Rate added with:

SCC Value of 

$12.9/metric ton 

CO2

* and Low 

Value for NOX

**

SCC Value of 

$40.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$62.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and High 

Value for NOX

**

billion 2012$

1 1.085 1.981 2.641 4.297

2 1.488 2.841 3.839 6.337

3 1.614 3.227 4.419 7.395

4 1.647 3.472 4.819 8.188

5 1.474 5.195 7.955 14.807 * These label values represent the global SCC in 2015, in 2012$. The present values have been calculated 

with scenario-consistent discount rates. ** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per 

ton of NOX emissions. High Value corresponds to $4,809 per ton of NOX emissions.

Although adding the value of consumercustomer savings to the values of emission 

reductions provides a valuable perspective, the following should be considered: (1) the 

national consumercustomer savings are domestic U.S. consumercustomer monetary 

savings found in market transactions, while the values of emissions reductions are based 

on estimates of marginal social costs, which, in the case of CO2, are based on a global 

value; and (2) the assessments of consumercustomer savings and emissionemissionsrelated benefits are performed with different computer models, leading to different 

timeframestime frames for analysis. For fixtures, the present value of national 

consumercustomer savings is measured for the period in which units shipped (2015–

2044)in 2016–2045 continue to operate. However,The SCC values, on the time frames of 

316
the benefits associated with the emission reductions differ. For example, the value of CO2 

emissions reductions reflectsother hand, reflect the present value of all future climaterelated impacts due to emitting aresulting from the emission of one metric ton of CO2 in 

that year, out to 2300. Chapter 14 of the NOPR TSD presents calculations of the 

combined NPV including benefits from emissions reductions for each TSLyear. These 

impacts continue well beyond 2100.

C. Proposed Standards

DOE is subject to the EPCA requirement that any new or amended energy 

conservation standard for any type (or class) of covered equipment be designed to 

achieve the maximum improvement in energy efficiency that the Secretary determines is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In 

determining whether a standard is economically justified, the Secretary must determine 

whether the benefits of the standard exceed its burdens to the greatest extent practicable, 

in light of the seven statutory factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) 

The new or amended standard must also result in a significant conservation of energy. 

(42 U.S.C. 6295(o)(3)(B)) 

DOE considered the impacts of MHLF standards at each trial standard level, 

beginning with the max tech level, to determine whether that level met the evaluation 

criteria. If the max tech level was not justified, DOE then considered the next most 

efficient level and undertook the same evaluation until it reached the highest efficiency 

317
level that is both technologically feasible and economically justified and saves a 

significant amount of energy.

DOE discusses the benefits and/or burdens of each trial standard level in the 

following sections based on the quantitative analytical results for each trial standard level 

(presented in section VI.A) such as national energy savings, net present value (discounted 

at 7 and 3 percent), emissions reductions, industry net present value, life-cycle cost, and 

consumers’customers’ installed price increases. Beyond the quantitative results, DOE 

also considers other burdens and benefits that affect economic justification, including 

how technological feasibility, manufacturer costs, and impacts on competition may affect 

the economic results presented.

To aid the reader as DOE discusses the benefits and burdens of each trial standard 

level, DOE has included the following tables (Table VI.47 and Table VI.48) that 

summarize DOE’s quantitative analysis for each TSL. In addition to the quantitative 

results presented in the tables, DOE also considers other burdens and benefits that affect 

economic justification. Section VI.B.1 presents the estimated impacts of each TSL for 

these subgroupsthe LCC subgroup analysis.

Table VI.47 Summary of Results for Metal Halide Lamp Fixtures (Low-Shipments 

Scenario, Roll-up) 

Category

T

S

L 

1

TSL 

2

T

S

L

3

T

S

L

4

T

S

L

5

T

S

L

6

T

S

L

7

T

S

L

8

National Energy Savings (quads) 0.

1

0.19

67

0

.

0

.

0

. . .

0

.7

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318
Category

T

S

L 

1

TSL 

2

T

S

L

3

T

S

L

4

T

S

L

5

T

S

L

6

T

S

L

7

T

S

L

8

5

4

5

2

4

8

0

2

4

9

1

2

9

1

.

8

3

3

5

4

1

9

NPV of ConsumerCustomer Benefits (20102012$ billion)

3% discount rate

1.

1

8

6

3

1.38

2.25

2

.

4

5

1

2

.

6

6

1

.

6

4

2

.

5

0

1

.

6

2

1

.

9

7

1

.

8

9

1

.

8

0

7% discount rate 0.

5

1

6

9

0.57

91

0

.

6

8

9

5

0

.

6

7

9

3

0

.

6

0

3

5

0

.

7

3

0

.

6

1

0

.

1

2

Industry Impacts*

Ballast + Fixture Industry NPV (2010$2012$million)

(Base Case Industry NPV of $643 million)

2

2

8

6

2

0 

222

609 

2

2

3

6

0

0

2

2

4

5

9

5

2

2

4

5

0

2

2

1

8

2

1

8

2

1

5

Ballast + Fixture Industry NPV 

(change in 2012$million)

(

2

3.

2

)

(34.9

)

(

4

3

.

2

)

(

4

8

.

6

)

(141.0

)

Ballast + Fixture Industry NPV (% change)

-

3.

1

6

%

-

5

.

3

4

%

-

4

.

9

%

-

4

.

8

%

-

4

.

5

%

-

6

.

7

.

0

%

-

7

.

0

6

%

-

8.621.

9%

Fixture Industry NPV (2010$ million)Cumulative Emissions Reduction

5

4

2

5

4

1

5

3

3

5

3

0

52

4

5

1

6

5

0

6

436

CO2 (Mt) 2

7.

40.9

6

4

8

5

5 110.43

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Category

TS

L 1

TSL 2

TSL3TSL4TSL5

TSL6TSL7TSL8

30.53.16

SO

2 (kt)

3

6. 5354.8 2

64.9573.85

147.75

NO

x (kt)

3

6. 6655.2 0

65.5774.48

150.16

Hg (t) 0. 06

0.09

0.110.12

0.24

CH

4 (kt)

11

9. 79

180.

18

213.76243.04

488.01

N

2O (kt) 0. 49

0.74

0.891.01

2.06

Value of Cumulative Emissions Reduction

Fixture Industry NPV (% change)CO

2 (2012$ billion)**

-

0. 4%

2 

to 

2. 7

-0.6%3to4.0 -2.0%

-2.5%

-0.3to4.7%-0.4to5.2%3 -0.7.1%to10.6

-

19.8 %

NO

x

– 3% discount rate (2012$ million)**

5

1. 676.8

90.6

103.0

203.2

NO

x

– 7% discount rate (2012$ million)**2 38.145 98.1

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Category

T

S

L 

1

TSL 

2

T

S

L

3

T

S

L

4

T

S

L

5

T

S

L

6

T

S

L

7

T

S

L

8

5.

9

4

.

6

0

.

8

Mean LCC Savings (and Percent Customers Experiencing Net Benefit)*** (2012$)

50to100W_Ind_OtherV****†

(magnetic baseline)

3

2.

8

4

(

1

0

0

)

38.4

1

(100

)

3

8

.

4

1

(

1

0

0

)

3

8

.

4

1

(

1

0

0

)

-26.16

(72)

50to100W_Outd_OtherV

(magnetic baseline)

3

9.

5

0

(

1

0

0

)

46.4

4

(100

)

4

6

.

4

4

(

1

0

0

)

6

9

.

5

9

(

5

8

)

63.77

(57)

50to100W_Ind_OtherV

(electronic baseline) -- -- --

-

-

-8.48

(4)

50to100W_Outd_OtherV

(electronic baseline) -- -- --

-

-

-5.82

(16)

100to150W_Ind_OtherV‡

1

8.

5

0

(

9

9

)

39.6

8

(100

)

1

0

.

1

4

(

7

7

)

1

0

.

1

4

(

7

7

)

10.14

(77)

100to150W_Outd_OtherV

2

0.

6

6

(

1

0

0

)

44.7

0

(100

)

1

1

2

.

5

1

(

7

4

)

1

1

2

.

5

1

(

7

4

)

112.51

(74)

150to250W_Ind_OtherV‡ 6.

5

13.1

2

1

3

1

3

-59.44

(56)

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Category

TS

L 1

TSL 2

TSL3TSL4TSL5

TSL6TSL7TSL8

5(64)(69).12(69).12(69)

150to250W_Outd_OtherV

6. 73(80)

13.7 5(85)

13.75(85)13.75(85)

46.08 (46)

250to500W_Ind_OtherV

9. 10(60)

28.2 3(82)

28.23(82)28.23(82)

-99.07

(39)

250to500W_Outd_OtherV

9. 16(78)

30.4 7(93)

30.47(93)30.47(93)

26.49 (37)

500to2000W_Ind_OtherV

47

1. 20(100)

502.

21

(100)

502.21(100)502.21(100)

502.21

(100)

500to2000W_Outd_OtherV

38

5. 18

409.

02

(100)

409.0409.0

409.02

(100)

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Category

TS

L 1

TSL 2

TSL3TSL4TSL5

TSL6TSL7TSL8

(100)2(100)2(100)

Median PBP (years)

50to100W_Ind_OtherV

(magnetic baseline)

0. 5 4.

2

4.24.2

5.4

50to100W_Outd_OtherV

(magnetic baseline)

0. 6 4.

4

4.4

12.8

14.6

50to100W_Ind_OtherV

(electronic baseline) -- --

---- 32.3

50to100W_Outd_OtherV

(electronic baseline) -- --

---- 44.7

100to150W_Ind_OtherV‡ 7. 2 5.8

4.74.7

4.7

100to150W_Outd_OtherV 8. 3 6.6

10.510.5

10.5

150to250W_Ind_OtherV‡

1

2. 411.8

11.811.8

11.5

150to250W_Outd_OtherV

1

4. 814.0

14.014.0

21.4

250to500W_Ind_OtherV

1

2. 810.5

10.510.5

16.2

250to500W_Outd_OtherV

1

5. 412.3

12.312.3

24.4

500to2000W_Ind_OtherV 1. 8 2.0

2.02.0

2.0

500to2000W_Outd_OtherV 2. 7 3.0

3.03.0

3.0

Employment Impacts

Direct Employment Impacts4 97 -91 152 -

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323
Category

T

S

L 

1

TSL 

2

T

S

L

3

T

S

L

4

T

S

L

5

T

S

L

6

T

S

L

7

T

S

L

8

1 

-

(

5

0

2

)

(502

)

6

-

(

5

0

2

)

0

1

-

(

5

0

2

)

(502)

Indirect Domestic Jobs||

3

7

6

511

7

9

1

1

,

0

9

1

2,336

*INPV results are shown under the preservation of operating profit markup scenario.

**Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of 

NOX reductions is based on estimates at $2,636/ton. 

***For LCCs, a negative value means an increase in LCC by the amount indicated.

****”Indoor” and “outdoor” as defined in section V.A.2.

† Equipment class abbreviations in the form of 50 to100W_Ind_OtherV refers to the equipment class of fixtures with (1) a rated lamp 

wattage of 50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 480 V. See section V.A.2 for more 

detail on equipment class distinctions.

‡The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt 

lamps that are also rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A) and contain a ballast 

that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. The ≥150 W and ≤250 W equipment 

classes contain all other covered fixtures that are rated only for 150 watt lamps.

|| Changes in 2020.

Table VI.48 Summary of Results for Metal Halide Lamp Fixtures (High-Shipments 

Scenario)

Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

National Energy Savings (quads) 0.59 0.9

0 1.08 1.22 2.53

NPV of Customer Benefits (2012$ billion)

3% discount rate 2.10 2.9

3 3.22 3.48 3.40

7% discount rate 0.84 1.1

2 1.18 1.15 0.48

Industry Impacts*

Ballast + Fixture Industry NPV (2012$million)

(Base Case Industry NPV of $752 million)

790 82

0 

822 831 900 

Ballast + Fixture Industry NPV 

(change in 2012$million)

37.8 67.

3 

69.2 78.3 147.9 

Ballast + Fixture Industry NPV (% change) 5.0% 8.9

%

9.2% 10.4

%

19.7%

Cumulative Emissions Reduction

CO2 (Mt) 1835.78 24 3064.9 307 345 1

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324
Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

54.

29

8 3.39 7

1

5

1

.

4

7

43 0

2

SO2 (kt) 47.80 72.

54 86.79 98.08 202.14

NOx (kt)

648.94

87

4.5

5

989.50

101

00.9

5

1

2

2

1

0

.

2

6

1

4

1

7

3

2

Hg (t)

0.2608

0.3

41

2

0.4215 0.42

16

0

.

5

3

3

4

0

.

6

2

0

.

7

4

1

.

4

3

CH4 (kt)

158.30

24

0.8

0

288.54 325.

92 674.79

N2O (kt) 0.68 1.0

4 1.25 1.41 2.98

Value of Cumulative Emissions Reduction

CO2 (20102012$ billion)** 0.072 to 

1.043.4

0.0

94

to 

5.1

.3

6

0.11

4 to

6.1.71

0.11

5 to 

1.72

6.9

1

.

0

.

1

4

t

o

2

.

1

4

.

1

0

.

1

6

t

o

2

.

5

0

0

.

2

0

t

o

3

.

0

1

0

.

3

8 

t

o 

5

.

8

2

NOx – 3% discount rate (20102012$ million))**

65.0 97.

8

11116.

3

131

31.7

1

3

2

6

6

.

1

7

2

0

2

4

4

6

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

Deleted Cells

325
Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

4

NOx – 7% discount rate (20102012$ million))**

430.9

5

4

5

.

8

77

53.9 106

1.2

1

2

1

2

0

.

3

23

Mean LCC Savings (and Percent ConsumersCustomers Experiencing Net Benefit)*** (20102012$)

50to100W_Ind_OtherV****†

(magnetic baseline)

23.49

32.84

(100)

23.

05

(99

.63

8.4

1

(10

0)

23.05

(99.638

.41

(100)

48.1

7

(74.6

38.4

1

(100

)

4

8

.

1

7

(

7

4

.

6

-

2

6

.

1

6

(

7

2

)

4

8

.

1

7

(

7

4

.

6

)

4

8

.

1

7

(

7

4

.

6

)

3

9.

6

6

(

6

3.

9

)

50to10050to100W_Outd_OtherV

(magnetic baseline)

24.11

39.50

(100)

24.

30

(97

.04

6.4

4

(10

0)

24.30

(97.046

.44

(100)

24.3

0

(97.0

69.5

9

(58)

1

5

.

3

8

(

2

8

.

1

6

3

.

7

7

(

5

7

)

2

4

.

3

0

(

9

7

.

0

)

7

.

2

9

(

2

2

.

1

)

7.

2

9

(

2

2.

1

)

50to100W_Ind_OtherV

(electronic baseline) -- -- -- -

-

-

-

-

-

-

-

-

8.5148

(0.74)

50to10050to100W_Outd_OtherV

(electronic baseline) -- -- -- -

-

-

-

-

-

-

-

-8.09

(1.5.8

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

326
Category TSL 1 TS

L 2

TSL 3 TSL 4TSL 5 2

(16)

100to150100to150W_Ind_OtherV‡

7.40

(85.818.50

(99)

19.

66

(96

.23

9.68

(100)

83.47

(90.110

.14

(77)

67.2 6

(76.4

10.1 4

(77)

67.26(76.410.14(77)83.47(90.1)67.26(76.4)6

7. 26(7

6. 4)

100to150100to150W_Outd_OtherV

7.

77

(6

9.

9)

20.2666

(83.8100)

44.

70

(10

0)

48.96

(112.51

.8

(74)

48.96(112.51.8(74)33.

02

(37

.0)

48.96(112.51.8(74)33.02(37.0)33.

02

(37

.0)

150to250150to250W_Ind_OtherV‡

--

6.55

(64)

--------13.

89

12 (30

.06

9)

13.8912 (30.069 )

13.8

912

(30.0

69)

-59.44

(56)

150to250150to250W_Outd_OtherV --6.73

(80)

--

13.

75

(85)

--13.75(8--------

-

19.1

3.75 (85

(11.6 )

46.08

(46)

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

327
Category TSL 1 TS

L 2

TSL 3 TSL 4TSL 5

5)

250to500250to500W_Ind_OtherV --9.10

(60)

--

28.

23

(82)

--28.23

(82)

--

28.2 3

(82)

---99.07(39)-----3

5. 37(1

3. 4)

250to500250to500W_Outd_OtherV --9.16

(78)

--

30.

47

(93)

--30.47

(93)

--

30.4 7

(93)

--26.49(37)1.07(36.0)1.07(36.0)-6

7. 39(

9. 0)

500to2000500to2000W_Ind_OtherV

259.63

471.20

(100)

27

3.58

50

2.21

(10

0)

273.58

502.21

(100)

273.

58

502.

21

(100)

273.58502.21(100)273.58(100)273.58(100)27

3. 58(100)

500to2000500to2000W_Outd_OtherV

219.06

385.18

(100)

22

9.46

(99

.94

09.

02

(100)

229.46

(99.940

9.02

(100)

229.

46

(99.9

409.

02

(100)

229.46(99.94229.46(99.9)229.46(99.9)22

9. 46(9

9. 9)

Deleted Cells

Deleted Cells

Deleted Cells

328
Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

0

9

.

0

2

(

1

0

0

)

Median PBP§ (years)

50to100W_Ind_OtherV

(magnetic baseline)

0.585 4.5

42

4.542 4.37

2

5

.

4

.

3

7

4

.

3

7

4

.

3

7

7

.

0

9

50to10050to100W_Outd_OtherV

(magnetic baseline)

0.616

4.8

74

4.874 4.87

12.8

1

3

.

3

7

1

4

.

6

4

.

8

7

1

5

.

2

9

1

5

.

2

9

50to100W_Ind_OtherV

(electronic baseline)

-- -- -- --

-

-

3

2

.

3

-

-

-

-

3

5

.

9

8

50to10050to100W_Outd_OtherV

(electronic baseline)

-- -- -- --

-

-

4

4

.

7

-

-

-

-

3

3

.

1

0

100to150W_Ind_OtherV‡ 7.2 5.8 4.7 4.7 4.7

100to150_Ind100to150W_Outd_OtherV‡ 8.233 6.5

66

3.1610

.5

6.04

10.5

6

.

0

4

1

0

.

5

3

.

1

6

6

.

0

4

6

.

0

4

100to150_Outd150to25W0_Ind_OtherV‡

9.

0

8

7.

1

9

9.

4

0

9.

4

0

12.114

9.

40

11.

12.11.8 12.1

1.8

11.5

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

329
Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

8

150to250_Ind_OtherV‡ -

- -- -- --

-

-

13.1

8

13.

18

13.

18

150to250150to250W_Outd_OtherV --14.8

--

14.

0

--14.0 --

14.0

-

-

2

1

.

4

-

-

-

-

1

8

.

6

7

250to500250to500W_Ind_OtherV --12.8

--

10.

5

--10.5 --

10.5

-

-

1

6

.

2

-

-

-

-

1

9

.

3

7

250to500250to500W_Outd_OtherV --15.4

--

12.

3

--12.3 --

12.3

-

-

2

4

.

4

1

3

.

5

2

1

3

.

5

2

2

3

.

1

9

500to2000500to2000W_Ind_OtherV 2.351.8

2.6

50

2.650 2.65

0

2

.

6

5

0

2

.

6

5

2

.

6

5

2

.

6

5

500to2000500to2000W_Outd_OtherV 2.897

3.2

60 3.260 3.26

0

3

.

2

6

0

3

.

2

6

3

.

2

6

3

.

2

6

Distribution of Consumer LCC Impacts (see Table VI.2 through Table VI.13)

Generation Capacity Reduction (GW) || 0

.

1

5

0.20 0.25

0

.

2

5

0

.

3

1

0.37 0.4

4

0.8

6

Employment Impacts

Direct Employment Impacts

19 - (51941 -

(508)

30

-

(5

19

98 

-

(50

8)

25 -

(51997 

- (508)

26 -

(519

102 -

(508

)

3

5

-

(

5

1

9

1

5

4

5

4

-

(

5

1

9

)

6

8

-

(

5

1

9

)

1

3

8 

-

(

5

1

9

)

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

330
Category TSL 1 TS

L 2

TSL 3 TSL 

4

TSL 5

-

(

5

0

8

)

Indirect Domestic Jobs(thousands) ||

0.30392

0.

40

53

0

0

.

5

1

8

2

7

0

.

5

1

0

.

6

2

0

.

8

2

0

.

9

5

1.77

,142 2,445

*INPV results are shown under the low shipment and preservation of operating profit-flat markup scenariosscenario.

**Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of 

NOX reductions is based on estimates at $2,636/ton.

***For LCCs, a negative value means an increase in LCC by the amount indicated.

****”Indoor” and “outdoor” as defined in section V.A.2.

† Equipment class abbreviations in the form of 50 to100W_Ind_OtherV refers to the equipment class of fixtures with (1) a rated lamp 

wattage of 50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 480 V. See section V.A.2 for more 

detail on equipment class distinctions.

‡The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt 

lamps that are also rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A) and contain a ballast 

that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. The ≥150 W and ≤250 W equipment 

classes contain all other covered fixtures that are rated only for 150 watt lamps.

§ For PBPs, negative values indicate standards that reduce operating costs and installed costs; “N/A” indicates 

standard levels that do not reduce operating costs.

|| Changes in 20442020.

Table . Summary of Results for Metal Halide Lamp Fixtures (High Shipments 

Scenario, Roll-up)

Category TSL 

1

TSL 

2

TSL 

3

TSL 

4

TSL 

5

TSL 

6

TSL 

7

TSL 

8

National Energy Savings 

(quads) 0.18 0.22 0.28 0.2

8

0.3

5

0.4

1

0.4

9

0.9

5

NPV of Consumer Benefits (2010$ billion)

3% discount rate 1.46 1.72 2.08 2.06 2.03 2.50 2.39 2.33

7% discount rate 0.60 0.68 0.81 0.79 0.71 0.87 0.73 0.16 

Industry Impacts*

Deleted Cells

Deleted Cells

Deleted Cells

Deleted Cells

Inserted Cells

331
Category TSL 

1

TSL 

2

TSL 

3

TSL 

4

TSL 

5

TSL 

6

TSL 

7

TSL 

8

Ballast Industry NPV 

(2010$ million) 251 250 249 250 251 256 259 291

Ballast Industry NPV 

(% change)

-

0.5%

-

0.9% -1.2% -0.8%

-

0.3% 1.6% 2.9% 15.4%

Fixture Industry NPV 

(2010$ million) 628 637 634 632 644 646 660 722

Fixture Industry NPV 

(% change) 2.0% 3.3% 2.9% 2.7% 4.5% 4.9% 7.2% 17.3

%

Cumulative Emissions Reduction

CO2 (Mt) 21 28 35 35 44 51 62 120

NOx (kt) 4 6 7 7 9 11 13 25

Hg (t) 0.23 0.30 0.38 0.39 0.48 0.56 0.68 1.32

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)**

0.08 

to 

1.21

0.10 

to 

1.59

0.13

to

2.00

0.13 

to 

2.01

0.16

to

2.50

0.19 

to 

2.93

0.23 

to 

3.53

0.45 

to 

6.88

NOx – 3% discount rate 

(2010$ million) 7 10 12 12 15 18 22 43

NOx – 7% discount rate 

(2010$ million) 5 6 8 8 10 11 13 26

Mean LCC Savings (and Percent Consumers Experiencing Net Benefit)*** 

(2010$)

50to100W_Ind_OtherV***

*†

(magnetic baseline)

23.49

(100)

23.05

(99.6)

23.05

(99.6)

48.17

(74.6)

48.17

(74.6)

48.17

(74.6)

48.17

(74.6)

39.66

(63.9)

50to100_Outd_OtherV

(magnetic baseline)

24.11

(100)

24.30

(97.0)

24.30

(97.0)

24.30

(97.0)

15.38

(28.1)

24.30

(97.0)

7.29

(22.1)

7.29

(22.1)

50to100W_Ind_OtherV

(electronic baseline) -- -- -- -- -- -- -- -8.51

(0.7)

50to100_Outd_OtherV

(electronic baseline) -- -- -- -- -- -- -- -8.09

(1.5)

332
Category TSL 

1

TSL 

2

TSL 

3

TSL 

4

TSL 

5

TSL 

6

TSL 

7

TSL 

8

100to150_Ind_OtherV‡ 7.40

(85.8)

19.66

(96.2)

83.47

(90.1)

67.26

(76.4)

67.26

(76.4)

83.47

(90.1)

67.26

(76.4)

67.26

(76.4)

100to150_Outd_OtherV 7.77

(69.9)

20.26

(83.8)

48.96

(51.8)

48.96

(51.8)

33.02

(37.0)

48.96

(51.8)

33.02

(37.0)

33.02

(37.0)

150to250_Ind_OtherV‡ -- -- -- -- -- 13.89

(30.0)

13.89

(30.0)

13.89

(30.0)

150to250_Outd_OtherV -- -- -- -- -- -- --

-

19.85

(11.6)

250to500_Ind_OtherV -- -- -- -- -- -- --

-

35.37

(13.4)

250to500_Outd_OtherV -- -- -- -- -- 1.07

(36.0)

1.07

(36.0)

-

67.39

(9.0)

500to2000_Ind_OtherV

259.6

3

(100)

273.5

8

(100)

273.58

(100)

273.5

8

(100)

273.5

8

(100)

273.5

8

(100)

273.5

8

(100)

273.5

8

(100)

500to2000_Outd_OtherV

219.0

6

(100)

229.4

6

(99.9)

229.46

(99.9)

229.4

6

(99.9)

229.4

6

(99.9)

229.4

6

(99.9)

229.4

6

(99.9)

229.4

6

(99.9)

Median PBP§ (years)

50to100W_Ind_OtherV

(magnetic baseline) 0.58 4.54 4.54 4.37 4.37 4.37 4.37 7.09

50to100_Outd_OtherV

(magnetic baseline) 0.61 4.87 4.87 4.87 13.37 4.87 15.29

15.2

9

50to100W_Ind_OtherV

(electronic baseline) -- -- -- -- -- -- -- 35.98

50to100_Outd_OtherV

(electronic baseline) -- -- -- -- -- -- -- 33.10

333
Category TSL 

1

TSL 

2

TSL 

3

TSL 

4

TSL 

5

TSL 

6

TSL 

7

TSL 

8

100to150_Ind_OtherV‡ 8.23 6.56 3.16 6.04 6.04 3.16 6.04 6.04

100to150_Outd_OtherV 9.08 7.19 9.40 9.40 12.1

1 9.40 12.11

12.1

1

150to250_Ind_OtherV‡ -- -- -- -- -- 13.1

8

13.1

8

13.1

8

150to250_Outd_OtherV -- -- -- -- -- -- -- 18.6

7

250to500_Ind_OtherV -- -- -- -- -- -- -- 19.3

7

250to500_Outd_OtherV -- -- -- -- -- 13.5

2

13.5

2

23.1

9

500to2000_Ind_OtherV 2.35 2.65 2.65 2.65 2.65 2.65 2.65 2.65

500to2000_Outd_OtherV 2.89 3.26 3.26 3.26 3.26 3.26 3.26 3.26

Distribution of Consumer LCC Impacts (see Table VI.2 through Table VI.13)

Generation Capacity 

Reduction (GW) || 0.20 0.27 0.34 0.34 0.42 0.50 0.60 1.16

Employment Impacts 

Direct Employment 

Impacts

21 -

(515)

35 -

(515)

29 -

(515)

30 -

(515)

38 -

(515)

62 -

(515)

78 -

(515)

157 -

(515)

Indirect Domestic Jobs 

(thousands) || 0.45 0.59 0.77 0.78 0.92 1.20 1.39 2.41

*INPV results are shown under the low shipment and preservation of operating profit markup scenarios.

**Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions.

***For LCCs, a negative value means an increase in LCC by the amount indicated.

 ”Indoor” and “outdoor” as defined in section V.A.2.

† Equipment class abbreviations in the form of 50 to100W_Ind_OtherV refers to the equipment class of 

fixtures with (1) a rated lamp wattage of 50 W to 100 W, (2) an indoor operating location, and (3) a 

tested input voltage other than 480 V. See section V.A.2 for more detail on equipment class distinctions.

‡The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are 

fixtures rated only for 150 watt lamps that are also rated for use in wet locations, as specified by the 

National Electrical Code 2002, section 410.4(A) and contain a ballast that is rated to operate at ambient 

air temperatures above 50°C, as specified by UL 1029–2001. The ≥150 W and ≤250 W equipment 

classes contain all other covered fixtures that are rated only for 150 watt lamps.

§ For PBPs, negative values indicate standards that reduce operating costs and installed costs; “N/A” 

indicates standard levels that do not reduce operating costs.

|| Changes in 2044.

As discussed in previous DOE standards rulemakings and a recent Notice of Data 

Availabilitythe February 2011 NODA (76 FR 9696, (Feb. 22, 2011)), DOE also notes 

that the economics literature provides a wide-ranging discussion of how 

334
consumerscustomers trade off upfront costs and energy savings in the absence of 

government intervention. Much of this economics literature attempts to explain why 

consumerscustomers appear to undervalue energy efficiency improvements. This 

undervaluation suggests that regulation promoting energy efficiency can produce 

significant net private gains (as well as producing social gains by, for example, reducing 

pollution). There is evidence that consumerscustomers undervalue future energy savings 

as a result of (1) a lack of information, (2) a lack of sufficient savings to warrant 

delayingaccelerating or altering purchases (e.g., an inefficient ventilation fan in a new 

building or the delayed replacement of a water pump), (3) inconsistent (e.g., excessive 

short-term) weighting of future energy cost savings relative to available returns on other 

investments, (4) computational or other difficulties associated with the evaluation of 

relevant tradeoffs, and (5) a divergence in incentives (e.g., renter versus owner; builder 

vs. purchaser). Other literature indicates that with less-than-perfect foresight and a high 

degree of uncertainty about the future, consumers mayit may be rational for customers to

trade off these types of investments at a higher-than expected rate between current 

consumption and uncertain future energy cost savings. In the abstract, it may be difficult 

to say how a welfare gain from correcting under-investment compares in magnitude to 

the potential welfare losses associated with no longer purchasing a machine or switching 

to an imperfect substitute, both of which still exist in this framework. 

Other economic literature indicates that with less than perfect foresight and uncertainty 

about the future, consumers may trade off these types of investments at a higher than -

expected rate between current consumption and uncertain future energy cost savings. 

Comment [AGA29]: Revised at the request of 

OIRA.

Comment [AGA30]: Revised at the request of 

OIRA.

Comment [AGA31]: Revised at the request of 

OIRA.

Comment [AGA32]: Revised at the request of 

OIRA.

Comment [AGA33]: Revised at the request of 

OIRA.

335
Some studies suggest that this seeming undervaluation may be explained in certain 

circumstances by differences between tested and actual energy savings, or by uncertainty 

and irreversibility of energy investments. There may also be “hidden” welfare losses to 

customers if newer energy efficient products are imperfect substitutes for the less 

efficient products they replace, in terms of performance or other attributes that customers

value. In the abstract, it may be difficult to say how a welfare gain from correcting

potential under-investment in energy conservation compares in magnitude to the potential 

welfare losses associated with no longer purchasing a machine or switching to an 

imperfect substitute, both of which still exist in this framework. 

The mix of evidence in the empirical economics literature suggests that if 

feasible, analysis of regulations mandating energy-efficiency improvements should 

explore the potential for both welfare gains and losses and move toward a fuller 

economic framework where all relevant changes can be quantified.70 While DOE is not 

prepared at present to provide a fuller quantifiable framework for this discussion, DOE 

seeks comments on how to assess these possibilities.71 In particular, DOE requests 

comment on whether there are features or attributes of the more energy efficient ballasts 

that manufacturers would produce to meet the standards in this proposed rule that might 

affect the welfare, positively or negatively, of consumers who purchase MHLFs. One 

70 A good review of the literature related to this issue can be found in Gillingham, K., R. Newell, K. 

Palmer. (2009). ‘‘Energy Efficiency Economics and Policy,’’ Annual Review of Resource Economics, 1: 

597–619; and Tietenberg, T. (2009). ‘‘Energy Efficiency Policy: Pipe Dream or Pipeline to the Future?’’ 

Review of Environmental Economics and Policy. Vol. 3, No. 2: 304–320. 71 A draft paper, ‘‘Notes on the Economics of Household Energy Consumption and Technology Choice,’’ 

proposes a broad theoretical framework on which an empirical model might be based and is posted on the 

DOE Web site along with this notice at www.eere.energy.gov/buildings/appliance_standards

appliance_standards..

Comment [AGA34]: Revised at the request of 

OIRA.

336

 
example of such an effect might result from the use of electronic ballasts in outdoor 

applications, which DOE’s analysis models for compliance with TSL3 for 150 watt 

fixtures. In TSL4, electronic ballasts are also modeled for outdoor applications for 70 

watt fixtures. As discussed above, currently magnetic ballasts are generally favored over 

electronic ballasts for outdoor applications, but there are some commercially available 

fixtures using electronic ballasts that are designed for outdoor applications. DOE requests 

comment specifically on whether the more widespread use of electronic ballasts would 

involve any performance or reliability effects for either 70-watt or 150-watt fixtures, and 

how any such effects should be weighed in the choice of standards for these two wattage 

categories for the final rule.

1. Trial Standard Level 85

DOE first considered the most efficient level, TSL 85, which would save an 

estimated total of 0.791.8 to 0.952.5 quads of energy through 2044for fixtures shipped in 

2016–2045—a significant amount of energy. For the nation as a whole, TSL 85 would 

have a net savings of $0.1235 billion–$0.1648 billion at a 7-percent discount rate, and 

$1.82.5 billion–2.–$3.4 billion at a 3-percent discount rate. The emissions reductions at 

TSL 85 are estimated at 102–120 to be 110–151 million metric tons (Mt) of CO2, 25–32 

kilotons (148–202 kt) of SO2, 150–210 kt of NOx, and 1.32–1.430.24–0.34 tons of Hg. 

Total generating capacity in 2044 is estimated to decrease compared to the reference case 

by 0.86–1.16 gigawatts under TSL 8. As seen in section VI.B.1, for almost all over half 

of the representative equipment classes, consumerscustomers have available designs that 

result in positive mean LCC savings, ranging from $10.84–$302.3714-$502.21, at TSL 8. 

Comment [AGA35]: Revised at the request of 

OIRA.

337
Consumers that experience negative5. The equipment classes with positive mean LCC 

savings at TSL 85 are those that would purchase indoor fixtures with a rated lamp 

wattage of ≥50outdoor 70 W and ≤100 W or >250 W and ≤500 W and outdoor fixtures67

with a rated lamp wattage of ≥15072 W and ≤500 W. DOE’s LCC analysis indicates (see 

tables through ) that although (for the mean LCC savings are positive, the majority of 

consumers have increased life cycle costs for magnetic ballast baseline), indoor and 

outdoor 150 W fixtures with a rated lamp wattage of ≥50 W and <15073 W and indoor , 

outdoor 250 W fixtures, outdoor 400 W fixtures, and indoor and outdoor 1000 W 

fixtures. However, DOE’s NPV analysis indicates (see Table VI.38 with a rated lamp 

wattage of ≥50 W and ≤100 W or ≥15074 W and ≤500 W.) that most equipment classes

experience a negative NPV at TSL 5. The equipment classes that have negative NPV at 

TSL 5 are indoor and outdoor 70 W, 250 W, and 400 W fixtures. The equipment classes 

with positive NPV at TSL 5 are indoor and outdoor 150 W and 1000 W fixtures. The 

projected change in industry value for metal halide ballast manufacturers would range 

from an increase of $38.736.5 million to a decrease of $20.324.1 million, or a net gain of 

15.429.8 percent to a net loss of 8.623.3 percent in INPV. The projected change in 

industry value for metal halide lamp fixture manufacturers would range from an increase 

72 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001. 73 This wattage range contains those fixtures that are rated only for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001. 74 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

338

 
of $106111.3 million to a decrease of $107.8116.9 million, or a net gain of 17.37 percent 

to a net loss of 19.821.6 percent in INPV.

DOE based TSL 85 on the most efficient commercially available equipment for 

each representative equipment class analyzed. This TSL corresponds to a commercially 

available low-frequency electronic ballast for fixtures rated for lamp wattages ≥50 

Windoor and ≤outdoor 70 W, 150 W, 250 W fixtures, a commercially available highfrequency electronic ballast for indoor and outdoor metal halide lamp fixtures rated for 

lamp wattages of >250 W and ≤500 W400 W fixtures, and a commercially available 

magnetic ballast in fixtures rated1000 W fixtures. DOE notes that there is limited 

compatibility between the high-frequency electronic ballasts required for indoor and 

outdoor 400W fixtures and high efficiency CMH lamps. This could potentially limit 

energy savings opportunities through the use of CMH lamps. See section V.C.8 for lamp 

wattages >500 W and ≤2000 W.additional detail. TSL 85 also prohibits the use of probestart ballasts in new 1000 W fixtures for the >500 W and ≤2000 W equipment classes.

After considering the analysis, the comments that DOE received on the 

preliminary analysis, and the benefits and burdens of TSL 85, the Secretary has reached 

the following tentative conclusion: the benefits of energy savings, emissions reductions 

(both in physical reductions and the monetized value of those reductions), and the 

positive net economic savings to the nation are outweighed by the increasednegative 

NPV experienced in some equipment classes at both a 3-percent and 7-percent discount 

rate, the negative mean LCC for the majority of consumerssavings experienced in some 

339
equipment classes, and the potential decrease in INPV for manufacturers. Consequently, 

the Secretary has tentatively concluded that trial standard level 85 is not economically 

justified.

2. Trial Standard Level 74

DOE then considered TSL 74, which would save an estimated total of 0.4191 to 

0.491.2 quads of energy through 2044for fixtures shipped in 2016–2045—a significant 

amount of energy. For the nation as a whole, TSL 74 would have a net savings of 

$0.6193 billion–$0.731.2 billion at a 7-percent discount rate, and $1.92.7 billion–2.4–

$3.5 billion at a 3-percent discount rate. The emissions reductions at TSL 74 are 

estimated at 53–62to be 55–73 Mt of CO2, , 13–1774–98 kt of SO2, 74–101 kt of NOx, 

and 0.6812–0.7416 tons of Hg. Total generating capacity in 2044 is estimated to decrease 

compared to the reference case by 0.44–0.60 gigawatts under TSL 7. As seen in section 

VI.B.1, for all representative equipment classes, consumerscustomers have available 

designs whichthat result in positive mean LCC savings, ranging from $0.00–

$302.3710.14–$502.21, at TSL 7. However,4. DOE’s LCCNPV analysis indicates (see

Table VI.38tables through ) that although the mean LCC savings areeach equipment 

class has a positive, the majority of consumers would still have increased LCC for 

outdoor fixtures with a rated lamp wattage of ≥50 W and <15075 W or >250 W and ≤500 

W and indoor fixtures with a rated lamp wattage of ≥15076 W and ≤500 W. NPV at TSL 

75 This wattage range contains those fixtures that are rated only for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001. 76 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

340

 
4. The projected change in industry value for metal halide ballast manufacturers would 

range from an increase of $4.7.4 million to a decrease of $16.524.8 million, or a net gain 

of 2.93.8 percent to a net loss of 724.0 percent in INPV. The projected change in industry 

value for metal halide lamp fixture manufacturers would range from an increase of 

$44.373.6 million to a decrease of $38.623.8 million, or a net gain of 11.7.2 percent to a 

net loss of 7.14.4 percent in INPV.

TSL 74 represents the maximum energy savings achievable with positive mean 

LCC savingsNPV for each representative equipment class, considering indoor and 

outdoor fixtures separately. This TSL corresponds to a modeled magnetic ballast in 

indoor 70 W fixtures, indoor and outdoor 250 W fixtures and indoor and outdoor 400 W 

fixtures; a commercially available low-frequency electronic ballast in fixtures rated for 

lamp wattages ≥50 W and <15077 W, indoor fixtures rated for lamp wattages ≥15078 W 

and ≤250 W, and outdoor outdoor 70 W fixtures rated for lamp wattages >250 W and 

≤500 W, and indoor and outdoor 150 W fixtures; and a commercially available magnetic 

ballast in fixtures rated for lamp wattages >500 W indoor and ≤2000 W, outdoor 1000 W 

fixtures rated. TSL 4 sets different standards for lamp wattages ≥1507970 W and ≤250 W, 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001. 77 This wattage range contains those fixtures that are rated only for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001. 78 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001. 79 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

341

 
and indoor fixtures rated for lamp wattages of >250 W and ≤500 W, and a modeled 

magnetic ballast in outdoor fixtures rated for lamp wattages >250 W and ≤500 W. TSL 

7for the indoor versus outdoor equipment classes. TSL 4 also prohibits the use of probestart ballasts in new 1000 W fixtures.

Setting different standards for the indoor versus outdoor fixtures of the same 

wattage has the potential for certification issues and lost energy savings. Indoor 70 W 

fixtures require EL2 magnetic ballasts while outdoor 70 W fixtures require electronic 

ballasts. Because the indoor magnetic ballast can provide the features necessary for 

outdoor operation, there is potential for indoor fixtures to be used outdoors in 

applications where moisture is a smaller concern. For example, a parking garage or other 

semi-covered structure is less likely to sustain direct water contact. Additionally, the 

indoor EL2 magnetically ballasted fixtures are less expensive than the outdoor EL3 

electronically ballasted fixtures. This creates an economic incentive for outdoor 

customers to use the indoor EL2 fixtures. This substitution could decrease the expected 

energy savings, and could reduce the reliability and lifetime of the misapplied indoor 

fixtures. Furthermore, setting different standards for the >500 W and ≤2000 W equipment 

classesindoor versus outdoor equipment classes increases compliance, certification, and 

enforcement costs for manufacturers. Fixture manufacturers would use different ballasts 

for indoor and outdoor fixtures of the same wattage, complicating fixture-ballast 

matching and increasing the number of basic models.

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

342

 
After considering the analysis, the comments that DOE received on the 

preliminary analysis, and the benefits and burdens of TSL 74, the Secretary has reached 

the following tentative conclusion: at TSL 74, the benefits of energy savings, emissions 

reductions (both in physical reductions and the monetized value of those reductions), and 

the positive net economic savings to the nation would be outweighed by the increased 

LCC potential for certification issues and lost energy savings resulting from setting 

different standards for the indoor versus outdoor fixtures of the majority of 

consumerssame wattage, and the potential decrease in INPV for manufacturers. 

Consequently, the Secretary has tentatively concluded that trial standard level 74 is not 

economically justified.

3. Trial Standard Level 63

DOE then considered TSL 63, which would save an estimated total of 0.3580 to 

0.411.1 quads of energy through 2044for fixtures shipped in 2016–2045—a significant 

amount of energy. For the nation as a whole, TSL 63 would have a net savings of 

$0.7395 billion–$0.871.2 billion at a 7-percent discount rate, and $1.972.5 billion––

$3.2.50 billion at a 3-percent discount rate. The emissions reductions at TSL 63 are 

estimated at 44–51to be 49–65 Mt of CO2, 11–14approximately 65–87 kt of SO2, 66–90

kt of NOx, and 0.5611–0.6215 tons of Hg. Total generating capacity in 2044 is estimated 

to decrease compared to the reference case by 0.37–0.50 gigawatts under TSL 6. As seen 

in section VI.B.1, for all representative types, consumersequipment classes, customers

have available designs whichthat result in positive mean LCC savings, ranging from 

343
$0.00–$302.3710.14–$502.21, at TSL 6. However,3. DOE’s LCCNPV analysis indicates 

(see Table VI.38tables through ) that although the mean LCC savings areeach equipment 

class has a positive, the majority of consumers have increased LCC for outdoor fixtures 

with a rated lamp wattage of >250 W and ≤500 W and indoor fixtures with a rated lamp 

wattage of ≥15080 W and ≤500 W. NPV at TSL 3. The projected change in industry value 

for metal halide ballast manufacturers would range from an increase of $4.15 million to a 

decrease of $16.625.9 million, or a net gain of 1.63.7 percent to a net loss of 725.0 

percent in INPV. The projected change in industry value for metal halide lamp fixture 

manufacturers would range from an increase of $30.364.8 million to a decrease of 

$28.117.3 million, or a net gain of 4.910.3 percent to a net loss of 53.2 percent in INPV.

TSL 63 represents the maximum energy savings achievable with positive mean 

LCC savings for each representative equipment class with the requirement thatpositive 

NPV (when comparing the total NPV associated with TSL 3 to all other TSLs) and sets

the same efficiency levels for fixtures operating indoors and outdoors be analyzed. This 

TSL corresponds to a modeled magnetic ballast in outdoor fixtures rated for lamp 

wattages ≥50 W and ≤100 W or >250 W and ≤500 W,70 W, 250 W, and 400 W fixtures;

a commercially available low-frequency electronic ballast in fixtures rated for lamp 

wattages >100 W and ≤250 W and indoor fixtures rated for lamp wattages ≥50 W and 

≤100 W,150 W fixtures; and a commercially available magnetic ballast in 1000 W 

fixtures rated for lamp wattages >250 W and ≤2000 W.. TSL 63 also prohibits the use of 

80 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

344

 
probe-start ballasts in new 1000 W fixtures for. Because the >500 W and ≤2000150 W 

fixtures are subject to a more stringent standard (EL4, max tech) than other equipment 

classes (EL2), there is potential for customers to switch to the higher wattage fixtures to 

avoid the more stringent standards. This customer behavior could reduce the energy 

savings associated with TSL 3.

After considering the analysis, comments on the preliminary analysis, and the 

benefits and burdens of TSL 6, the Secretary has reached the following tentative 

conclusion: at TSL 6, the benefits of energy savings, emissions reductions (both in 

physical reductions and the monetized value of those reductions), and the positive net 

economic savings to the nation would still be outweighed by the increased LCC for the 

majority of consumers and the potential decrease in INPV for manufacturers. 

Consequently, the Secretary has tentatively concluded that trial standard level 6 is not 

economically justified.

2. Trial Standard Level 5

DOE then considered TSL 5, which would save an estimated total of 0.29 to 0.35 

quads of energy through 2044—a significant amount of energy. For the nation as a 

whole, TSL 5 would have a net savings of $0.60 billion–$0.71 billion at a 7-percent 

discount rate, and $1.62 billion–2.03 billion at a 3-percent discount rate. The emissions 

reductions at TSL 5 are estimated at 37–44 Mt of CO2, 9–12 kt NOx, and 0.48–0.53 tons 

of Hg. Total generating capacity in 2044 is estimated to decrease compared to the 

reference case by 0.31–0.42 gigawatts under TSL 5. As seen in section , for all 

345
representative types, consumers have available designs which result in positive LCC 

savings, ranging from $0.00–$302.37, at TSL 5. However, DOE’s LCC analysis indicates 

(see tables through ) that although the mean LCC savings are positive, the majority of 

consumers still have increased LCC for outdoor fixtures with a rated lamp wattage of ≥50 

W and <15081 W and indoor fixtures with a rated lamp wattage of ≥15082 W and ≤250 

W. The projected change in industry value for metal halide ballast manufacturers would 

range from a decrease of $0.8 million to a decrease of $10.5 million, or a net loss of 0.3

percent to a net loss of 4.5 percent in INPV. The projected change in industry value for 

metal halide lamp fixture manufacturers would range from an increase of $27.5 million to 

a decrease of $20.1 million, or a net gain of 4.5 percent to a net loss of 3.7 percent in 

INPV.

TSL 5 represents the maximum positive mean LCC savings for each 

representative equipment class. This TSL corresponds to a commercially available lowfrequency electronic ballast in metal halide lamp fixtures rated for lamp wattages ≥50 W

and <15083 W and a commercially available magnetic ballast in fixtures rated for lamp 

81 This wattage range contains only those fixtures that are rated for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001. 82 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001. 83 This wattage range contains those fixtures that are rated only for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001.

346

 
wattages ≥15084 and ≤2000 W. TSL 5 also prohibits the use of probe start ballasts in new 

fixtures for the >500 W and ≤2000 W equipment classes.

After considering the analysis, comments on the preliminary analysis, and the 

benefits and burdens of TSL 5, the Secretary has reached the following tentative 

conclusion: at TSL 5, the benefits of energy savings, emissions reductions (both in 

physical reductions and the monetized value of those reductions), and the positive net 

economic savings to the nation still would be outweighed by the increased LCCs for the 

majority of consumers and the potential decrease in INPV for manufacturers. 

Consequently, the Secretary has tentatively concluded that trial standard level 5 is not 

economically justified.

3. Trial Standard Level 4

DOE then considered TSL 4, which would save an estimated total of 0.24 to 0.28 

quads of energy through 2044—a significant amount of energy. For the nation as a 

whole, TSL 4 would have a net savings of $0.67 billion–$0.79 billion at a 7-percent 

discount rate, and $1.64 billion–2.06 billion at a 3-percent discount rate. The emissions 

reductions at TSL 4 are estimated at 30–35 Mt of CO2, 7–10 kt of NOx, and 0.39–0.42 

tons of Hg. Total generating capacity in 2044 is estimated to decrease compared to the 

reference case by 0.25–0.34 gigawatts under TSL 4. As seen in section , for all 

representative equipment classes, the majority of consumers have available designs 

84 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

347

 
which result in LCC savings, ranging from $0.00–$302.37 (mean LCC savings), at TSL 

4. The projected change in industry value for metal halide ballast manufacturers would 

range from a decrease of $2.1 million to a decrease of $11.3 million, or a net loss of 0.8

percent to a net loss of 4.8 percent in INPV. The projected change in industry value for 

metal halide lamp fixture manufacturers would range from an increase of $16.4 million to 

a decrease of $13.6 million, or a net gain of 2.7 percent to a net loss of 2.5 percent in 

INPV.

TSL 4 represents the maximum energy savings with a majority of consumers 

having positive LCC savings for each representative equipment class. This TSL 

corresponds to a commercially available low-frequency electronic ballast in indoor 

fixtures rated for lamp wattages ≥50 W and ≤100 W and fixtures rated for lamp wattages 

>100 W and <15085, a modeled magnetic ballast in outdoor fixtures rated for lamp 

wattages ≥50 W and ≤100 W, and a commercially available magnetic ballast in fixtures 

rated for lamp wattages ≥15086 and ≤2000 W. TSL 4 also prohibits the use of probe start

ballasts in new fixtures for the >500 W and ≤2000 W equipment classes.

TSL 4 sets different efficiency levels for indoor and outdoor fixtures for the ≥50 

W and ≤100 W equipment classes and different efficiency levels for indoor and outdoor 

fixtures for the >100 W and <150 W equipment classes. Because the definition of an 

85 This wattage range contains only those fixtures that are rated for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001. 86 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

348

 
outdoor fixture is a fixture rated for wet locations, DOE is concerned about the possibility 

that an outdoor fixture (as defined by DOE)would be used indoors. Because the standards 

included in TSL 4 are more stringent for indoor than outdoor fixtures, there could be a 

perverse cost incentive (the more efficient indoor fixture is more costly) to use outdoor 

rated fixtures indoors. This substitution would result in reduced energy savings relative to 

DOE’s projections. A second concern is that the compliance and enforcement burden for 

maintaining separate indoor and outdoor standards would be considerable.

After considering the analysis, comments on the preliminary analysis, and the 

benefits and burdens of TSL 4, DOE has reached the following tentative conclusion: at 

TSL 4, the benefits of energy savings, emissions reductions (both in physical reductions 

and the monetized value of those reductions), the positive net economic savings to the 

nation, and the majority of consumers having positive LCC savings for all representative 

equipment classes still would be outweighed by the compliance and enforcement burden 

of having different standards set for metal halide lamp fixtures that operate in indoor and 

outdoor locations. In addition, there is the potential for the less stringent outdoor 

standards for fixtures rated from 50 W to 150 W to encourage use of outdoor fixtures 

indoors. Consequently, DOE has tentatively concluded that trial standard level 4 is not 

economically justified.

4. Trial Standard Level 3

DOE next considered TSL 3, which would save an estimated total of 0.24 to 0.28 

quads of energy through 2044—still a significant amount of energy. For the nation as a 

349
whole, TSL 3 would have a net savings of $0.68 billion–$0.81 billion at a 7-percent 

discount rate, and $1.66 billion–2.08 billion at a 3-percent discount rate. The emissions 

reductions at TSL 3 are estimated at 30–35 Mt of CO2, 7–9 kt of NOx, and 0.38–0.42 tons 

of Hg. Total generating capacity in 2044 is estimated to decrease compared to the 

reference case by 0.25 to 0.34 gigawatts under TSL 3. As seen in section , for all 

representative equipment classes, the majority of consumers have available designs 

which result in LCC savings, ranging from $0.00–$302.37 (mean LCC savings), at TSL 

3. The projected change in industry value for metal halide ballast manufacturers would 

range from a decrease of $2.9 million to a decrease of $11.6 million, or a net loss of 1.2

percent to a net loss of 4.9 percent in INPV. The projected change in industry value for 

metal halide lamp fixture manufacturers would range from an increase of $17.9 million to 

a decrease of $10.8 million, or a net gain of 2.9 percent to a net loss of 2.0 percent in 

INPV.

TSL 3 represents the maximum energy savings with a majority of consumers 

having positive LCC savings. It also has the same standard levels set for metal halide 

lamp fixtures operating in both indoor and outdoor locations. This TSL corresponds to a 

modeled magnetic ballast in metal halide lamp fixtures rated for lamp wattages ≥50 W 

and ≤100 W, a commercially available low-frequency electronic ballast in fixtures rated 

for lamp wattages >100 W and <150,87 and a commercially available magnetic ballast in 

87 This wattage range contains only those fixtures that are rated for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029–2001.

350

 
fixtures rated for lamp wattages ≥15088 and ≤2000 W. TSL 3 also prohibits the use of 

probe start ballasts in new fixtures for the >500 W and ≤2000 W equipment classes. 

Because TSL 3 requires the same minimum ballast efficiencies for indoor and outdoor 

fixtures, it does not have the potential for the compliance and enforcement and product 

substitution issues possible with TSL 4. 

After considering the analysis, commentsAfter considering the analysis, 

the comments that DOE received on the preliminary analysis, and the benefits and 

burdens of TSL 3, the Secretary has reached the following tentative conclusion: TSL 3 

offers the maximum improvement in efficiency that is technologically feasible and 

economically justified, and will result in significant conservation of energy. The 

Secretary has reached the initial conclusion that The benefits of energy savings, 

emissions reductions (both in physical reductions and the monetized value of those 

reductions), the positive net economic savings to the nation,(NPV) at discount rates of 3-

percent and positive LCC savings for a majority of consumers7-percent at each 

representative equipment class would outweigh the potential reduction in INPV for 

manufacturers. Therefore, DOE today proposes to adopt energy conservation standards

for metal halide lamp fixtures at TSL 3. DOE seeks comment on its proposal of adopting 

energy conservation standards for metal halide lamp fixtures at TSL 3. DOE will consider 

the comments and information received in determining the final energy conservation 

standards.

88 This wattage range contains all covered fixtures that are rated only for 150 watt lamp that are not also 

rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and do 

not also contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 

1029–2001.

351

 
D. Backsliding

As discussed in section II.A, EPCA contains what is commonly known as an 

“anti-backsliding” provision, which mandates that the Secretary not prescribe any 

amended standard that either increases the maximum allowable energy use or decreases 

the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) 

DOE is evaluating amended standards in terms of ballast efficiency, which is the same 

metric that is currently used in energy conservation standards. Therefore, DOE compared 

the existing standards to the proposed amendments to confirm that none of the proposals 

constituted backsliding.

The existing standards for ballast efficiency for metal halide lamp fixtures, set by 

EISA 2007, mandated that ballasts rated at wattages ≥150 W and ≤500 W operate at a 

minimum of 88% percent efficiency if pulse-start, 94 percent if probe-start magnetic, 90 

percent if non-pulse nonpulse-start electronic ≥150 W and ≤250 W, and 92 percent if 

non-pulse nonpulse-start electronic ballasts >250 W and ≤500 W. These standards 

excluded fixtures with regulated-lag ballasts, fixtures that use 480 V electronic ballasts, 

and fixtures that (1) are only rated for use with 150 W lamps,; (2) are rated for use in wet 

locations,; and (3) contain a ballast that is rated to operate above 50oC50 oC. This 

rulemaking is proposing to cover fixtures with ballasts rated at ≥50 W and ≤2000 W, 

retain the exemptions for fixtures with regulated lag ballasts or 480 V electronic ballasts, 

and remove the exemption for 150 W fixtures used in wet locations with ballasts rated 

tothat operate above 50o

C50 oC. 

352
As presented in the following table, DOE is not proposing any efficiency 

standards that would qualify as backsliding. In the ≥50 W and <150 W89 range, there are 

no existing federal efficiency standards. Thus, any standard set by DOE in this 

rulemaking would not be backsliding, as it would be prescribing a standard where there 

previously was not one. The 150 W ballasts currently exempt by EISA (those only rated 

for use with 150 W lamps, rated for wet locations, and rated to operate at temperatures 

greater than 50oC50 oC) are not covered by any existing federal energy conservation 

standards, so amended standards set for such ballasts would likewise not be subject to 

backsliding. Similarly, in the >500 W and ≤2000 W range, there are no existing federal 

energy conservation standards, so standards proposed in this rulemaking would not 

backslide. Finally for the ≥150 W90 and ≤500 W range (not including the exempt 150 W 

fixtures), EISA currently prescribes standards. However, DOE is notalso proposing any 

amendments to these standards, so there can not for fixtures in this wattage range. The 

proposed standard changes with wattage, but always requires ballasts in new fixtures to 

be at least 88 percent efficient (88 percent efficiency for pulse-start ballasts is the least 

stringent of the various EISA 2007 requirements). If the efficiency standard proposed by 

DOE is lower than the standard prescribed by EISA for any ballast types or wattages

(e.g., 94 percent efficiency requirement for probe-start ballasts), then the EISA standard 

will take precedence and prevent any potential backsliding. 

89 This wattage range contains those fixtures that are rated only for 150 watt lamps that are also rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and contain a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. 90 This wattage range contains all covered fixtures that are rated only for 150 watt lamplamps that are not

also rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and 

do not also contain a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by 

UL 1029–2001.

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On the basis of this section, the standards proposed in this NOPR are either higher 

than the existing standards, primarily because they set standards for previously 

unregulated fixtures., or if the EISA standards are higher than those proposed in this 

NOPR then the EISA standard is given precedence. As such, the proposed standards do 

not decrease the minimum required energy efficiency of the covered equipment and,

therefore, do not violate the anti-backsliding provision in EPCA.

Table VI.49 Existing Federal Efficiency Standards and Proposed Efficiency 

Standards

Rated Lamp 

Wattage

Indoor/ 

Outdoor** *

Test Input 

Voltage‡

Existing 

Standards 

(Efficiency)

Proposed Efficiency 

Standards/Equations

%

≥50 W and ≤100 

W Indoor 480 V N/A 0.99499.4/(1+2.5*P^(-0.55)) †

≥50 W and ≤100 

W Indoor All others N/A 1100/(1+2.5*P^(-0.55))

≥50 W and ≤100 

W Outdoor 480 V N/A 0.99499.4/(1+2.5*P^(-0.55))

≥50 W and ≤100 

W Outdoor All others N/A 1100/(1+2.5*P^(-0.55))

>100 W and <150 

W* Indoor 480 V N/A 0.99499.4/(1+2.50.36*P^(-0.5530))

>100 W and <150 

W* Indoor All others N/A 1100/(1+0.6*36∗P^(-0.3430))

>100 W and <150 

W* Outdoor 480 V N/A 0.99499.4/(1+2.50.36*P^(-0.5530))

>100 W and <150 

W* Outdoor All others N/A 1100/(1+0.6*36∗P^(-0.3430))

≥150 W** and 

≤250 W Indoor 480 V

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendmentsFor 

≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

6.0*10^(-2)*P + 76.0

≥150 W** and 

≤250 W Indoor All others

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendmentsFor 

≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

7.0*10^(-2)*P + 74.0

≥150 W** and 

≤250 W Outdoor 480 V

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendmentsFor 

≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

6.0*10^(-2)*P + 76.0

≥150 W** and 

≤250 W Outdoor All others

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendmentsFor 

≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

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7.0*10^(-2)*P + 74.0

>250 W and ≤500 

W Indoor 480 V

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendments91.0

>250 W and ≤500 

W Indoor All others

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendments91.5

>250 W and ≤500 

W Outdoor 480 V

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendments91.0

>250 W and ≤500 

W Outdoor All others

Varies from 88% 

to 94% depending 

on ballast type

No proposed amendments91.5

>500 W and 

≤2000 W Indoor 480 V N/A

For >500 W to <1000 W:

0.994*(∗(3.2*∗10^(-5)*3)∗P + 

089.9)

For ≥1000 W to ≤2000 W: 

91.9%92.5 

>500 W and 

≤2000 W Indoor All others N/A

For >500 W to <1000 W:

3.2*∗10^(-5)*3)∗P + 089.9

For ≥1000 W to ≤2000 W: 

92.5%93.1 

>500 W and 

≤2000 W Outdoor 480 V N/A

For >500 W to <1000 W:

0.994*∗(3.2*∗10^(-5)*3)∗P + 

089.9)

For ≥1000 W to ≤2000 W: 

91.9%92.5 

>500 W and 

≤2000 W Outdoor All others N/A

For >500 W to <1000 W:

3.2*∗10^(-5)*3)∗P + 089.9

For ≥1000 W to ≤2000 W: 

92.5%93.1 

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that are also; rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A)); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that are also; rated for use in 

wet locations, as specified by the National Electrical Code 2002, section 410.4(A)); and containcontaining a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

*** DOE’s proposed definitions for “indoor” and “outdoor” metal halide lamp fixtures are described in section V.A.2.

† P is defined as the rated wattage of the lamp the fixture is designed to operate.

‡Input voltage for testing would be specified by the test procedureprocedures. Ballasts rated to operate lamps less than 150 W 

would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at 

either of these voltages would be tested at the highest voltage the ballast is designed to operate.

VII. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

Section 1(b)(1) of E.O. 12866, “Regulatory Planning and Review,” 58 FR 51735 

(Oct. 4, 1993), requires each agency to identify the problem that it intends to address, 

including, where applicable, the failures of private markets or public institutions that 

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warrant new agency action, as well as to assess the significance of that problem. The 

problems addressed by today’s standards are as follows: 

(1) There is a lack of consumercustomer information and/or informationprocessing capability about energy-efficiency opportunities in the commercial 

equipment market.

(2) There is asymmetric information (one party to a transaction has more and 

better information than the other) and/or high transactionstransaction costs 

(costs of gathering information and effectingaffecting exchanges of goods and 

services).

(3) There are external benefits resulting from improved energy efficiency of 

metal halide lamp fixtures that are not captured by the users of such 

equipment. These benefits include externalities related to environmental 

protection and energy security that are not reflected in energy prices, such as 

reduced emissions of greenhouse gases.

In addition, DOE has determined that today’s regulatory action is an 

“economically significant regulatory action” under section 3(f)(1) of E.O. 12866. 

Accordingly, section 6(a)(3) of the E.O. requires that DOE prepare a regulatory impact 

analysis (RIA) on today’s proposed rule and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) review this 

proposed rule. DOE presented to OIRA for review the draft rule and other documents 

prepared for this rulemaking, including the RIA, and has included these documents in the 

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rulemaking record. The assessments prepared pursuant to E.O. 12866 can be found in the 

technical support document for this rulemaking.

DOE has also reviewed this regulation pursuant to E.O. 13563, issued on January 

18, 2011 (76 FR 3281 (Jan. 21, 2011)). E.O. 13563 is supplemental to and explicitly 

reaffirms the principles, structures, and definitions governing regulatory review 

established in E.O. 12866. To the extent permitted by law, agencies are required by E.O.

13563 to: (1) propose or adopt a regulation only upon a reasoned determination that its 

benefits justify its costs (recognizing that some benefits and costs are difficult to 

quantify); (2) tailor regulations to impose the least burden on society, consistent with 

obtaining regulatory objectives, taking into account, among other things, and to the extent 

practicable, the costs of cumulative regulations; (3) select, in choosing among alternative 

regulatory approaches, those approaches that maximize net benefits (including potential 

economic, environmental, public health and safety, and other advantages; distributive 

impacts; and equity); (4) to the extent feasible, specify performance objectives, rather 

than specifying the behavior or manner of compliance that regulated entities must adopt; 

and (5) identify and assess available alternatives to direct regulation, including providing 

economic incentives to encourage the desired behavior, such as user fees or marketable 

permits, or providing information upon which choices can be made by the public.

DOE emphasizes, as well, that E.O. 13563 requires agencies to use the best 

available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, OIRA has emphasized that such techniques may 

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include identifying changing future compliance costs that might result from technological 

innovation or anticipated behavioral changes. For the reasons stated in the preamble, 

DOE believes that today’s NOPR is consistent with these principles, including the 

requirements that, to the extent permitted by law, benefits justify costs and net benefits 

are maximized.

B. Review Under the Regulatory Flexibility Act

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that, by law, must be proposed 

for public comment, unless the agency certifies that the rule, if promulgated, will not 

have a significant economic impact on a substantial number of small entities. As required 

by E. O. 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” (67 FR 

53461 (Aug. 16, 2002)), DOE published procedures and policies on February 19, 2003, to 

ensure that the potential impacts of its rules on small entities are properly considered 

during the rulemaking process. (68 FR 7990) DOE has made its procedures and policies 

available on the Office of the General Counsel’s website (http://energy.gov/gc/officegeneral-counsel). DOE reviewed the potential standard levels considered in today’s 

NOPR under the provisions of the Regulatory Flexibility Act and the procedures and 

policies published on February 19, 2003.

As a result of this review, DOE has prepared an IRFA for metal halide ballasts 

and metal halide lamp fixtures, a copy of which DOE will transmit to the Chief Counsel 

for Advocacy of the SBA for review under 5 U.S.C 605(b). As presented and discussed 

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below, the IRFA describes potential impacts on small metal halide ballast and metal 

halide lamp fixture manufacturers and discusses alternatives that could minimize these 

impacts.

A statement of the reasons for the proposed rule, and the objectives of and legal 

basis for the proposed rule, are set forth elsewhere in the preamble and not repeated here.

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

For manufacturers of metal halide ballasts and metal halide lamp fixtures, the 

SBA has set a size threshold which defines those entities classified as “small businesses” 

for the purposes of the statute. DOE used the SBA’s small business size standards to 

determine whether any small entities would be subject to the requirements of the rule. (65 

FR 30836, 30850 (May 15, 2000), as amended at 65 FR 53533, 53545 (Sept. 5, 2000) and 

codified at 13 CFR part 121) The size standards are listed by North American Industry 

Classification System (NAICS) code and industry description and are available at 

http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. Metal halide 

ballast manufacturing is classified under NAICS 335311, “Power, Distribution and 

Specialty Transformer Manufacturing.” The SBA sets a threshold of 750 employees or 

less for an entity to be considered as a small business for this category. Metal halide lamp 

fixture manufacturing is classified under NAICS 335122, “Commercial, Industrial, and 

Institutional Electric Lighting Fixture Manufacturing.” The SBA sets a threshold of 500 

employees or less for an entity to be considered as a small business for this category.

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To estimate the number of companies that could be small business manufacturers 

of equipment covered by this rulemaking, DOE conducted a market survey using all 

available public information to identify potential small manufacturers. DOE’s research 

involved industry trade association membership directories (including NEMA), 

individual company websites, and market research tools (e.g., Dun and Bradstreet reports 

and Hoovers reports) to create a list of every company that manufactures or sells metal 

halide ballasts or metal halide lamp fixtures covered by this rulemaking. DOE also asked 

stakeholders and industry representatives if they were aware of any other small 

manufacturers during manufacturer interviews and at previous DOE public meetings. 

DOE contacted companies on its list, as necessary, to determine whether they met the 

SBA’s definition of a small business manufacturer of covered equipment. DOE screened 

out companies that did not offer equipment covered by this rulemaking, did not meet the 

definition of a “small business,” or were foreign owned and operated.

DOE initially identified at least 25 potential manufacturers of metal halide 

ballasts sold in the U.S. DOE reviewed publicly available information on these 25 

potential manufacturers and determined that 13 were either large manufacturers, 

manufacturers that were foreign owned and operated, or did not manufacture ballasts 

covered by this rulemaking. DOE then attempted to contact the remaining 12 companies 

that were potential small business manufacturers. DOE was able to determine that five 

companies meet the SBA’s definition of a small business and likely manufacture ballasts 

covered by this rulemaking.

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For metal halide lamp fixtures sold in the U.S., DOE initially identified at least 

134 potential manufacturers. DOE reviewed publicly available information on these 134 

potential manufacturers and determined that 66 were large manufacturers, manufacturers 

that were foreign owned and operated, or did not sell fixtures covered by this rulemaking. 

DOE then attempted to contact the remaining 68 companies that were potential small 

business manufacturers. Though many companies were unresponsive, DOE was able to 

determine that approximately 54 meet the SBA’s definition of a small business and likely 

manufacture fixtures covered by this rulemaking.

NEMA stated that small manufacturers may be significantly burdened by energy 

conservation standards because they have limited resources at their disposal to redesign 

products. (NEMA, No. 34 at p. 16) DOE agrees that there is potential for small 

manufacturers to be disproportionately burdened by regulations and outlines its 

conclusions on the potential impacts of standards on small businesses in the sections that 

follow.

b. Manufacturer Participation

Before issuing this NOPR, DOE attempted to contact the small business 

manufacturers of metal halide ballasts and metal halide lamp fixtures it had identified. 

One small ballast manufacturer and two small fixture manufacturers consented to being 

interviewed. DOE also obtained information about small business impacts while 

interviewing large manufacturers.

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c. Metal Halide Ballast and Fixture Industry Structure

Ballasts. Five major ballast manufacturers with limited domestic production 

supply the vast majority of the metal halide ballast market. None of the five major 

manufacturers is a small business. The remaining market share is held by a few smaller 

domestic companies, only one of which has significant market share. Nearly all metal 

halide ballast production occurs abroad.

Fixtures. The majority of the metal halide lamp fixture market is supplied by six 

major manufacturers with sizeable domestic production. None of these major 

manufacturers is a small business. The remaining market share is held by several smaller 

domestic and foreign manufacturers. Most of the small domestic manufacturers produce 

fixtures in the U.S. Although none of the small businesses holds a significant market 

share individually, collectively these small businesses account for a third of the market. 

See chapter 3 of the NOPR TSD for further details on the metal halide ballast and metal 

halide lamp fixture markets.

d. Comparison Between Large and Small Entities

Ballasts. The five large ballast manufacturers typically offer a much wider range 

of designs of metal halide ballasts than small manufacturers do. Ballasts can vary by start 

method, input voltage, wattage, and design. Often large ballast manufacturers will offer 

several different ballast options for each lamp wattage. Small manufacturers generally 

specialize in manufacturing only a handful of different ballast types and do not have the 

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volume to support as wide a range of products as large manufacturers do. Three of the 

five small ballast manufacturers specialize in high-efficiency electronic ballasts and do 

not offer any magnetic ballasts. Some small ballast manufacturers offer a wide variety of 

lighting products, but others focus exclusively on metal halide ballasts.

Fixtures. The six large fixture manufacturers typically serve large-scale 

commercial lighting markets, while small fixture manufacturers tend to operate in niche 

lighting markets such as architectural and designer lighting. Small fixture manufacturers 

also frequently fill custom orders that are much smaller in volume than large fixture 

manufacturers’ typical orders are. Because small manufacturers typically offer 

specialized products and cater to individual customers’ needs, they can command higher 

markups than most large manufacturers. Like large ballast manufacturers, large fixture 

manufacturers offer a wider range of metal halide lamp fixtures than small fixture 

manufacturers. A small fixture manufacturer may offer fewer than 50 models, while a 

large manufacturer may typically offer several hundred models. Almost all small fixture 

manufacturers offer a variety of lighting products in addition to those covered by this 

rulemaking, such as fluorescent, incandescent, and LED fixtures.

2. Description and Estimate of Compliance Requirements 

Ballasts. Because three of the five small metal halide ballast manufacturers offer 

only electronic ballasts that already meet the standards at TSL 3, the level proposed in 

today’s notice, DOE does not expect any product or capital conversion costs for these 

small ballast manufacturers. The fourth small ballast manufacturer offers a wide range of 

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magnetic and electronic ballasts, so DOE does not expect this manufacturer’s conversion 

costs to differ significantly from those of the large manufacturers. The fifth small ballast 

manufacturer currently offers a large variety of lighting products, but only two models of 

metal halide ballasts. Because it would likely invest in other parts of its business, this 

manufacturer stated to DOE that this rulemaking is unlikely to significantly affect it.

Fixtures. As stated above, DOE identified approximately 54 small metal halide 

lamp fixture businesses affected by this rulemaking. Based on interviews with two of 

these manufacturers and examinations of product offerings on company websites, DOE 

believes that approximately one-fourth of these small businesses will not face any 

conversion costs because they offer very few metal halide lamp fixture models and 

would, therefore, focus on more substantial areas of their business. Of the remaining 

small businesses DOE identified, nearly two-thirds primarily serve the architectural or 

specialty lighting markets. Because these products command higher prices and margins 

compared to the typical products offered by a large manufacturer, DOE believes that 

these small fixture manufacturers will be able to pass on any necessary conversion costs 

to their customers without significantly impacting their businesses.

The remaining small fixture manufacturers (roughly 14 in number) could be 

differentially impacted by today’s proposed standards. These manufacturers operate 

partially in industrial and commoditized markets in which it may be more difficult to pass 

on any disproportionate costs to their consumerscustomers. The impacts could be 

relatively greater for a typical small manufacturer because of the far lower production 

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volumes and the relatively fixed nature of the R&D and capital resources required per 

fixture family.

Based on interviews, however, DOE anticipates that small manufacturers would 

take steps to mitigate the costs required to meet new and amended energy conservation 

standards. At TSL 3, DOE believes that under the proposed standards, small fixture 

businesses would likely selectively upgrade existing product lines to offer products that 

are in high demand or offer strategic advantage. Small manufacturers could then spread 

out further investments over a longer time period by not upgrading all product lines prior 

to the compliance date.

Additionally, DOE does not expect that small fixture manufacturers would be 

burdened by compliance requirements. As discussed in section IV.A, the standards 

proposed in this NOPR provide simplifying amendments to the current testing and 

reporting procedures. One of DOE’s goals in this rulemaking was to have minimal, if 

any, increase in testing and reporting burden on manufacturers. DOE is only mandating 

testing at a single input voltage for metal halide lamp fixtures. Other options considered 

would have increased testing to either two or four input voltages per fixture. Because 

DOE selected the least burdensome input voltage option, DOE concludes that regulations 

in this NOPR would not have an adverse impact on the testing burden of small 

manufacturers.

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The existing test procedures already dictate that testing for certification requires a 

sample of at least four fixtures for compliance. DOE is not proposing to change this 

minimum sample size, and as such, does not find an increased testing burden on small 

manufacturers.

As discussed in section IV.A, DOE is amending the test procedures to mandate 

the equipment with which high-frequency electronic ballasts are to be tested, since 

existing test procedures prescribe test instrumentation only for magnetic and lowfrequency electronic ballasts. DOE proposes that any equipment be permitted for testing 

the output frequency of the ballast. Once it is determined that a fixture’s output frequency 

is greater than or equal to 1000 Hz, the frequency at which DOE proposes to define highfrequency electronic ballasts, the test procedures would require equipment to consist of 

(1) a power analyzer that conforms to ANSI C82.6-2005 with a maximum of 100 pF 

capacitance to ground and frequency response between 40 Hz and 1 MHz, (2) a current 

probe compliant with ANSI C82.6-2005 that is galvanically isolated and has a frequency 

response between 40 Hz and 20 MHz, and (3) a lamp current measurement device where 

its full transducer ratio is set in the power analyzer to match the current probe to the 

analyzer. DOE finds that these test requirements do not affect small manufacturers, 

noting that the equipment described above is the same equipment that is already required 

for the testing of fluorescent lamp ballasts. Because many lighting companies that 

manufacture or sell metal halide ballasts also manufacture or sell fluorescent lamp 

ballasts, this proposed change to the test procedures should not affect manufacturers’

testing burden or costs. In addition, DOE believes that the equipment specified for high366
frequency electronic ballast testing is representative of typical high-quality equipment 

currently used by manufacturers in the business of designing and selling these ballasts.

DOE seeks comment on the potential impacts of new and amended standards on 

the small metal halide ballast and metal halide lamp fixture manufacturers.

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being considered today.

4. Significant Alternatives to the Proposed Rule 

The discussion above analyzes impacts on small businesses that would result from 

the other TSLs DOE considered. Though TSLs lower than the proposed TSLs are 

expected to reduce the impacts on small entities, DOE is required by EPCA to establish 

standards that achieve the maximum improvement in energy efficiency that are 

technically feasible and economically justified, and result in significant conservation of 

energy. Thus, DOE rejected the lower TSLs.

In addition to the other TSLs being considered, the NOPR TSD includes a 

regulatory impact analysis in chapter 18. For metal halide lamp fixtures, this report 

discusses the following policy alternatives: (1) no standard, (2) consumercustomer

rebates, (3) consumercustomer tax credits, (4) manufacturer tax credits, and (5) early 

replacement. DOE does not intend to consider these alternatives further because they are 

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either not feasible to implement, or not expected to result in energy savings as large as 

those that would be achieved by the standard levels under consideration.

DOE continues to seek input from businesses that would be affected by this 

rulemaking and will consider comments received in the development of any final rule.

C. Review Under the Paperwork Reduction Act

Manufacturers of metal halide lamp fixtures must certify to DOE that their 

equipment complies with any applicable energy conservation standard. In certifying 

compliance, manufacturers must test their equipment according to the DOE test 

procedures for metal halide lamp fixtures, including any amendments adopted for those 

test procedures. DOE has established regulations for the certification and recordkeeping 

requirements for all covered consumercustomer products and commercial equipment, 

including metal halide lamp fixtures. 76 FR 12422 (March 7, 2011). The collection-ofinformation requirement for certification and recordkeeping is subject to review and 

approval by OMB under the Paperwork Reduction Act (PRA). This requirement has been 

approved by OMB under OMB control number 1910-1400. Public reporting burden for 

the certification is estimated to average 20 hours per response, including the time for 

reviewing instructions, searching existing data sources, gathering and maintaining the 

data needed, and completing and reviewing the collection of information.

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

368
information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number. 

D. Review Under the National Environmental Policy Act of 1969 

Pursuant to the National Environmental Policy Act (NEPA) of 1969, DOE has 

determined that the proposed rule fits within the category of actions included in 

Categorical Exclusion (CX) B5.1 and otherwise meets the requirements for application of 

a CX. See 10 CFR part 1021, appendix. B, B5.1(b); 1021.410(b) and appendix B, B(1)-

(5). The proposed rule fits within the category of actions because it is a rulemaking that 

establishes energy conservation standards for consumer products or industrial equipment, 

and for which none of the exceptions identified in CX B5.1(b) apply. Therefore, DOE has 

made a CX determination for this rulemaking, and DOE does not need to prepare an 

Environmental Assessment or Environmental Impact Statement for this proposed rule. 

CX determination for this proposed rule is available at http://cxnepa.energy.gov DOE 

has prepared a draft environmental assessment (EA) of the impacts of the proposed rule 

pursuant to the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.), the 

regulations of the Council on Environmental Quality (40 CFR parts 1500–1508), and 

DOE’s regulations for compliance with the National Environmental Policy Act of 1969 

(10 CFR part 1021). This assessment includes an examination of the potential effects of 

emission reductions likely to result from the rule in the context of global climate change, 

as well as other types of environmental impacts. The draft EA has been incorporated into 

the NOPR TSD as chapter 16. Before issuing a final rule for metal halide lamp fixtures, 

DOE will consider public comments and, as appropriate, determine whether to issue a 

369
finding of no significant impact (FONSI) as part of a final EA or to prepare an 

environmental impact statement (EIS) for this rulemaking.

.

E. Review Under Executive Order 13132

Executive Order 13132, “Federalism,” 64 FR 43255 (Aug. 10, 1999), imposes 

certain requirements on Federal agencies formulating and implementing policies or 

regulations that preempt state law or that have Federalism implications. The E.O. requires 

agencies to examine the constitutional and statutory authority supporting any action that 

would limit the policymaking discretion of the states and to carefully assess the necessity 

for such actions. The E.O. also requires agencies to have an accountable process to 

ensure meaningful and timely input by state and local officials in the development of 

regulatory policies that have Federalism implications. On March 14, 2000, DOE 

published a statement of policy describing the intergovernmental consultation process it 

will follow in the development of such regulations. 65 FR 13735. EPCA governs and 

prescribes Federal preemption of state regulations as to energy conservation for the 

products that are the subject of today’s proposed rule. States can petition DOE for 

exemption from such preemption to the extent, and based on criteria, set forth in EPCA. 

(42 U.S.C. 6297) No further action is required by E.O. 13132.

F. Review Under Executive Order 12988

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of E.O. 12988, “Civil Justice Reform,” imposes on Federal 

370
agencies the general duty to adhere to the following requirements: (1) eliminate drafting 

errors and ambiguity; (2) write regulations to minimize litigation; and (3) provide a clear 

legal standard for affected conduct rather than a general standard and promote 

simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

E.O.12988 specifically requires that Executive agencies make every reasonable effort to 

ensure that the regulation: (1) clearly specifies the preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal law or regulation; (3) provides a clear legal 

standard for affected conduct while promoting simplification and burden reduction; (4) 

specifies the retroactive effect, if any; (5) adequately defines key terms; and (6) addresses 

other important issues affecting clarity and general draftsmanship under any guidelines 

issued by the Attorney General. Section 3(c) of E.O. 12988 requires Executive agencies 

to review regulations in light of applicable standards in section 3(a) and section 3(b) to 

determine whether they are met or it is unreasonable to meet one or more of them. DOE 

has completed the required review and determined that, to the extent permitted by law, 

this proposed rule meets the relevant standards of E.O. 12988.

G. Review Under the Unfunded Mandates Reform Act of 1995

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on state, local, and 

tribal governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 

1531). For a proposed regulatory action likely to result in a rule that may cause the 

expenditure by state, local, and tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

371
202 of UMRA requires a Federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 1532(a), 

(b)) UMRA also requires a Federal agency to develop an effective process to permit 

timely input by elected officers of state, local, and tribal governments on a proposed

“significant intergovernmental mandate,” and requires an agency plan for giving notice 

and opportunity for timely input to potentially affected small governments before 

establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820. DOE’s policy statement is 

also available at www.gc.energy.gov.

Although today’s proposed rule does not contain a Federal intergovernmental 

mandate, it may require expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could require 

expenditures of $100 million or more. Such expenditures may include: (1) investment in 

research and development and capital expenditures by metal halide lamp fixture

manufacturers in the years between the final rule and the compliance date for the new 

standards, and (2) incremental additional expenditures by consumerscustomers to 

purchase higher-efficiency metal halide lamp fixtures, starting at the compliance date for 

the applicable standard.

Section 202 of UMRA authorizes a Federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

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rule. (2 U.S.C. 1532(c)) The content requirements of section 202(b) of UMRA relevant to 

a private-sector mandate substantially overlap with the economic analysis requirements 

that apply under section 325(o) of EPCA and E.O. 12866. The SUPPLEMENTARY 

INFORMATION section of this NOPR and the “Regulatory Impact Analysis” section of 

the NOPR TSD for this proposed rule respond to those requirements. 

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. (2 U.S.C. 1535(a)) DOE is required to 

select from those alternatives the most cost-effective and least-burdensome alternative 

that achieves the objectives of the proposed rule unless DOE publishes an explanation for 

doing otherwise, or the selection of such an alternative is inconsistent with law. As 

required by 42 U.S.C. 6295(d), (f), and (o), 6313(e), and 6316(a), today’s proposed rule 

would establish energy conservation standards for metal halide lamp fixtures that are 

designed to achieve the maximum improvement in energy efficiency that DOE has 

determined to be both technologically feasible and economically justified. A full 

discussion of the alternatives considered by DOE is presented in the “Regulatory Impact 

Analysis” section of the NOPR TSD for today’s proposed rule.

H. Review Under the Treasury and General Government Appropriations Act, 1999

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This rule would not have any impact on 

373
the autonomy or integrity of the family as an institution. Accordingly, DOE has 

concluded that it is not necessary to prepare a Family Policymaking Assessment.

I. Review Under Executive Order 12630

DOE has determined, under E. O. 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (Mar. 18, 

1988), that this regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

J. Review Under the Treasury and General Government Appropriations Act, 2001

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for Federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed today’s NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines.

K. Review Under Executive Order 13211

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

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any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that: (1) is a significant regulatory action under E.O. 12866, or any successor 

order; and (2) is likely to have a significant adverse effect on the supply, distribution, or 

use of energy, or (3) is designated by the Administrator of OIRA as a significant energy 

action. For any proposed significant energy action, the agency must give a detailed 

statement of any adverse effects on energy supply, distribution, or use should the 

proposal be implemented, and of reasonable alternatives to the action and their expected 

benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that today’s regulatory action, which sets forth 

energy conservation standards for metal halide lamp fixtures, is not a significant energy 

action because the proposed standards are not likely to have a significant adverse effect 

on the supply, distribution, or use of energy, nor has it been designated as such by the 

Administrator at OIRA. Accordingly, DOE has not prepared a Statement of Energy 

Effects on the proposed rule.

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the bulletin is to enhance the quality and credibility of 

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the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as “scientific information the agency reasonably can determine will have or does 

have a clear and substantial impact on important public policies or private sector 

decisions.” 70 FR 2667.

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report” dated February 2007 

has been disseminated and is available at the following Web site: 

www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.

VIII. Public Participation

A. Attendance at the Public Meeting

The time, date, and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this notice. If you plan to attend the public 

meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or 

Brenda.Edwards@ee.doe.gov. As explained in the ADDRESSES section, foreign 

376
nationals visiting DOE Headquarters are subject to advance security screening 

procedures.

In addition, you can attend the public meeting via webinar. Webinar registration 

information, participant instructions, and information about the capabilities available to 

webinar participants will be published on DOE’s website at: 

www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/49.

Participants are responsible for ensuring that their systems are compatible with the 

webinar software.

B. Procedure for Submitting Prepared General Statements For Distribution

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make follow-up contact, if needed.

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C. Conduct of the Public Meeting

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period.

The public meeting will be conducted in an informal, conference style. DOE will 

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will allow, as time permits, other participants to comment briefly on 

any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

378
accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting.

A transcript of the public meeting will be included in the docket, which can be 

viewed as described in the Docket section at the beginning of this notice. In addition, any 

person may buy a copy of the transcript from the transcribing reporter. 

D. Submission of Comments

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments, 

data, and other information using any of the methods described in the ADDRESSES 

section at the beginning of this notice.

Submitting comments via regulations.gov. The regulations.gov web page will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

submitter representative name (if any). If your comment is not processed properly 

because of technical difficulties, DOE will use this information to contact you. If DOE 

cannot read your comment due to technical difficulties and cannot contact you for 

clarification, DOE may not be able to consider your comment.

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However, your contact information will be publicly viewable if you include it in 

the comment itself or in any documents attached to your comment. Any information that 

you do not want to be publicly viewable should not be included in your comment, nor in 

any document attached to your comment. Otherwise, persons viewing comments will see 

only first and last names, organization names, correspondence containing comments, and 

any documents submitted with the comments. 

Do not submit to regulations.gov information for which disclosure is restricted by 

statute, such as trade secrets and commercial or financial information (hereinafter 

referred to as Confidential Business Information (CBI)). Comments submitted through 

regulations.gov cannot be claimed as CBI. Comments received through the website will 

waive any CBI claims for the information submitted. For information on submitting CBI, 

see the Confidential Business Information section below.

DOE processes submissions made through regulations.gov before posting. 

Normally, comments will be posted within a few days of being submitted. However, if 

large volumes of comments are being processed simultaneously, your comment may not 

be viewable for up to several weeks. Please keep the comment tracking number that 

regulations.gov provides after you have successfully uploaded your comment. 

Submitting comments via email, hand delivery/courier, or mail. Comments and 

documents submitted via email, hand delivery, or mail also will be posted to 

380
regulations.gov. If you do not want your personal contact information to be publicly 

viewable, do not include it in your comment or any accompanying documents. Instead, 

provide your contact information in a cover letter. Include your first and last names, 

email address, telephone number, and optional mailing address. The cover letter will not 

be publicly viewable as long as it does not include any comments

Include contact information each time you submit comments, data, documents, 

and other information to DOE. Email submissions are preferred. If you submit via mail or 

hand delivery/courier, please provide all items on a CD, if feasible. It is not necessary to 

submit printed copies. No facsimiles (faxes) will be accepted.

Comments, data, and other information submitted to DOE electronically should 

be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) 

file format. Provide documents that are not secured, that are written in English, and that 

are free of any defects or viruses. Documents should not contain special characters or any 

form of encryption and, if possible, they should carry the electronic signature of the 

author.

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter 

with a list of supporters’ names compiled into one or more PDFs. This reduces comment 

processing and posting time. 

381
Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

public disclosure should submit via email, postal mail, or hand delivery/courier two wellmarked copies: one copy of the document marked confidential including all the 

information believed to be confidential, and one copy of the document marked nonconfidential with the information believed to be confidential deleted. Submit these 

documents via email or on a CD, if feasible. DOE will make its own determination about 

the confidential status of the information and treat it according to its determination.

Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) a description of the items; (2) whether and why 

such items are customarily treated as confidential within the industry; (3) whether the 

information is generally known by or available from other sources; (4) whether the 

information has previously been made available to others without obligation concerning 

its confidentiality; (5) an explanation of the competitive injury to the submitting person 

which would result from public disclosure; (6) when such information might lose its 

confidential character due to the passage of time; and (7) why disclosure of the 

information would be contrary to the public interest.

It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 

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E. Issues on Which DOE Seeks Comment

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues: 

1. The appropriateness of continuing the exemption of regulated-lag ballasts;

2. The exclusion of dedicated 480 V electronic ballasts in the scope of this 

rulemaking; 

3. The inclusion of ballasts that are rated only for used with 150 W lamps, use in 

wet locations, and operation in ambient air temperature higher than 50 °C in 

the scope of this rulemaking; 

4. The expansion of coverage of this rulemaking to include metal halide lamp 

fixtures that operate lamps rated greater than or equal to 50 W and less than or 

equal to 150 W, and fixtures that operate lamps rated greater than 500 W and 

less than or equal to 2000 W; 

5. The decision that fixtures above 1000 W are available for general lighting 

applications and are thus covered by this rulemaking;

5.6.The appropriateness of setting efficiency standards for metal halide lamp 

fixtures based on ballast efficiency;

6.7.The appropriateness of the proposed amendments to the testing procedure, 

especially the specification of input voltage, high-frequency test 

instrumentation, and rounding requirements;

7.8.The appropriateness of DOE testing metal halide lamp fixtures at a single 

input voltage, based on the lamp wattage operated by the ballast;

Comment [AGA36]: Revised at the request of 

OIRA.

383
8.9.The appropriateness of placing indoor and outdoor fixtures into separate 

equipment classes;

9.10. How to best combine the HID lamp and MHLF energy conservation 

standards; 

10.11. The technological feasibility of the max tech levels selected, specifically 

data on the potential change in efficiency, the design options employed, and 

the associated change in cost; 

11.12. Any technological barriers to an improvement in efficiency above the max

-tech efficiency levels for all or certain types of ballasts; 

12.13. The appropriateness of separate equipment classes for ballasts tested at 

480 V (in accordance with the test procedures); 

13.14. The appropriateness of not dividing equipment classes by electronic 

configuration or circuit type; 

14.15. The suitability of defining equipment class by the rated lamp wattage 

ranges ≥50 W to ≤100 W, >100 W to ≤150 W, ≥150 W to ≤250 W, >250 W to 

≤500 W, and >500 W to ≤2000 W, specially the inclusion of 150 W fixtures 

previously exempted by EISA 2007 in the >100 W and ≤150 W range, and 

150 W fixtures subject to EISA 2007 standards in the ≥150 W to ≤250 W 

range;

15.16. The appropriateness of the equipment classes proposed in this NOPR; 

17. The assumption that there will be no lessening of utility or performance such 

that the physical size, including footprint, stack height, and weight, would be 

384
adversely affected for the magnetic ballast efficiencies associated with

efficiency levels based on modeled ballasts;

16.18. The appropriateness of the design options selected by the screening 

analysis presented in this NOPR;

17.19. The possibility of setting a standard that requires a high-frequency ballast; 

18.20. The issue of operating a lamp at wattages greater or less than its rating and 

its effect on ballast efficiency or lamp efficacy;

19.21. The analysis method of applying a 5.5 percent increase when calculating 

the representative input power of magnetic ballasts to account for the increase 

in wattage over a ballast’s lifetime;

22. The addition of the electronic 70 W baseline ballast; 

23. The possibility of high-frequency electronic ballasts requiring additional 

thermal and transient protection relative to low-frequency electronic ballasts 

and, if so, the technical reasons for this difference and whether ballast or 

fixture redesigns can overcome these barriers; 

20.24. The appropriateness of the efficiency levels proposed in this NOPR and 

whether or not an adjustment is needed for sources of variation not currently 

captured by the methodology; 

21.25. The proposal to apply a scaling factor of 0.6 percent to the efficiency 

levels for quad-volt ballasts to determine the appropriate values for 480 V 

ballasts;

26. The determination to include a design standard that would prohibit the sale of 

probe-start ballasts in newly sold fixtures, the proposed methods of analyzing 

Comment [AGA37]: Revised at the request of 

OIRA.

Comment [AGA38]: Revised at the request of 

OIRA.

385
these levels, and the potential for any lessening of the utility or the 

performance through the prohibition of the sale of probe-start ballasts in 

newly sold fixtures;

22.27. The applicability and appropriateness of the adder to MPC of electronic 

ballasts for 120 V auxiliary tappower functionality and the adders to the MPC 

of fixtures with electronic ballasts for thermal management and transient 

protection; 

23.28. The appropriateness of the derived MSPs presented in this NOPR;

29. Methods to improve itsDOE’s energy use analysis, as well as any data 

supporting alternate operating hour estimates or assumptions regarding fixture 

dimming;

30. The impact and feasibility of a compliance date of January 1, 2015;

31. The assumptions and methodology for estimating annual operating hours, 

which were based on data from the 2010 U.S. Lighting Market 

Characterization, and assumed to be 3,615 hours per year in the commercial 

sector, 6,113 hours per year in the industrial sector, and 4,493 hours per year 

for the outdoor stationary sector;

24.32. Methods to improve DOE’s fixture price forecastingprojections beyond 

the assumption of constant real prices, as well as any data supporting alternate 

methods;

33. The reasonableness of assuming a zero percent rebound effect (the tendency 

for customers to increase MHLF usage in response to life-cycle cost savings 

associated with more efficient ballasts used in new fixtures);

Comment [AGA39]: Revised at the request of 

OIRA.

Comment [AGA40]: Revised at the request of 

OIRA.

Comment [AGA41]: Revised at the request of 

OIRA.

386
34. Whether the shipment scenarios under various policy scenarios are reasonable 

and likely to occur;

35. The impediments that prevent users of metal halide lamp fixtures from 

switching to LED lighting to garner further energy savings;

36. The expected impact of new and revised standards on the rate at which MHLF 

customers transition to non-MHLF technology;

37. The methodology applied to determine the product and capital conversion 

costs;

38. The degree to which the manufacturers’ ability to recoup investment, 

combined with the opportunity cost of investment, would encourage 

manufacturers to exit the metal halide lamp fixture market;

25.39. The appropriateness of proposed trial standard levels;

1) How to assess the possibilities for both welfare gains and losses using a fuller 

economic framework where all relevant changes can be quantified; 

40. The presence of features or attributes of the more energy efficient ballasts 

used in new fixtures that manufacturers would produce to meet the standards 

in this proposed rule that might affect the welfare, positively or negatively, of 

customers who purchase metal halide lamp fixtures;

41. The possibility that the more widespread use of electronic ballasts would 

involve any performance or reliability effects for either 70-watt or 150-watt 

fixtures, and how any such effects should be weighed in the choice of 

standards for these two wattage categories for the final rule;

Comment [AGA42]: Revised at the request of 

OIRA.

Comment [AGA43]: Revised at the request of 

OIRA.

387
26.42. The appropriateness of choosing TSL 3 energy conservation standards;

and

27.43. The potential impacts of new and amended standards on the small metal 

halide ballast and metal halide lamp fixture manufacturers.

IX. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of today’s proposed rule.

List of Subjects in 10 CFR Part 430431

Administrative practice and procedure, Confidential business information, Energy 

conservation, Household appliances, Imports, Intergovernmental relations, Reporting and 

recordkeeping requirements, and Small businesses. 

Issued in Washington, DC, on 

________________________________

Henry Kelly

Acting David T. Danielson

Assistant Secretary of Energy

Energy Efficiency and Renewable Energy

388
For the reasons set forth in the preamble, DOE proposes to amend part 431, subpart S, of 

Chapter II, subchapter D of title 10 of the Code of Federal Regulations, as set forth 

below:

PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

1. The authority citation for part 431 continues to read as follows: 

Authority: 42 U.S.C. 6291–6317.

2. 2. Section 431.322 is amended by :

adding in alphabetical order a definitiondefinitions for “general lighting application,” 

“high-frequency electronic metal halide ballast.,” and “nonpulse-start electronic 

ballast,” to read as follows:

§ 431.322 Definitions concerning metal halide ballasts and fixtures.

* * * * *

General lighting application means lighting that provides an interior or exterior area with 

overall illumination.

High-frequency electronic metal halide ballast means an electronic ballast that operates a 

lamp at an output frequency of 1000 Hz or greater.

* * * * *

Nonpulse-start electronic ballast means an electronic ballast with a starting method other 

than pulse-start.

389
* * * * *

3. Section 431.324 is amended by: 

a. Revising paragraphs (b)(1)(i), (b)(3) and (c)(1)(i).); and

b. Adding paragraphs (b)(1)(iii), and (b)(1)(iv), (c)(1)(ii), and (c)(1)(iii)).

The additions and revisions read as follows:

§431.324 Uniform test method for the measurement of energy efficiency and 

standby mode energy consumption of metal halide ballasts.

* * * * *

(b) Testing and Calculations Active Mode. * * * 

(1)() * * *

(i) Test Conditions. The power supply, ballast test conditions (with the exception of input 

voltage), lamp position, lamp stabilization, and test instrumentation except as specified in 

sectionparagraph (b)(1)(iii) of this section shall all conform to the requirements specified 

in section 4.0, “General Conditions for Electrical Performance Tests,” of ANSI C82.6 

(incorporated by reference; see §431.323). Ambient temperatures for the testing period 

shall be maintained at 25 °C ± 5 °C. Airflow in the room for the testing period shall be 

≤0.5 meters/second. The ballast shall be operated until equilibrium. Lamps used in the 

test shall conform to the general requirements in section 4.4.1 of ANSI C82.6 and be 

seasoned for a minimum of 100 hours prior to use in ballast tests. Basic lamp stabilization 

shall conform to the general requirements in section 4.4.2 of ANSI C82.6, and 

390
stabilization shall be reached when the lamp's electrical characteristics vary by no more 

than 3-percent in three consecutive 10- to 15-minute intervals measured after the 

minimum burning time of 30 minutes. After the stabilization process has begun, the lamp 

shall not be moved or repositioned until after the testing is complete. In order to avoid 

heating up the test ballast during lamp stabilization, which could cause resistance changes 

and result in unrepeatable data, it is necessary to warm up the lamp on a standby ballast. 

This standby ballast should be a commercial ballast of a type similar to the test ballast in 

order to be able to switch a stabilized lamp to the test ballast without extinguishing the 

lamp. Fast-acting or make-before-break switches are recommended to prevent the lamps 

from extinguishing during switchover.

(ii) Alternative Stabilization Method. In cases where switching without extinguishing the

lamp is impossible or for low-frequency electronic ballasts, the following alternative 

stabilization method shall be used. The lamp characteristics are determined using a 

reference ballast and recorded for future comparison. The same lamp is to be driven by 

the ballast under test until the ballast reaches operational stability. Operational stability is 

defined by three consecutive measurements, 5 minutes apart, of the lamp power where 

the three readings are within 2.5 percent. The electrical measurements are to be taken 

within 5 minutes after conclusion of the stabilization period.

* * * * *

391
(iii) Instrumentation for High-Frequency Electronic Metal Halide Ballasts. If the output 

frequency of the ballast (frequency of power supplied to the lamp) is greater than 1000 

Hz, the testing instrumentation shall conform to the following sectionsparagraphs

(b)(1)(iii)(1A), (b)(1)(iii)(2B), and (b)(1)(iii)(3).C) of this section. Instrumentation for 

determination of the output frequency shall be compliant with section 4.0 of ANSI C82.6 

(incorporated by reference; see §431.323).

(1A) Power Analyzer. In addition to the specifications in ANSI C82.6, 

the power analyzer shall have a maximum 100 pF capacitance to ground and 

frequency response between 40 Hz and 1 MHz. 

(2B) Current Probe. In addition to the specifications in ANSI C82.6, 

the current probe shall be galvanically isolated and have frequency response 

between 40 Hz and 20 MHz.

(3C) Lamp Current. For the lamp current measurement, the full 

transducer ratio shall be set in the power analyzer to match the current probe to 

the power analyzer.

Full Transducer Ratio = Iin

Vout

× Rin

Rin+Rs

 Where:

Iin is current through the current transducer

Vout is the voltage out of the transducer

Rin is the power analyzer impedance

392
Rs is the current probe output impedance. 

(iv) Input Voltage for Tests. For ballasts designed to operate lamps rated less than 150 W 

that have 120 V as an available input voltage, testing shall be performed at 120 V. For 

ballasts designed to operate lamps rated less than 150 W that do not have 120 V as an 

available voltage, testing shall be performed at the highest available input voltage. For 

ballasts designed to operate lamps rated greater than or equal to 150 W that have 277 V 

as an available input voltage, testing shall be conducted at 277 V. For ballasts designed to 

operate lamps rated greater than or equal to 150 W that do not have 277 V as an available 

input voltage, testing shall be conducted at the highest available input voltage. 

* * * * *

(3) Efficiency Calculation. The measured lamp output power shall be divided by the 

ballast input power to determine the percent efficiency of the ballast under test to the 

nearest tenth of a percent.

(i) A fractional number at or above the midpoint between two consecutive decimal places 

shall be rounded up to the higher of the two decimal places; or

(ii) A fractional number below the midpoint between two consecutive decimal places 

shall be rounded down to the lower of the two decimal places.

393
(c)*) * * *

(1) Test Conditions. (i) The power supply, ballast test conditions with the exception of 

input voltage, and test instrumentation with the exception of high-frequency electronic 

ballasts shall all conform to the requirements specified in section 4.0, “General 

Conditions for Electrical Performance Tests,” of the ANSI C82.6 (incorporated by 

reference; see §431.323). Ambient temperatures for the testing period shall be maintained 

at 25 °C ± 5 °C. Send a signal to the ballast instructing it to have zero light output using 

the appropriate ballast communication protocol or system for the ballast being tested.

(ii) Input Voltage for Tests. For ballasts less than 150 W that have 120 V as an available 

input voltage, ballasts are to be tested at 120 V. For ballasts less than 150 W that do not 

have 120 V as an available voltage, ballasts are to be tested at the highest available input 

voltage. For ballasts greater than or equal to 150 W and less than or equal to 2000 W that 

have 277 V as an available input voltage, ballasts are to be tested at 277 V. For ballasts 

greater than or equal to 150 W and less than or equal to 2000 W that do not have 277 V 

as an available input voltage, ballasts are to be tested at the highest available input 

voltage. 

(iii) Instrumentation for High-Frequency Electronic Metal Halide Ballasts. Any 

instrumentation can be used to determine If the output frequency of athe ballast. If it is 

determined that the output (frequency of power supplied to the lamp) is greater than or 

equal to 1000 Hz, qualifying it as a high-frequency electronic ballast as specified by the 

definition of high-frequency electronic ballast in 431.322, then the testtesting 

394
instrumentation shall conform to paragraphs (b)(1)(iii)(A), (b)(1)(iii)(B), and 

(b)(1)(iii)(C) of this section. Instrumentation for high-frequency electronic ballasts shall 

conform to the following requirements: determination of the output frequency shall be 

compliant with section 4.0 of ANSI C82.6 (incorporated by reference; see §431.323).

(1A) Power Analyzer. In addition to the specifications in ANSI C82.6, the 

power analyzer shall have a maximum 100 pF capacitance to ground and frequency 

response between 40 Hz and 1 MHz. 

(2B) Current Probe. In addition to the specifications in ANSI C82.6, the 

current probe shall be galvanically isolated and have frequency response between 40 Hz 

and 20 MHz.

(3C) Lamp Current. For the lamp current measurement, the full transducer ratio 

shall be set in the power analyzer to match the current probe to the power analyzer.

Full Transducer Ratio = Iin

Vout

× Rin

Rin+Rs

 Where:

Iin is current through the current transducer

Vout is the voltage out of the transducer

Rin is the power analyzer impedance

Rs is the current probe output impedance. 

* * * * *

395
3. 3. Section 431.326 is amended by :

a) Revising paragraph (a); and

b) adding paragraphs (c), (d), (d)(1), and (d)(2).

The additions and revisionse) to read as follows:

§ 431.326 Energy conservation standards and their effective dates.

* * *

* * * * *

(c) Except when the requirements of paragraph (a) of this section are more stringent 

(i.e., require a larger minimum efficiency value) or as provided by paragraph (de) of this 

section, each metal halide lamp fixture manufactured on or after January 1, 2015 shall 

havecontain a metal halide ballast with an efficiency not less than the value determined 

from the appropriate equation in the following table:

396
Rated Lamp Wattage Tested Input Voltage

Type**‡‡

Minimum Standard Equation

%

≥50 W and ≤100 W Tested at 480 V 0.99499.4/(1+2.505∗P^(-0.55)) †††

≥50 W and ≤100 W All others 1100/(1+2.505∗P^(-0.55))

>100 W and <150† W Tested at 480 V 99.4/(1+0.36∗P ^(-0.30))

>100 W and <150† W All others 100/(1+0.36∗P^(-0.30))

>100≥150‡ W and <150*≤250

W Tested at 480 V

For ≥150 W and ≤200 W: 88.0.994/(1+

For >200 W and ≤250 W:

6.0*10^(-2.5∗)*P ^(-+ 76.0.55))

>100≥150‡ W and <150*≤250

W All others

1/(1+0.6∗P^(-0.34))For ≥150 W and ≤200 W: 

88.0

For >200 W and ≤250 W:

7.0*10^(-2)*P + 74.0

>250 W and ≤500 W Tested at 480 V 91.0

>250 W and ≤500 W All others 91.5

>500 W and ≤2000 W Tested at 480 V

For >500 W to <1000 W:

0.994*(3.2*10^(-53)∗P + 089.9)

For ≥1000 W to ≤2000 W: 91.9%92.5

>500 W and ≤2000 W All others

For >500 W to <1000 W:

3.2*10^(-53)∗P + 089.9

For ≥1000 W to ≤2000 W: 92.5%93.1

*The >100 W and <150 W equipment classes include†Includes 150 W fixtures exempted by EISA 

2007specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 watt lamps; rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

‡Excludes 150 W fixtures specified in paragraph (b)(3) of this section, which are alsofixtures rated only for 

150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 

410.4(A); and containcontaining a ballast that is rated to operate at ambient air temperatures above 50 °C, as 

specified by UL 1029–2001. All other fixtures with ballasts that are rated only for 150 watt lamps are covered 

by 10 CFR 431.326(a). 

**Tested input voltage is specified in 10 CFR 431.324

†††P is defined as the rated wattage of the lamp the fixture is designed to operate.

‡‡Tested input voltage is specified in 10 CFR 431.324

(d) Except as provided in paragraph (e) of this section, metal halide lamp fixtures 

manufactured on or after January 1, 2015 that operate lamps with rated wattage >500 W 

to ≤2000 W shall not contain a probe-start metal halide ballast.

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(e) The standards described in paragraph (aparagraphs (c) and (d) of this section do 

not apply to—

(1) Metal halide lamp fixtures with regulated-lag ballasts; and

(2) Metal halide lamp fixtures that use electronic ballasts that operate at 480 volts.

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