ES-i 

EXECUTIVE SUMMARY 

TABLE OF CONTENTS 

ES.1 OVERVIEW OF INTERIM ANALYSIS ACTIVITIES .............................................. ES-1

ES.2 KEY RESULTS OF THE ANALYSIS ........................................................................ ES-1

ES.2.1 Determination of Scope .............................................................................. ES-1

ES.2.2 Market and Technology Assessment .......................................................... ES-1

ES.2.3 Screening Analysis...................................................................................... ES-3

ES.2.4 Engineering Analysis .................................................................................. ES-3

ES.2.5 Equipment Price Determination .................................................................. ES-4

ES.2.6 Markups Analysis ....................................................................................... ES-4

ES.2.7 Energy Use Analysis ................................................................................... ES-5

ES.2.8 Life-Cycle Cost and Payback Period Analysis ........................................... ES-6

ES.2.9 Shipments Analysis ..................................................................................... ES-8

ES.2.10 National Impact Analysis ............................................................................ ES-9

ES.2.10.1 National Energy Savings Analysis............................................ ES-9

ES.2.10.2 Net Present Value Analysis .................................................... ES-11

ES.2.11 Interim Manufacturer Impact Analysis ..................................................... ES-13

ES.2.12 Other Analyses .......................................................................................... ES-13

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT ....................................... ES-13

ES.3.1 High-CRI Lamps ....................................................................................... ES-14

ES.3.2 Colored MH Lamp Definition .................................................................. ES-14

ES.3.3 Specialty Application Mercury Vapor Lamps .......................................... ES-14

ES.3.4 Electrodeless HID Lamps ......................................................................... ES-14

ES.3.5 Scope ......................................................................................................... ES-14

ES.3.6 Manufacturers of High-Intensity Discharge Lamps ................................. ES-15

ES.3.7 Technology Options .................................................................................. ES-15

ES.3.8 Bulb Finish ................................................................................................ ES-15

ES.3.9 Luminaire Characteristic ........................................................................... ES-15

ES.3.10 Equipment Classes .................................................................................... ES-15

ES.3.11 Market and Technology Assessment ........................................................ ES-16

ES.3.12 Screening Analysis.................................................................................... ES-16

ES.3.13 Representative Equipment Classes ........................................................... ES-16

ES.3.14 Baseline Lamps ......................................................................................... ES-16

ES.3.15 More Efficacious Substitutes .................................................................... ES-16

ES.3.16 Candidate Standard Levels ....................................................................... ES-16

ES.3.17 Reporting Requirements ........................................................................... ES-17

ES.3.18 Ballasts ...................................................................................................... ES-17

ES.3.19 Scaling Between Equipment Classes ........................................................ ES-17

ES.3.20 Engineering Analysis ................................................................................ ES-17

ES.3.21 HID Lamp Price Determination ................................................................ ES-17

ES.3.22 HID Ballast and Fixture Price Determination ........................................... ES-17

ES.3.23 Operating Profiles for Energy Use Characterization ................................ ES-18

ES.3.24 Average Equipment Lifetimes and Failure Distributions ......................... ES-18

ES.3.25 Historical Shipments Data ........................................................................ ES-18
ES-ii

ES.3.26 Shipment Trends ....................................................................................... ES-18

ES.3.27 Standards-Induced Market Shifts .............................................................. ES-18

ES.3.28 Customer Subgroups ................................................................................. ES-19

ES.3.29 Valuing Airborne Emission Reductions ................................................... ES-19

LIST OF TABLES 

Table ES.2.1 HID Lamps Included in the Scope of Coverage ..................................................ES-1

Table ES.2.2 Equipment Classes for High-Intensity Discharge Lamps ....................................ES-3

Table ES.2.3 Summary Candidate Standard Levels for High-Intensity Discharge Lamp 

Representative Equipment Classes ....................................................................ES-4

Table ES.2.4 Average Annual High-Intensity Discharge Lamp Operating Hours by Sector ....ES-5

Table ES.2.5 Annual Energy Use by High-Intensity Discharge Lamp Equipment Class .........ES-6

Table ES.2.6 Life-Cycle Cost and Payback Period Results for HID Lamps .............................ES-7

Table ES.2.7 Cumulative National Energy Savings for HID Lamps Purchased from 

2017–2046........................................................................................................ES-10

Table ES.2.8 Cumulative Net Present Value Results for HID Lamps Purchased from 

2017–2046........................................................................................................ES-12

LIST OF FIGURES 

Figure ES.2.1 Base-Case Forecasted Shipments for HID Lamps ..............................................ES-9
ES-1

EXECUTIVE SUMMARY 

ES.1 OVERVIEW OF INTERIM ANALYSIS ACTIVITIES 

 Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified. This executive summary 

highlights the activities associated with this interim analysis that DOE conducted when 

considering new energy conservation standards for high-intensity discharge (HID) lamps. The 

executive summary also describes key results from DOE’s interim analysis and delineates issues 

on which DOE seeks comment. 

ES.2 KEY RESULTS OF THE ANALYSIS 

 The following sections describe in detail the key analyses DOE performed. 

ES.2.1 Determination of Scope 

DOE assessed HID lamps to determine which lamps met the criteria for prescribing new 

standards (i.e., which HID lamps had potential for significant energy savings, technological 

feasibility, and economic justification). (42 U.S.C. 6295(o)(2)(A)) Table ES.2.1 outlines the HID 

lamps included in the scope of this rulemaking. 

Table ES.2.1 HID Lamps Included in the Scope of Coverage 

Lamp Type Rated Wattage Correlated Color Temperature 

(CCT)

Metal Halide 50 watts (W) and 2000 W 2800 Kelvin (K) and <7000 K

Mercury Vapor 50 W and 1000 W 3200 K and 6800 K

High-Pressure 

Sodium 50 W and 1000 W 1900 K and 2700 K

DOE is not considering standards for the following lamps in this interim analysis: 

 Directional HID lamps 

 Self-ballasted HID lamps 

 HID lamps intended for use with electronic ballasts only 

 Pulse-start MH lamps with CRI ≥95 

 Colored metal halide (MH) lamps (color rendering index [CRI] <40) 

 Mercury vapor (MV) lamps labeled for use with specialty applications 

 Electrodeless HID lamps 

ES.2.2 Market and Technology Assessment 

A market and technology assessment characterizes the relevant equipment markets and 

technology options, including prototype designs. DOE addresses (1) manufacturer market share 

and characteristics, (2) existing regulatory and non-regulatory initiatives for improving 
ES-2

equipment efficacy, and (3) trends in equipment characteristics and retail markets. This 

information provides data and resource material throughout the analysis. 

DOE reviews literature and interviews manufacturers to develop an overall understanding 

of the HID lamp industry. Industry publications—including trade journals, literature from 

manufacturers, government agencies, and trade organizations—provide the bulk of the 

information, which includes: (1) manufacturers and their market share, (2) shipments by lamp 

technology, (3) lamp information, and (4) industry trends. 

 DOE used information about existing and past technology options and prototype designs 

to determine which technologies and combinations of technologies manufacturers use to attain 

higher performance levels. In consultation with interested parties, DOE developed a list of 

technologies to be considered. The technologies initially identified include all those DOE 

believes may improve energy efficiency. See chapter 3 of this interim technical support 

document (TSD) for details. 

DOE generally divides covered equipment into equipment classes by the type of energy 

used, capacity, or other performance-related features that affect efficacy. (42 U.S.C. 6295(q)) 

Table ES.2.2 describes all of the equipment classes DOE is considering in this rulemaking. 
ES-3

Table ES.2.2 Equipment Classes for High-Intensity Discharge Lamps 

CCT Range Wattage Bulb Finish* Luminaire Characteristic**

1900 K and ≤2800 K 50 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

2800 K and ≤4500 K

50 W and ≤400 W

Clear Enclosed

Open

Coated Enclosed

Open

400 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

1000 W and ≤2000 W

Clear Enclosed

Open

Coated Enclosed

Open

4500 K and <7000 K

50 W and ≤400 W

Clear Enclosed

Open

Coated Enclosed

Open

400 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

1000 W and ≤2000 W

Clear Enclosed

Open

Coated Enclosed

Open

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

** MV and HPS lamps are placed in the enclosed equipment classes for their respective wattage and CCT.

ES.2.3 Screening Analysis 

 DOE developed an initial list of options for enhancing efficacy from the technologies 

identified in the technology assessment. In consultation with interested parties, DOE reviewed

the list to assess whether the technologies are technologically feasible, practicable to 

manufacture, install, and service; would adversely affect equipment utility or availability; or 

would have adverse impacts on health and safety. See chapter 4 of the interim TSD for details. 

ES.2.4 Engineering Analysis 

 In the engineering analysis, DOE chose certain classes as representative and concentrated 

its analytical effort on these classes. Generally, DOE selected representative equipment classes 

based on the highest shipment volumes, although it also considered unique performance 

characteristics as appropriate. DOE also chose appropriate baseline models and identified more 

efficacious replacements. The baseline model is typically the most common, least efficacious 

equipment sold in a given equipment class. In cases where a large portion of the market has 
ES-4

already adopted a more efficacious lamp, DOE analyzed two baseline models. See chapter 5 of 

the interim TSD for details. 

Table ES.2.3 presents the efficacy identified for each candidate standard level (CSL) in 

the engineering analysis. 

Table ES.2.3 Summary Candidate Standard Levels for High-Intensity Discharge Lamp 

Representative Equipment Classes 

CCT Range Wattage Range CSL Lamp Type Equation

>2800 K and ≤4500 K

≥50 W and ≤400 W

CSL 1 Probe MH lm/W = 45.5 * W^0.10

CSL 2 Pulse MH lm/W = 50.7 * W^0.10

CSL 3 CMH lm/W = 48.7 * W^0.13

>400 W and ≤1000 W

CSL 1 Probe MH lm/W = 0.021*W + 74.3

CSL 2 Pulse MH lm/W = 0.021* W + 83.8

>1000 W and ≤2000 W CSL 1 Probe MH lm/W = 95.3

* DOE is also considering a CSL 1 for the ≥1900 K and ≤2800 K CCT range and ≥50 W and ≤1000 W wattage range. The lamp type would be an 

HPS lamp that uses sapphire arc tube technology. DOE seeks comment on whether this technology passes the screening analysis and should be 

considered in the development of a CSL 1 for these lamps. For more information on the standard level for this potential CSL 1, see chapter 5 of 

the interim TSD. 

ES.2.5 Equipment Price Determination 

For this rulemaking, DOE estimated the end-user price of HID lamps directly, rather than 

develop manufacturer selling prices (MSPs) from a bill of materials and manufacturer markup 

analysis. DOE selected this methodology because it is difficult to reverse-engineer an HID lamp; 

they are not easily disassembled, and fill gas composition and partial pressures are difficult to 

assess. 

 In its review of publicly-available prices, DOE observed a range of end-user prices paid 

for a lamp, depending on the distribution channel through which it is purchased. In line with its 

observation of public pricing, DOE developed three sets of discounts from the blue-book prices, 

representing low (State procurement), medium (electrical distributors), and high (Internet 

retailers) lamp prices for HID lamps. See chapter 6 of the interim TSD for details. 

DOE determined that when transitioning from the baseline to a more efficacious 

substitute lamp, customers would also need to change their HID ballast and HID fixture. DOE 

used ballast and fixture teardown data, as well as ballast blue book data, to estimate 

manufacturer production costs (MPCs). Then, DOE marked up the ballast and fixture MPCs to 

MSPs using a manufacturer markup that accounts for non-production costs and manufacturer 

profit. See chapter 6 of the interim TSD for details. 

ES.2.6 Markups Analysis 

 Because DOE estimated HID lamp end-user prices directly, markups were not needed to 

relate MSPs to end-user prices for lamps.a However, DOE also considered the prices of ballasts 

and fixtures related to HID lamps because almost all higher-efficacy lamps are assumed to 

 

a

 Lamp MSPs will be used for the manufacturer impact analysis (MIA) to estimate annual revenue. DOE is 

considering a price markup of 1.15 to relate the low end-user prices for HID lamps to the MSPs used as MIA inputs. 
ES-5

require a new ballast or a new fixture (with a new ballast). Starting with MSPs for ballasts and 

fixtures, DOE applied estimated price markups to develop end-user prices used in the life-cycle 

cost (LCC) and payback period (PBP) analysis. 

 Consistent with the approach in the energy conservation standards rulemaking for metal 

halide lamp fixtures (MHLFs) and for fluorescent lamp ballasts (FLBs), DOE assumed a baseline 

markup of 1.39 for HID ballasts and fixtures.b

This baseline markup is a weighted average that 

reflects estimated proportions of equipment sold through different distribution channels, 

involving electrical wholesalers (distributors), contractors, and/or direct sales. DOE applied only 

baseline markups to the ballast and fixture MSPs, because DOE does not expect the cost 

structure for this ancillary equipment to vary with efficacy levels for HID lamps. Therefore, 

incremental markups were not used to develop end-user prices for HID ballasts and fixtures. See 

chapter 7 of the interim TSD for details. 

ES.2.7 Energy Use Analysis 

 The energy use analysis, which assesses the potential energy savings resulting from 

efficacy standards, provides the basis for developing the energy savings used in the LCC analysis 

and subsequent analyses. Ballasts designed to operate HID lamps are not subject to the energy 

efficiency standards being developed in this rulemaking, but are considered in the energy use 

analysis because the input power of the complete lamp-and-ballast system is required to 

accurately characterize the energy use of the system. DOE determined the annual energy usage 

of the HID lamp-and-ballast systems by multiplying input power to the ballast (i.e., the rate of 

energy use) and operating hours per year (i.e., the way customers use the lamp-and-ballast 

systems). DOE developed weighted average annual operating hours for each representative lamp 

type, based on their application in different market sectors. Table ES.2.4 summarizes the average 

annual sector operating hours used in developing weighted averages for the energy use 

characterization. 

Table ES.2.4 Average Annual High-Intensity Discharge Lamp Operating Hours by Sector 

Sector Average Annual Operating Hours

hr/yr

Commercial 3,961

Industrial 6,113

Outdoor Stationary, 

≤1000 W 4,493

Outdoor Stationary, 

>1000 W 778

 The engineering analysis references rated lamp wattage and measured ballast efficiency, 

which were used to calculate system input power for the representative equipment types. Table 

ES.2.5 shows the weighted average annual electricity use in kilowatt-hours (kWh) for each 

efficacy level in every representative equipment class that DOE considers in this rulemaking. 

 

b

 The MHLF preliminary TSD is available at: 

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

The FLB final rule TSD is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/62 
ES-6

Table ES.2.5 Annual Energy Use by High-Intensity Discharge Lamp Equipment Class 

Representative 

Equipment Class

Representative 

Lamp Type CSL Lamp Type**

Weighted 

Average Annual 

Operation

hr

Annual 

Energy Use

kWh

≥1900 K and ≤2800 K;

≥50 W to ≤1000 W;

clear; enclosed-rated

HPS 70 W Baseline* HPS 70 W 4,586 417

HPS 100 W Baseline* HPS 100 W 4,586 587

HPS 250 W Baseline* HPS 250 W 4,586 1,360

HPS 400 W Baseline* HPS 400 W 4,586 2,123

HPS 1000 W Baseline* HPS 1000 W 4,586 4,994

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W

Baseline MV MV 100 W 4,731 568

1 N/A --- ---

Baseline MH / 2 pulse MH 70 W 4,731 460

3 CMH 50 W 4,731 265

MV 175 W

Baseline MV MV 175W 4,760 976

1 N/A --- ---

Baseline MH / 2 pulse MH 100 W 4,760 619

3 CMH 70 W 4,760 371

MV 250 W

Baseline MV MV 250 W 4,760 1,362

Baseline MH / 1 probe MH 175 W 4,760 947

2 pulse MH 150 W 4,760 882

3 CMH 100 W 4,760 528

MV 400 W

Baseline MV MV 400 W 4,760 2,137

Baseline MH / 1 probe MH 250 W 4,760 1,352

2 pulse MH 200 W 4,760 1,082

3 CMH 150 W 4,760 790

probe MH 400 

W 

Baseline MV N/A --- ---

Baseline MH / 1 probe MH 400 W 4,760 2,164

2 pulse MH 320 W 4,760 1,731

3 CMH 250 W 4,760 1,287

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W 

Baseline MV MV 1000 W 4,855 5,256

1 N/A --- ---

2 pulse MH 750 W 4,855 4,015

probe MH 1000 

W 

Baseline MV N/A --- ---

Baseline MH / 1 probe MH 1000 W 4,855 5,289

2 pulse MH 875W 4,855 4,710

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 

W

Baseline probe MH 2000 W 778 1,637

1 probe MH 1500 W 778 1,269

* DOE is also considering a CSL 1 for the ≥1900 K and ≤2800 K CCT range and ≥50 W and ≤1000 W wattage range. The lamp type would be an 

HPS lamp that uses sapphire arc tube technology. DOE seeks comment on whether this technology passes the screening analysis and should be 

considered in the development of a CSL 1 for these lamps. For more information on the annual energy use of this potential CSL 1, see chapter 8 of 

the interim TSD. 

**Entries of “N/A” indicate CSLs where more efficacious MV replacements for MV baseline lamps do not exist, or where MV baseline lamps do 

not exist at a particular wattage range.

 For more details on the energy use characterization, see chapter 8 of the interim TSD. 

ES.2.8 Life-Cycle Cost and Payback Period Analysis 

 DOE analyzes the net effect of energy conservation standards on customers by evaluating 

the net life-cycle cost using the efficacies and prices derived from the engineering analysis, 

equipment price determination, and markups analysis, as well as the energy costs derived from 
ES-7

the energy use analysis. New standards typically increase the installed cost of equipment and 

decrease operating cost. Therefore, there is a point at which the equipment has higher-thanbaseline efficacy, while the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher-efficacy equipment. The time 

required for equipment to reach this cost-equivalence point is the payback period. 

Inputs to the LCC calculation include the installed cost to the customer, operating 

expenses, lifetime of the equipment, and discount rates. For this interim analysis, DOE analyzed 

three triggering events which necessitate a lamp purchase in the base case: (1) lamp failure; (2) 

ballast failure; and (3) fixture failure. DOE also assumed that a fixture purchase was necessary in 

higher EL cases, for all three triggering events. Table ES.2.6 presents the key findings for the 

lamp failure triggering event, as this was the only triggering event common to all equipment 

classes. Chapter 9 of this TSD provides a detailed description of the LCC-PBP analysis and the 

results for all three triggering events. 

In general, negative LCC savings occur because it is costlier to install an entire fixture 

than a new lamp only. In addition, equipment classes with MV baselines and probe MH 

baselines had shortened analysis periods to reflect shortened equipment lifetimes, which 

contributed to negative LCC savings. DOE assumed shorter lifetimes and analysis periods in 

these cases because new ballasts (and thus new fixtures as well) cannot be purchased in the MV 

case, and only replacement ballasts can be purchased in probe MH case—not allowing enough 

time to recover high equipment costs in the standards case. . 

Table ES.2.6 Life-Cycle Cost and Payback Period Results for HID Lamps 

Representative 

Equipment Class

Representative 

Lamp Type CSL Lamp Type

LCC

$

LCC 

Savings

$

PBP**

Yrs

≥1900 K and ≤2800 K;

≥50 W and ≤1000 W;

clear; enclosed-rated

HPS 70 W Baseline* HPS 70 W 1,253 --- ---

HPS 100 W Baseline* HPS 100 W 1,442 --- ---

HPS 250 W Baseline* HPS 250 W 2,123 --- ---

HPS 400 W Baseline* HPS 400 W 2,788 --- ---

HPS 1000 W Baseline* HPS 1000 W 5,506 --- ---

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W 

Baseline MV MV 100 W 629 --- ---

1 N/A --- --- ---

Baseline MH / 2 pulse MH 70 W 740 -111 19.7

3 CMH 50 W 682 -53 7.6

Baseline MH / 2 pulse MH 70 W 1,035 --- ---

3 CMH 50 W 1,143 -108 22.6

MV 175 W 

Baseline MV MV 175W 808 --- ---

1 N/A --- --- ---

Baseline MH / 2 pulse MH 100 W 896 -88 8.7

3 CMH 70 W 859 -51 6.7

Baseline MH / 2 pulse MH 100 W 1,187 --- ---

3 CMH 70 W 1,429 -242 N/A

MV 250 W 

Baseline MV MV 250 W 1,048 --- ---

Baseline MH / 1 probe MH 175 W --- --- ---

2 pulse MH 150 W 1,147 -99 7.9

3 CMH 100 W 1,034 14 5.2

Baseline MH / 1 probe MH 175 W 2,225 --- ---

2 pulse MH 150 W 2,144 81 8.6
ES-8

Representative 

Equipment Class

Representative 

Lamp Type CSL Lamp Type

LCC

$

LCC 

Savings

$

PBP**

Yrs

3 CMH 100 W 1,728 497 4.5

MV 400 W 

Baseline MV MV 400 W 1,439 --- ---

Baseline MH / 1 probe MH 250 W --- --- ---

2 pulse MH 200 W 1,328 112 4.2

3 CMH 150 W 1,263 177 3.8

Baseline MH / 1 probe MH 250 W 2,846 --- ---

2 pulse MH 200 W 2,303 543 4.5

3 CMH 150 W 2,343 504 5.0

probe MH 400 

W 

Baseline MV N/A --- --- ---

Baseline MH / 1 probe MH 400 W 3,064 --- ---

2 pulse MH 320 W 3,070 -6 11.5

3 CMH 250 W 2,933 132 9.3

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W

Baseline MV MV 1000 W 3,067 --- ---

1 N/A --- --- ---

2 pulse MH 750 W 3,207 -140 6.8

MV 1000 W

Baseline MV N/A --- --- ---

Baseline MH / 1 probe MH 1000 W 6,242 --- ---

2 pulse MH 875 W 5,980 262 7.1

>2800 K and ≤4500 K;

>1000 W and ≤2000 

W;

clear; enclosed-rated

probe MH 2000 

W 

Baseline MH 2000 W 2,481 --- ---

1 MH 1500 W 2,929 -448 20.8

* DOE is also considering a CSL 1 for the ≥1900 K and ≤2800 K CCT range and ≥50 W and ≤1000 W wattage range. The lamp type would be an 

HPS lamp that uses sapphire arc tube technology. DOE seeks comment on whether this technology passes the screening analysis and should be 

considered in the development of a CSL 1 for these lamps. For more information on the LCC and PBP results for this potential CSL 1, see 

chapter 9 of the interim TSD. 

**Negative PBP values indicate standards that reduce operating costs and installed costs. Entries of “N/A” indicate standards that do not reduce 

operating costs. 

ES.2.9 Shipments Analysis 

 Shipment forecasts are needed to calculate the national impacts of energy conservation 

standards on energy use, the net present value (NPV) of customer costs and savings, and future 

manufacturer cash flows for each representative equipment class under consideration. DOE 

develops a base-case shipments forecast against which standards-case shipments forecasts at 

higher efficacy levels (based on the CSLs) are compared. In determining the base-case 

projection, DOE considered historical shipments, the mix of efficacies currently sold in the 

absence of regulation, and how that mix might change over time. 

Figure ES.2.1 presents the base case shipments projections from 2017–2046 for the HID 

lamp equipment classes under consideration. 
ES-9

Figure ES.2.1 Base-Case Forecasted Shipments for HID Lamps 

 Chapter 10 of this TSD provides additional detail on the shipments analysis. 

ES.2.10 National Impact Analysis 

 The national impact analysis (NIA) estimates the following national impacts from 

possible CSLs: (1) the national energy savings (NES); (2) monetary value of the energy savings 

due to standards; (3) increased total installed costs of the considered equipment due to standards; 

and (4) the NPV of energy savings (difference between value of energy savings and increased 

total installed costs). DOE prepared a spreadsheet model to forecast energy savings and national 

customer economic costs and savings resulting from new standards. Chapter 11 of this TSD 

provides additional detail on the analysis. 

ES.2.10.1 National Energy Savings Analysis 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without energy conservation standards) and in each higher-efficacy standard case. 

The cumulative energy savings are the sum of the annual NES over the lifetime of HID lamps 

purchased from 2017–2046. Table ES.2.7 shows the cumulative NES results under a “roll-up” 

scenario. Energy savings for individual equipment classes illustrate the approximate relative 

energy savings of each lamp type under a CSL. 

0

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

14,000,000

16,000,000

18,000,000

1990 2000 2010 2020 2030 2040

Total Amount of Shipments

Year

HPS Lamps

MV Lamps

Probe-Start MH

Pulse-Start MH

Ceramic MH
ES-10

Table ES.2.7 Cumulative National Energy Savings for HID Lamps Purchased from 2017–

2046

CSL Representative Equipment Class* Representative

Lamp Type

National Energy Savings

quads**

Roll-Up Scenario

1

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W  0.00

MV 175 W** ** 0.01

MV 250 W 0.01

MV 400 W 0.03

probe MH 400 W N/A

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W  0.00

probe MH 1000 W N/A

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W 0.01

TOTAL CSL 1 0.06

2** *

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W 0.00

MV 175 W 0.01

MV 250 W 0.02

MV 400 W 0.08

probe MH 400 W 0.29

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W 0.00

probe MH 1000 W 0.17

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W 0.01

TOTAL CSL 2 0.59

3***

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W 0.28

MV 175 W 0.19

MV 250 W 0.36

MV 400 W 0.85

probe MH 400 W 2.23

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W 0.00

probe MH 1000 W 0.17

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W 0.01

TOTAL CSL 3 4.09

* DOE is also considering a CSL 1 for the ≥1900 K and ≤2800 K CCT range and ≥50 W and ≤1000 W wattage range. The lamp 

type would be an HPS lamp that uses sapphire arc tube technology. DOE seeks comment on whether this technology passes the 

screening analysis and should be considered in the development of a CSL1 for these lamps. For more information on the national 

energy savings for this potential CSL 1, see chapter 11 of the interim TSD. 

** quads =quadrillion British thermal units of primary (source) energy; entries of “N/A” indicate where baseline and CSL1 

efficiency levels are represented by the same lamp type. 

*** For some representative lamp types, a CSL 2 or CSL 3 does not exist. In those cases, DOE reports the NES corresponding to 

the highest CSL available. 

**** CSL 1 is not applicable to these representative lamp types. Instead, DOE presents the NES for CSL 2 for these lamp types. 
ES-11

ES.2.10.2 Net Present Value Analysis 

 DOE calculated NPV as the difference between total savings in operating costs and 

increases in total installed costs in the base case and standards case. DOE calculated savings over 

the life of the equipment using discount rates of seven and three percent to discount future costs 

and savings to the present. 

Table ES.2.8 shows the total cumulative NPV results and NPV values for individual 

equipment classes. An NPV greater than zero shows net benefit to the nation that the CSL would 

bring about relative to the base case in present value terms. An NPV less than zero indicates that 

the CSL would result in a net cost to the nation in present value terms.

 This interim analysis results are due, in many cases, to the need to exchange fixtures in 

the standards case after the rule goes into effect. When a customer can no longer buy a lamp due 

to a standard, they can no longer operate an existing fixture, which necessitates a new fixture 

purchase in the standards case. In the base case, the replacement lamps are still available, so a 

lamp or lamp and ballast purchase will often suffice. 
ES-12

Table ES.2.8 Cumulative Net Present Value Results for HID Lamps Purchased from 2017–

2046

CSL Representative Equipment Class*

Representative

Lamp Type

Net Present Value

billion 2012$

Roll-Up Scenario

7 Percent 

Discount Rate

3 Percent 

Discount Rate

1

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W*** -0.002 -0.002

MV 175 W*** 0.02 0.02

MV 250 W -0.01 -0.02

MV 400 W -0.01 -0.01

probe MH 400 W --- ---

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W*** 0.00 0.00

probe MH 1000 W --- ---

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W -0.08 -0.10

TOTAL CSL 1 -0.09 -0.10

2**

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W -0.002 -0.002

MV 175 W 0.02 0.02

MV 250 W -0.73 -0.95

MV 400 W -0.96 -1.22

probe MH 400 W -0.40 -0.36

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W 0.00 0.00

probe MH 1000 W -1.01-1.20

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W -0.08 -0.10

TOTAL CSL 2 -3.17 -3.80

3**

>2800 K and ≤4500 K;

≥50 W and ≤400 W;

clear; enclosed-rated

MV 100 W -0.29 -0.12

MV 175 W -0.35 -0.33

MV 250 W -0.81 -0.78

MV 400 W -1.60 -1.16

probe MH 400 W -0.51 -1.55

>2800 K and ≤4500 K

>400 W and ≤1000 W;

clear; enclosed-rated

MV 1000 W 0.00 0.00

probe MH 1000 W -1.01 -1.20

>2800 K and ≤4500 K;

>1000 W and ≤2000 W;

clear; enclosed-rated

probe MH 2000 W -0.08 -0.10

TOTAL CSL 3 -4.65 -2.14

* DOE is also considering a CSL 1 for the ≥1900 K and ≤2800 K CCT range and ≥50 W and ≤1000 W wattage 

range. The lamp type would be an HPS lamp that uses sapphire arc tube technology. DOE seeks comment on 

whether this technology passes the screening analysis and should be considered in the development of a CSL1 for 
ES-13

these lamps. For more information on the net present value calculations for this potential CSL 1, see chapter 11 of 

the interim TSD. 

** For some representative lamp types, a CSL 2 or CSL 3 does not exist. In those cases, DOE reports the NES 

corresponding to the highest CSL available. 

*** CSL 1 is not applicable to these representative lamp types. Instead, DOE presents the NES for CSL 2 for these 

lamp types. 

ES.2.11 Interim Manufacturer Impact Analysis 

The MIA assesses the potential impacts of energy conservation standards on 

manufacturers, including effects on expenditures for capital conversion, marketing costs, 

shipments, and research and development costs. Impacts to direct employment are also addressed 

in the MIA. Potential impacts might lead to changes in manufacturing practices for HID lamps. 

DOE identified potential impacts through interviews with manufacturers and other interested 

parties. 

 

 During preliminary interviews for this interim MIA, manufacturers identified four major 

areas of concern: (1) energy savings from replacement HID lamps, (2) testing burden, (3) 

technology shift, and (4) product innovation. See chapter 13 of the interim TSD for details. 

ES.2.12 Other Analyses 

The remaining chapters of the interim TSD address the following analyses, which will be 

performed for the notice of proposed rulemaking (NOPR): 

 The customer subgroup analysis evaluates the effects of energy conservation standards on 

various national customer subgroups (chapter 12), 

 The employment impact analysis examines the indirect effects of energy conservation 

standards on national employment (chapter 14), 

 The utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 15), 

 The emissions analysis examines the effects of energy conservation standards on various 

airborne emissions (chapter 16), 

 The monetization of emissions analysis quantifies the impacts of reduced emissions as a 

result of energy conservation standards (chapter 17), and

 The regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards (chapter 18). 

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

 DOE is interested in receiving comment on all aspects of this interim analysis. DOE 

especially invites comment or data to improve DOE’s analyses, including information that will 

respond to the following questions and concerns raised in response to the framework document 

and in the development of this interim TSD. 
ES-14

ES.3.1 High-CRI Lamps 

 For MH lamps, DOE found that lamps with CRI ≥95 could not reach the same levels of 

efficacy as lower-CRI lamps. For the interim analysis, DOE did not consider standards for pulsestart MH lamps with CRI ≥95. DOE requests comment on this preliminary determination. 

ES.3.2 Colored MH Lamp Definition 

DOE considered adopting the European Union’s (EU) definition of white light, which 

sets chromaticity requirements based on the coordinates of the CIE 1931 chromaticity diagram. 

DOE preliminarily determined that a colored MH lamp could be effectively defined instead 

using CRI. DOE requests comment on this conclusion and whether consistency with the EU 

definition would be beneficial. 

ES.3.3 Specialty Application Mercury Vapor Lamps 

DOE is aware of certain specialty applications, such as quality inspection, industrial 

processing, or scientific uses, including fluorescent microscopy and ultraviolet curing that can 

only be served by MV lamps and not any other HID or solid-state technologies. To ensure these 

specialty application lamps remain commercially available, DOE is not considering standards for 

MV lamps that are individually labeled for specialty application, including the intended 

application. DOE requests comment on excluding specialty application MV lamps labeled in this 

manner from the scope of coverage. 

ES.3.4 Electrodeless HID Lamps 

DOE determined that “electrodeless HID lamps” meet the EPCA definition of HID lamp. 

These lamps meet the four main specifications of an HID lamp: (1) the arc tube wall loading is in 

excess of three watts/cm2; (2) the light-producing arc is stabilized by the arc tube wall 

temperature; (3) the lamp is either a MV, HPS, or MH lamp; and (4) the lamp is an “electricdischarge lamp.” However, based on their small market share and lack of an industry consensus 

test method, DOE is not considering standards for electrodeless HID lamps. DOE requests 

comment on this determination and whether additional information is necessary to define this 

exclusion. 

ES.3.5 Scope 

DOE is considering energy conservation standards in this rulemaking for the following 

HID lamp types: MH lamps with a rated wattage of ≥50 W and ≤2000 W, and MV and highpressure sodium (HPS) lamps with a rated wattage of ≥50 W and ≤1000 W. Within these wattage 

ranges, DOE is considering including MH lamps with CCTs ≥2800 K and <7000 K, MV lamps 

with CCTs ≥3200 K and ≤6800 K, and HPS lamps with CCTs ≥1900 K and ≤2700 K. DOE is 

not considering standards for directional HID lamps, self-ballasted HID lamps, HID lamps for 

use with electronic ballasts only, pulse-start MH lamps with CRI ≥95, colored MH lamps (CRI 

<40), MV lamps intended for specialty applications, and electrodeless HID lamps. DOE seeks 

comment on the proposed scope and listed exclusions. 
ES-15

ES.3.6 Manufacturers of High-Intensity Discharge Lamps 

Although the HID lamp market is predominantly controlled by large manufacturers, DOE 

conducts a study of small businesses that manufacture HID lamps for the NOPR stage of this 

rulemaking analysis. DOE invites interested parties to provide information for any small 

businesses that manufacture HID lamps and should be consulted before DOE publishes a NOPR. 

ES.3.7 Technology Options 

DOE determined that the only way to increase efficacy in applications using MV lamps is 

to substitute MH or HPS lamps for MV. The only technology option to achieve higher efficacy 

in HPS lamps may be to construct the arc tubes out of a sapphire material instead of 

polycrystalline alumina. DOE seeks information on this technology, including whether it meets 

DOE’s screening criteria. To DOE’s knowledge, the technology options for improving MH lamp 

efficacy are to manufacture arc tubes out of ceramic instead of quartz, to redesign the arc tube 

shape, and to switch from probe-start technology to pulse-start technology. DOE requests 

comment on the technology options considered and any additional options that should be 

considered. 

ES.3.8 Bulb Finish 

DOE observed that HID lamp manufacturers offered several different non-clear bulb 

finish options, including coated, diffuse, frosted, white, and deluxe white. DOE noted that most 

of these non-clear finishes are characterized by a phosphor coating applied to the inner wall of 

the outer bulb, while marketing technique accounted for any variation in terminology. Therefore, 

DOE chose to define “coated lamps” as all lamps that are not clear. DOE requests comment on 

its definition of coated lamps. 

ES.3.9 Luminaire Characteristic 

 When separating equipment classes according to luminaire characteristic, DOE 

distinguished between open-rated lamps, enclosed-rated lamps, and S-rated lamps. Open-rated 

lamps, which are tested and approved for use in open luminaires, are characterized by specific 

safety measures, including the requirement to have a glass shroud that surrounds the arc tube to 

protect the surrounding area in the event of arc tube rupture. Enclosed-rated and S-rated lamps 

do not have this glass shroud, and so DOE put enclosed-rated and S-rated lamps in separate 

equipment classes from open-rated lamps. DOE also found definitions for F-rated lamps, but did 

not identify any of these lamps in its review of manufacturer catalogs. DOE requests comment 

on the separation of equipment classes by luminaire characteristic, as well as the applications of 

F-rated lamps and how they should be categorized within DOE’s equipment class structure. 

ES.3.10 Equipment Classes 

DOE defined equipment classes based on CCT, wattage, bulb finish, and luminaire 

characteristic. These class-setting factors created 28 equipment classes, summarized in Table 

ES.2.2. DOE seeks comments on these equipment classes. 
ES-16

ES.3.11 Market and Technology Assessment 

DOE requests any general comments on the methodology and results of the market and 

technology assessment. 

ES.3.12 Screening Analysis 

 DOE invites comment on whether the technology options, and in particular sapphire arc 

tube technology, meet DOE’s screening criteria. 

ES.3.13 Representative Equipment Classes 

DOE identified the following four equipment classes as representative: 

 ≥1900 K and ≤2800 K; ≥50 W to ≤1000 W; clear; enclosed-rated lamps 

 >2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed-rated lamps 

 >2800 K and ≤4500 K; >400 W and ≤1000 W; clear; enclosed-rated lamps 

 >2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed-rated lamps 

DOE requests comment on the use of these four equipment classes as representative. 

ES.3.14 Baseline Lamps 

Baseline lamps are typically characteristic of the most common and least efficacious 

lamps within the four representative equipment classes. In cases where the most common and 

least efficacious lamp is not the same, DOE designated both lamps as baseline units. DOE 

requests comment on the baseline units selected. 

ES.3.15 More Efficacious Substitutes 

After choosing baseline lamps for each representative lamp type, DOE identified between 

one and three more efficacious substitute lamps. DOE chose more efficacious substitutes that 

were within 10 percent mean lumens to the baseline as well as, when possible, holding constant 

initial lumen output, operating orientation, rated life, CRI, bulb shape, and base type. DOE 

requests comment on the criteria used in selecting more efficacious substitute lamps, as well as 

the units that were selected to be substitutes. 

ES.3.16 Candidate Standard Levels 

When developing efficacy equations, DOE modeled each CSL to represent a particular 

lamp technology. When possible, to develop equations, DOE used power function regression 

curves to best fit the representative units in each equipment class, according to an equation of the 

form: 

lm/W = coefficient * (lamp input power)^exponent 

DOE requests comment on the equations developed for the CSLs in each of the 

representative equipment classes. 
ES-17

ES.3.17 Reporting Requirements 

 DOE based its engineering analysis on performance data presented in manufacturer 

catalogs. At this time, DOE does not have third party test data or compliance reports with which 

to analyze the variation in test data and the impact of reporting requirements. DOE invites 

comment on whether an adjustment to the CSLs is needed to account for the reporting 

requirements and other sources of variation. 

ES.3.18 Ballasts 

 DOE paired each representative HID lamp with a representative ballast to develop 

representative lamp-and-ballast systems. DOE used product catalogs and manufacturer input to 

identify the ballast type that is used most commonly with each representative lamp type. DOE 

then calculated ballast efficiencies for each ballast type and wattage combination, based on 

catalog efficiency data and applicable energy conservation standards. DOE requests comment on 

the ballast types and ballast efficiencies chosen for each lamp type to calculate lamp-and-ballast 

system energy use. 

ES.3.19 Scaling Between Equipment Classes 

DOE extrapolated its analysis from representative equipment classes to those not directly 

analyzed by calculating scaling factors to account for percent initial efficacy changes in bulb 

finish, luminaire characteristic, and CCT range. DOE requests comment on the methodology and 

result of this scaling analysis and, in particular, whether the scaling factor between these CCT 

ranges should be a function of wattage. DOE would also appreciate a technical description of 

why such a trend between wattage and efficacy difference might exist between CCT ranges. 

ES.3.20 Engineering Analysis 

DOE requests any comments pertaining to the methodology and results of the 

engineering analysis. 

ES.3.21 HID Lamp Price Determination 

 In its review of publicly-available prices, DOE observed a range of end-user prices paid 

for a lamp, depending on the distribution channel through which it is purchased. In line with its 

observation of public pricing, DOE developed three sets of discounts from the blue-book prices, 

representing low (State procurement), medium (electrical distributors), and high (Internet 

retailers) lamp prices for HID lamps. DOE found the discount did not vary with wattage or lamp 

technology, and therefore applied a single discount for all lamps to estimate end-user prices. 

DOE invites comment on its methodology and results for estimating end-user prices for HID 

lamps. 

ES.3.22 HID Ballast and Fixture Price Determination 

 DOE used ballast and fixture teardown data, as well as ballast blue-book data, to estimate 

MPCs. Then, DOE marked up the ballast and fixture MPCs to MSPs using a manufacturer 
ES-18

markup that accounts for non-production costs and manufacturer profit. DOE invites comment 

on its methodology and results for estimating MSPs for HID ballasts and fixtures. 

ES.3.23 Operating Profiles for Energy Use Characterization 

 To characterize the nation’s average use of HID lamps for a typical year, DOE developed 

annual operating hours by sector using data published in the 2010 U.S. Lighting Market 

Characterization. DOE assumed that all lamp equipment classes analyzed (Table ES.2.2) could 

be used in the three evaluated sectors (i.e., commercial, industrial, and outdoor stationary), and 

applied average annual operating hours based on each sector (Table ES.2.4). DOE welcomes 

comment on the basis and assignment of these end-use operating profiles for the ballast types 

covered under this rulemaking. 

ES.3.24 Average Equipment Lifetimes and Failure Distributions 

 For the LCC-PBP analysis and shipment projections, DOE assumed HID lamp fixture 

lifetimes of 20 years for interior fixtures and 25 years for exterior fixtures. DOE assumed 

lifetimes of 40,000 hours for electronic ballasts, and 50,000 hours for magnetic ballasts. DOE 

also used an average of lamp lifetimes at different operating orientations for lamp lifetimes in 

each equipment class. These average values suggest that a majority of failures occur later in the 

service lifetime. DOE seeks comment on its assumed lifetimes for fixtures, ballasts, and lamps, 

and how they may vary within the representative equipment classes, as well as the distribution of 

failures around the average values. In particular, DOE seeks comment on how many years 

beyond its average lifetime that equipment can remain in service. 

ES.3.25 Historical Shipments Data 

 For this rulemaking, DOE used lamp shipment data previously published in the HID 

lamps final determination, NEMA lamp shipment data (2002–2010) provided by manufacturers, 

and market trend information from manufacturers to develop historical shipment data for lamps 

from 1990–2010. DOE requests comment on this approach, and would welcome actual HID 

lamp shipment data to validate its methodology. 

ES.3.26 Shipment Trends 

 DOE modeled events that trigger lamp purchases (e.g., replacement and new 

construction) and applied growth rate and replacement rate assumptions to develop annual 

shipment projections. DOE based future lamp shipments on the 2010 HID lamps final 

determination; DOE assumes that these trends integrate various regulatory and non-regulatory 

initiatives in the lighting marketplace. DOE requests comment on the magnitude and timing of 

its projected lamp shipment trends (e.g., rising and declining shipments, plateaus) as well as the 

effects of current regulatory initiatives on future HID lamp shipments. 

ES.3.27 Standards-Induced Market Shifts 

In the shipments analysis, DOE assumes that a portion of the market shifts to LED, 

induction, and linear fluorescent sources. DOE requests comments on this assumption as well as 

on the likelihood and magnitude of an additional market shift to non-HID technologies in 
ES-19

response to standards. If a standards-induced shift is expected, DOE requests further comments 

on: (1) which equipment classes, applications, or fixture types would experience the shift; (2) 

which non-HID technologies would replace HID; and (3) on what basis an equivalent non-HID 

replacement would be specified by a customer (e.g., fixture light output, lamp mean lumens, 

etc.). 

ES.3.28 Customer Subgroups 

 Some subgroups might be adversely affected by potential energy conservation standards 

for HID lamps. DOE has preliminarily identified the following subgroups: medium to high-end 

retail, grocery, big-box retail, schools, community centers, sport facilities, industrial, 

warehousing, various types of facilities with outdoor area lighting, and owners of streets and 

roadways (e.g., property owners, municipalities, and state and federal departments of 

transportation). DOE welcomes additional suggestions for its customer subgroup analysis. 

ES.3.29 Valuing Airborne Emission Reductions 

 DOE will conduct an emissions analysis as part of the NOPR stage of this rulemaking. In 

the emissions analysis, DOE will estimate the reduction in power sector emissions of carbon 

dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2) and mercury (Hg) from potential 

energy conservation standards for the considered products. In addition, DOE will estimate 

emissions impacts in production activities (extracting, processing, and transporting fuels) that 

provide the energy inputs to power plants (i.e., “upstream” emissions). Together, these emissions 

account for the full fuel cycle, the analysis of which includes impacts on emissions of methane 

and nitrous oxide, both of which are recognized as greenhouse gases. DOE also plans on 

monetizing the emission reductions due to standards consistent with methods used in recent DOE 

standards rulemakings for other consumer products and commercial equipment. For example, in 

the case of CO2, the most recent interagency estimates of the potential global benefits resulting 

from reduced CO2 emissions in 2015 were $6.2, $25.7, $41.5, and $78.7 per metric ton in 2012$. 

DOE invites comment on the approaches for monetizing the emission savings due to energy 

conservation standards.