Building Technologies Program 1 eere.energy.gov

BUILDING TECHNOLOGIES PROGRAM

NOPR Public Meeting

Test Procedures for High-Intensity 

Discharge Lamps 

Tina Kaarsberg, Ph.D.

Department of Energy 

Energy Efficiency and Renewable Energy

HIDLamps-2010-TP-0044@ee.doe.gov

Thursday, January 19, 2012
Building Technologies Program 2 eere.energy.gov

• Introductions (including web participants)

• Role of the Facilitator

• Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– One person speak at a time (raise hand to be recognized; state 

your name for the record; web participants will have certain 

times allotted for their Q&A)

– Set cell phones (and other devices that make noise) to 

silent/vibrate, web participants mute phones.

• Housekeeping Items

• Agenda Review

• Opening Remarks

Welcome
Building Technologies Program 3 eere.energy.gov

Public Meeting Agenda

9:00 – 9:30 am Welcome, Introductions, Opening Statements

9:30 – 9:45 am Statute and Context 

9:45 – 11:15 am Proposed Test Procedures: Definitions; Test Methods

11:15 – 11:30 am Break

11:30 – 12:00 pm Proposed Test Procedures: Laboratory Accreditation 

Program; Test Measurements and Calculations

12:00 – 12:30 pm Conclusion and Closing Remarks

12:30 pm Adjourn

At the end of each section, time will be set aside for Web 

participants to ask questions and/or make statements.

Questions e-mailed during webinar will be included in the transcript.
Building Technologies Program 4 eere.energy.gov

1. Review statute and DOE actions for high-intensity 

 discharge (HID) lamps.

2. Present DOE’s proposed test procedures

3. Seek comment from participants on the proposed test 

 procedures

Purpose of the Test Procedures 

NOPR Public Meeting

At this time DOE welcomes opening remarks 

(including from Web participants) on the NOPR for 

the HID Lamp Test Procedures.
Building Technologies Program 5 eere.energy.gov

Issues for Comment

Issue Box: DOE welcomes comment concerning the 

proposed HID lamp test procedures. Throughout this 

presentation, issues will be raised for discussion on slides in 

boxes like this, with identifying numbers corresponding to 

those in the HID Lamp Test Procedures NOPR. 

Issue box numbering corresponds to the list of issues published at the end of 

the Test Procedures NOPR published December 15, 2011: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hid_tp_nopr

_fr_notice_2011_12_15.pdf

Comment Period Ends: Tuesday, February 28, 2012
Building Technologies Program 6 eere.energy.gov

Public Meeting Agenda

2 Proposed HID Lamp Test Procedures

3 Closing Remarks

1 Statute and Context
Building Technologies Program 7 eere.energy.gov

Regulatory History – Test Procedure

Energy Policy and 

Conservation Act (EPCA), 

1975 

HID Notice of Determination 

75 FR 37975 

(July 1, 2010)

Established energy conservation standards and 

methods of test procedure development for 

consumer products. 

DOE issued a final determination that standards 

and test procedures are technically feasible, 

economically justified, and result in energy savings.

Current test procedures 

rulemaking 

76 FR 77914

(Dec. 15, 2011)

DOE proposed test procedures for HID lamps 

based on a review of industry standards and a 

review of technical aspects of the technology and 

measurement.
Building Technologies Program 8 eere.energy.gov

Test Procedures Rulemaking 

Process/ Schedule

Milestone Date

HID Test Procedures NOPR Issued, 76 FR 77914

Beginning of 75 day comment period

December 15, 2011

End of 75 day Comment Period February 28, 2012

Final rule to establish any final test procedures for HID lamps 

(projected) January 1, 2013

NOPR Final

Rule

Today
Building Technologies Program 9 eere.energy.gov

Industry Standards for HID Lamps

(CIE Standards)

CIE* Standards

Standard Subject

CIE 13.3 - 1995

Method of Measuring and 

Specifying Color Rendering 

of Light Sources

CIE 15 - 2004 Colorimetry

 These CIE standards are proposed to be incorporated by reference 

into 10 CFR part 431

*International Commission on Illumination (Commission Internationale de l’Eclairage (CIE))
Building Technologies Program 10 eere.energy.gov

Outdated Reference 

Standards

Updated or Current 

Standard

Subject

ANSI C78.386 -1989

(Mercury Lamps)

ANSI C78.389-R2009

-for Electric Lamps

-High-Intensity Discharge

-Methods of Measuring 

Characteristics

ANSI C78.387 - 1990 

(Metal Halide Lamps)

ANSI C78.388 - 1989 

(High Pressure Sodium Lamps)

NA ANSI C78.379-2006 

-for Electric Lamps

-Classification of the Beam 

Patterns of Reflector 

Lamps

Industry Standards for HID Lamps

(ANSI Standards)

ANSI* Standards

 ANSI standards are proposed to be incorporated into 10 CFR part 431

* American National Standards Institute
Building Technologies Program 11 eere.energy.gov

Industry Standards for HID Lamps

(IES Standards)

IES* Standards

Current Standard Subject

LM-47-01

Approved Method for Life Testing of High 

Intensity Discharge (HID) Lamps

(for testing of lumen maintenance)

LM-51-00

Approved Method for the Electrical and 

Photometric Measurements of High 

Intensity Discharge Lamps

 LM-47 and 51 are proposed to be incorporated by reference into 10 

CFR part 431

* Illuminating Engineering Society of North America (IES formerly abbreviated as IESNA)
Building Technologies Program 12 eere.energy.gov

• HID lamps are considered to be commercial equipment.

• HID lamps do not operate in either standby or off mode.

• Therefore no measure of standby and/or off mode 

energy use for HID lamps is included in this NOPR. 

No Measure of Standby Mode and 

Off Mode Energy Usage
Building Technologies Program 13 eere.energy.gov

Public Meeting Agenda

2 Proposed HID Lamp Test Procedures

3 Closing Remarks

1 Statute and Context
Building Technologies Program 14 eere.energy.gov

Definitions

Test Methods for Measuring Energy Efficiency of HID 

Lamps

Laboratory Accreditation Program

Test Measurements and Calculations

Proposed HID Lamp Test Procedures
Building Technologies Program 15 eere.energy.gov

• The following definitions from EPCA are relevant to the HID lamp 

test procedures. 

• DOE proposes to adopt without modification these definitions: 

“ballast” “color rendering index” 

“correlated color temperature” “high-intensity discharge lamp” 

“mercury vapor lamp” “metal halide lamp” 

Ref: 42 U.S.C. 6291 (58), (30)(J), (30)(K), (46), (47)(A), and (63) 

 

Existing Definitions –

No Amendment
Building Technologies Program 16 eere.energy.gov

• The following definitions from 10 CFR part 430 are relevant to the 

HID lamp test procedures. 

• DOE proposes to adopt with minor modifications these definitions: 

“lamp electrical power input” “lamp wattage”

“lumen maintenance” “rated luminous flux or rated lumen output”

Ref: 10 CFR 430.2, subpart R, 42 U.S.C (30)(O), 10 CFR 430.2, Subpart B, 

appendix W, sections (2)(c) and (2)(d).

Existing Definitions –

Requiring Amendment
Building Technologies Program 17 eere.energy.gov

• Additional definitions are necessary for the HID lamps test 

procedures in order to provide a comprehensive test procedure that 

produces consistent and reproducible test measurement results. 

• DOE proposes that the following new definitions are needed for the 

HID test procedures:

“beam angle” “directional lamp” 

“high-pressure sodium lamp” “lamp efficacy”

“self-ballasted lamp” “basic model”

New Definitions for HID Lamps
Building Technologies Program 18 eere.energy.gov

• DOE proposes to distinguish directional lamps by distribution rather than 

lamp construction. 

• DOE’s proposed definition of directional lamp is based on the current 

European Union definition (Commission Regulation (EC) No 244/2009).

• The proposed definition for “directional lamp” is: 

‘Directional lamp’ means a lamp emitting at least 80 percent light output within a solid 

angle of π steradians (corresponding to a cone with an angle of 120 degrees).

• DOE proposes to use the industry-accepted practice for beam angle 

measurement as specified in ANSI C78.379 

• The proposed definition for “beam angle” is: 

‘Beam angle’ means the beam angle (or angles) as measured according to the 

requirements of ANSI C78.379, including complex beam angles as described in ANSI 

C78.379, appendix A. 

New Definitions for HID Lamps

(directional lamp, beam angle)
Building Technologies Program 19 eere.energy.gov

• DOE is proposing a definition for high-pressure sodium lamp (HPS)

– recommended by NEMA in response to the HID lamps notice of 

proposed determination (75 FR 22031) and

– based on the one given for “HPS lamps” in ANSI C82.9-1996, 

“American National Standard for High-Intensity Discharge and LowPressure Sodium Lamps, Ballasts and Transformers – Definitions 

(ANSI C82.9).” 

• The proposed definition for “high-pressure sodium lamp” is: 

‘High-pressure sodium lamp’ means a high-intensity discharge lamp in which the major 

portion of the light is produced by radiation from sodium vapor operating at a partial 

pressure of about 6,670 pascals (approximately 0.066 atmospheres or 50 torr) or 

greater.

New Definitions for HID Lamps

(high-pressure sodium lamps)
Building Technologies Program 20 eere.energy.gov

• For the proposed rule DOE proposes to adopt and amend the 

existing definition for lamp efficacy from 10 CFR 430 Subpart B, 

Appendix R by: 

– replacing “lamp lumen output” with “rated luminous flux or rated 

lumen output” and 

– adding the abbreviation “lm/W” after “lumens per watt.”

• The proposed modified definition for “lamp efficacy” is: 

‘Lamp efficacy’ means the ratio of rated lumen output (or rated luminous flux) to the 

measured lamp electrical power input in watts, rounded to the nearest tenth, in units 

of lumens per watt (lm/W).”

New Definitions for HID Lamps

(lamp efficacy)
Building Technologies Program 21 eere.energy.gov

• DOE proposes test procedures for self-ballasted HID lamps (those 

that require no external ballast).

• DOE proposes a definition for self-ballasted lamps based on that 

used for self-ballasted CFL lamps. (10 CFR part 430, subpart B, 

Appendix W)

• The proposed definition for a “self-ballasted lamp” for HID lamps is:

‘Self-ballasted lamp’ means a lamp unit that incorporates, all elements that are 

necessary for the starting and stable operation of the lamp in a permanent 

enclosure, and does not include any replaceable or interchangeable parts.” 

New Definitions for HID Lamps

(self-ballasted lamp)
Building Technologies Program 22 eere.energy.gov

• To demonstrate compliance with an efficacy standard for HID lamps, 

manufacturers must test each “basic model” (10 CFR 429.11)

• The proposed definition for a HID lamp “basic model” is:

‘Basic model’ with respect to HID lamps means all units of a given type of covered 

equipment (or class thereof) manufactured by one manufacturer, having the same 

primary energy source and which have essentially identical electrical, physical, and 

functional (or hydraulic) characteristics that affect energy consumption, energy 

efficiency, water consumption, or water efficiency, and are rated to operate a given 

lamp type and wattage.”

New Definitions for HID Lamps

(basic model)

Issue 1a: DOE invites comment on the proposed new definitions.
Building Technologies Program 23 eere.energy.gov

• DOE proposes to amend the existing definition for “ballast efficiency” 

to distinguish the values “Pin”, “Pout” and “lamp electrical power input”

• The proposed modified definitions for “ballast efficiency” is follows:

‘Ballast efficiency’ means, in the case of a high-intensity discharge fixture, 

the efficiency of a lamp and ballast combination, expressed as a 

percentage, and calculated in accordance with the following formula: 

Efficiency = Lamp electrical power input / Ballast power input 

Existing Definitions 

Requiring Amendment

Issue 1b: DOE invites comment on the proposed amendments to 

existing definitions and whether alternative amendments would be 

more appropriate for HID lamp testing.
Building Technologies Program 24 eere.energy.gov

Proposed HID Lamp Test Procedure

Definitions

Test Methods for Measuring Energy Efficiency of HID 

Lamps

Laboratory Accreditation Program

Test Measurements and Calculations
Building Technologies Program 25 eere.energy.gov

• Proposed Test Conditions (ANSI C78.389):

– Ambient temperature 25 oC ± 5 oC

– Air speed ≤ 0.5 meters per second (m/s)

Issue 2: DOE requests comment on the proposed ambient test 

temperature requirements. 

Issue 3: DOE requests comment on the proposal to adopt for 

HID lamps the same air speed requirements as DOE required for 

the MH Lamp Ballast Test Procedure (2010). 

Test Method for HID Lamps 

(proposed test conditions)
Building Technologies Program 26 eere.energy.gov

• To determine HID lamp efficacy and color parameters, the proposed 

test procedures requires measurement of the photometric and 

electrical characteristics of the lamps 

Electric Photometric

line voltage total luminous flux (lumens (lm))

lamp voltage luminous intensity (candelas (cd))

lamp current correlated color temperature (CCT) 

power input color rendering index (CRI)

• Proposed measurement details are derived from ANSI C78.389 and 

LM-51

Test Method for HID Lamps 

(electric and photometric measurements)
Building Technologies Program 27 eere.energy.gov

Test Method for HID Lamps 

(power supply characteristics)

• DOE proposes power supply characteristics requirements for these 

HID lamps test procedures that are derived from ANSI C78.389 and 

LM-51:

– Voltage supply waveshape must be sinusoidal 

– Root-mean-square (rms) sum of harmonic components must be less than 

3% of the fundamental frequency

– Voltage regulation within ± 0.1% (from LM-51)

– Power source impedance must be less than or equal 2% of the reference 

ballast impedance 

– Kilovolt-amperes rating of variable autotransformers or other voltage 

transformation devices should be at least five times the test lamp’s normal 

wattage

Issue 4: DOE invites comments on the proposal to adopt the 

waveshape, voltage regulation, and power source impedance 

requirements of ANSI C78.389 in part and LM-51.
Building Technologies Program 28 eere.energy.gov

Test Method for HID Lamps 

(reference ballast requirements)

Issue 5: DOE invites comments on the proposed reference ballast 

requirements and the appropriateness of adopting the requirements 

as recommended by ANSI C78.389.

• DOE proposes that lamps are to be operated with an appropriately 

rated reference ballast 

– Provide specified power, voltage and current (ANSI C78.389. sec 3.4.)

– Readily available

– Other ballasts may provide results that are not consistent, only valid for 

specific ballast and circuit
Building Technologies Program 29 eere.energy.gov

Test Method for HID Lamps 

(instrumentation requirements)

• Proposed HID test procedures adopt the instrumentation 

requirements of ANSI C78.389 for electrical measurements and 

LM-51 for photometry

• For electrical measurements these are:

– Better than 0.75% accuracy in the frequency range of 40 to 1000 Hz.

– Voltage drop and current draw caused by impedance must be within 

specified limits for each lamp type

• For light output and color measurement these are:

– Photometer with an approximate V-lambda (V(λ)) spectral response 

– Integrating sphere used for total luminous flux measurements

Issue 6: DOE invites comments on the proposed instrumentation 

specifications and the appropriateness of adopting these requirements 

from ANSI C78.389, section 3.8, and LM-51, section 9.0.
Building Technologies Program 30 eere.energy.gov

Test Method for HID Lamps 

(sampling method)

• Proposed sampling method to be adopted from the 

GSFL/GSIL/IRL sampling plan - 10 CFR 429.27

– Sample of 21 units over a 12-month production period.

– Use true mean lamp characteristics values for sample group 

measurement data (e.g., lumen output, lumens per watt, CCT and 

CRI)

• For each basic model of HID lamps:

– Measurement results for all samples averaged over 12-month period

– Each lamp characteristic sample mean derated and confidence limit 

set to 95%

– Each lamp characteristic mean value no greater than the lower of the 

mean of the sample or the lower 95% confidence limit divided by 0.97

Issue 7: DOE invites comments and data on the precision and 

applicability of the proposed sampling method. 
Building Technologies Program 31 eere.energy.gov

• Prior to testing, DOE proposes that all lamps be “aged” 100 hours in the 

burning position that would be used during testing (ANSI C78.389)

• DOE proposes that all lamps be warmed up sufficiently and checked for 

stabilized operation prior to measurement to obtain reproducible and 

consistent measurements. (ANSI C78.389) 

Test Method for HID Lamps 

(aging and stabilization)

Table III.1 ANSI C78.389 HID Lamp Warm-Up and Stabilization Criteria

Lamp Type Lamp Warm-Up Time Stabilization Criteria

MV 15–20 mins

3 successive measurements (voltage and current)

5 minute measurement intervals

Change in value < 1.0%

HPS 1 hour

3 successive measurements (voltage and current)

10-15 minute measurement intervals

Change in value < 1.0%

MH 6 hours operated within 

10% rated wattage

3 successive measurements (voltage and current)

10-15 minute measurement intervals

Change in value < 3.0%

Issue 8: DOE invites comments and data on the applicability of the 

proposed 100-hour aging requirement and stabilization methods.
Building Technologies Program 32 eere.energy.gov

Test Method for HID Lamps 

(cool down and re-stabilization)

• DOE proposes HID lamp transfer and re-stabilization 

requirements that vary by lamp type

– MV lamps do not require prior cooling prior to transfer

– MH lamp orientation must not change else longer re-stabilization times 

 will be required

– HPS lamps must be cooled and will require 1 hour warm up time

• DOE proposes detailed lamp stabilization, re-stabilization and lamp 

transfer requirements for the various HID lamp types, as described 

in ANSI C78.389

Issue 9: DOE has proposed lamp cool down and re-stabilization 

methods for HID lamps and invites comments on whether an 

alternative re-stabilization method should be considered. 
Building Technologies Program 33 eere.energy.gov

Test Method for HID Lamps 

(lamp orientation)

• DOE proposes the lamp orientation requirements in ANSI C78.389

• Orientation is critical for aging, stabilization, and testing of HID 

lamps

• DOE proposes lamps marked “universal” or that lack a specified position 

be operated in the base up position

• DOE proposes lamps for use in a specified operating position be tested 

in that specified position

Issue 10: DOE invites comments on the appropriateness of the lamp 

orientation requirements in section 3.6 of ANSI C78.389 that require 

base up unless otherwise specified. 

DOE also seeks comments on whether a preferred lamp orientation 

exists for lamp ballast testing.
Building Technologies Program 34 eere.energy.gov

Test Method for HID Lamps

(directional lamps)

• DOE proposes that HID lamp test procedures for directional lamps 

with a discernible beam pattern include determination of the beam 

angle

• Beam angle is calculated using the results of goniophotometric

testing 

• DOE proposes set-up and measurement of directional lamps be 

done following ANSI C78.379

Issue 11: DOE invites comments on the proposed setup and 

measurement standard selection for directional lamps based on ANSI 

C78.379. 

DOE also invites comments on the various methods for calculating 

beam angle. 
Building Technologies Program 35 eere.energy.gov

Proposed HID Lamp Test Procedure

Definitions

Test Methods for Measuring Energy Efficiency of HID 

Lamps

Laboratory Accreditation Program

Test Measurements and Calculations
Building Technologies Program 36 eere.energy.gov

• DOE proposes that testing be conducted by independent test 

laboratories that are also accredited by the National Voluntary 

Laboratory Accreditation Program (NVLAP) or by an accrediting 

organization recognized by NVLAP

• DOE proposes that a manufacturer's or importer's own laboratory, if 

accredited by NVLAP or by an accrediting organization recognized 

by NVLAP, may conduct the applicable testing

Laboratory Accreditation Program

Issue 12: DOE requests comment on the proposal to require NVLAPaccredited (or equivalent) laboratories for testing similar to as DOE 

required in the GSFL/IRL/GSIL test procedure (issued Dec 2011).
Building Technologies Program 37 eere.energy.gov

Proposed HID Lamp Test Procedure

Definitions

Test Methods for Measuring Energy Efficiency of HID 

Lamps

Laboratory Accreditation Program

Test Measurements and Calculations
Building Technologies Program 38 eere.energy.gov

• 100 hour lamp aging

• Lamp stabilization and re-stabilization if necessary

• Measure electrical and photometric characteristics 

– voltage, current → power

– Light Output → lumens (integrating sphere)

– Light Output → color (spectroradiometer)

– Light Output → distribution (goniophotometer)

• Calculate lamp efficacy (lumens/watts)

• Calculate color values (CCT and CRI)

– DOE is considering use of color values in establishing product 

classes for energy conservation standards

• Repeat for entire test sample group calculate group statistics.

Test Measurements and Calculations

Use methods in ANSI C78.379 annex A, CIE 13.3, 15; IESNA LM-47, annex; and LM-51.

start

finish
Building Technologies Program 39 eere.energy.gov

Test Measurements and Calculations

Issue 13: DOE invites comments and data on the suitability of the 

proposed* measurement and calculation procedures for lamp 

efficacy, center beam intensity, beam angle, lumen maintenance, 

and color characteristics (CCT and CRI).

*ANSI C78.379, annex A; CIE 15 and 13.3; IESNA LM-47; and LM-51
Building Technologies Program 40 eere.energy.gov

Public Meeting Agenda

2 Proposed HID Lamp Test Procedure

3 Closing Remarks

1 Statute and Context
Building Technologies Program 41 eere.energy.gov

Closing Remarks

At this time DOE welcomes any closing 

remarks from interested parties.
Building Technologies Program 42 eere.energy.gov

• In all correspondence, include all of the following:

– Test Procedures for High-Intensity Discharge Lamps

– Docket Number: EERE-2011-BT-TP-0044

– Regulatory Identification Number (RIN):1904-AC37

• Contact Information

Email: HIDLamps-2010-TP-0044@ee.doe.gov

URL:http://www1.eere.energy.gov/buildings/appliance_standards/co

mmercial/high_intensity_discharge_lamps.html

Postal Mail: Courier:

Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program Building Technologies Program

Mailstop EE-2J 950 L’Enfant Plaza, S.W., 6th Floor

1000 Independence Avenue S.W. Washington, D.C. 20024

Washington, D.C. 20585-0121

Submission of Comments

Comment period closes: Tuesday, February 28, 2012
Building Technologies Program 43 eere.energy.gov

 Back Up SLIDES

Backup Slides
Building Technologies Program 44 eere.energy.gov

Test Method for HID Lamps

Lamp Type Lamp Warm-Up Time Stabilization Criteria

MV 15–20 mins

3 successive measurements (voltage and current)

5 minute measurement intervals

Change in value < 1.0%

HPS 1 hour

3 successive measurements (voltage and current)

10-15 minute measurement intervals

Change in value < 1.0%

MH

6 hours

Operated within 10% 

rated wattage

3 successive measurements (voltage and current)

10-15 minute measurement intervals

Change in value < 3.0%

Table III.1 ANSI C78.389 HID Lamp Warm-Up and Stabilization Criteria

Lamp Type Cooling Requirement Re-stabilization Time

MV None

Not in standard

Reconfirm stabilized operations upon 

transfer/restrike

HPS Allow to cool for 1 hour minimum 

before relocating

Not in standard

Reconfirm stabilized operations upon 

transfer/restrike

MH Cool to below 60 oC if relocating

No relocation no reorientation – 30 minutes

Relocation with no reorientation – 30 minutes

Reorientation – 6 hours

Table III.2 ANSI C78.389 HID Lamp Cool Down and Re-stabilization 

Requirements 
Building Technologies Program 45 eere.energy.gov

ANSI C78.389 HID Lamp Test Electrical Circuit Diagram

Test Method for HID Lamps
Building Technologies Program 46 eere.energy.gov

Issue 1a: DOE invites comment on the proposed new definitions.

Issue 1b: DOE invites comment on the proposed amendments to existing 

definitions and whether alternative amendments would be more appropriate for 

HID lamp testing.

Issue 2: DOE requests comment on the proposed ambient test temperature 

requirements. 

Issue 3: DOE requests comment on the proposal to adopt for HID lamps the 

same air speed requirements as DOE required for the MH Lamp Ballast Test 

Procedure (2010).

Issue 4: DOE invites comments on the proposal to adopt the waveshape, 

voltage regulation, and power source impedance requirements of ANSI 

C78.389 in part and LM-51.

Issue 5: DOE invites comments on the proposed reference ballast 

requirements and the appropriateness of adopting the requirements as 

recommended by ANSI C78.389.

Requests for Comment in TP NOPR
Building Technologies Program 47 eere.energy.gov

Issue 6: DOE invites comments on the proposed instrumentation specifications 

and the appropriateness of adopting these requirements from ANSI C78.389, 

section 3.8, and LM-51, section 9.0.

Issue 7: DOE invites comments and data on the precision and applicability of 

the proposed sampling method.

Issue 8: DOE invites comments and data on the applicability of the proposed 

100-hour aging requirement and stabilization methods.

Issue 9: DOE has proposed lamp cool down and re-stabilization methods for 

HID lamps and invites comments on whether an alternative re-stabilization 

method should be considered. 

Issue 10: DOE invites comments on the appropriateness of the lamp 

orientation requirements in section 3.6 of ANSI C78.389 that require base up 

unless otherwise specified. 

DOE also seeks comments on whether a preferred lamp orientation exists for 

lamp ballast testing. 

Requests for Comment in TP NOPR
Building Technologies Program 48 eere.energy.gov

Issue 11: DOE invites comments on the proposed setup and measurement 

standard selection for directional lamps based on ANSI C78.379. 

DOE also invites comments on the various methods for calculating beam angle. 

Issue 12: DOE requests comment on the proposal to require NVLAPaccredited (or equivalent) laboratories for testing similar to as DOE required in 

the GSFL/IRL/GSIL test procedure (issued Dec 2011).

Issue 13: DOE invites comments and data on the suitability of the proposed* 

measurement and calculation procedures for lamp efficacy, center beam 

intensity, beam angle, lumen maintenance, and color characteristics (CCT and 

CRI).

*ANSI C78.379, annex A; CIE 15 and 13.3; IESNA LM-47; and LM-51. 

Requests for Comment in TP NOPR