2

- i CHAPTER 2. ANALYTICAL FRAMEWORK

TABLE OF CONTENTS

2.1 INTRODUCTION

................................ ................................ ................................ ........... 2

- 1

2.2 BACKGROUND

................................ ................................ ................................ ............. 2

- 2

2.2.1 History of Standards Rulemakings for Metal Halide Lamp Fixtures and Regulatory Authority

................................ ................................ ........................... 2

- 2

2.2.2 Test Procedure

................................ ................................ ................................ ..... 2

- 5

2.2.3 Stan dby and Off Mode Energy Consumption

................................ ...................... 2

- 7

2.3 SCOPE OF COVERAGE

................................ ................................ ................................ 2

- 9

2.3.1 Scope of Existing Energy Conservation Standards

................................ ............. 2

- 9

2.3.2 Scope of Energy Conservation Standards Rulemaking

................................ ....... 2

- 9 2.3.2.1 System Approach

................................ ................................ ..................... 2

- 9 2.3.2.2 Expansion of Coverage of Energy Conservation Standards

.................. 2

- 18

2.3.3 Summary

................................ ................................ ................................ ............ 2

- 21

2.4 MARKET AND TECHNOLOG Y ASSESSMENT

................................ ...................... 2

- 22

2.4.1 Market Assessment

................................ ................................ ............................ 2

- 22 2.4.1.1 Manufacturers of Metal Halide Lamp Fixtures

................................ ..... 2

- 22 2.4.1.2 Manufacturers of Metal Halide Lamp Bal lasts

................................ ...... 2

- 23 2.4.1.3 Regulatory and Non

- Regulatory Programs

................................ ............ 2

- 24 2.4.1.4 Metal Halide Lamp Fixture Shipments

................................ .................. 2

- 24

2.4.2 Technology Assessment

................................ ................................ ..................... 2

- 26

2.4.3 Equipment Classes

................................ ................................ ............................. 2

- 29

2.5 SCREENING ANALYSIS

................................ ................................ ............................ 2

- 36

2.6 ENGI NEERING ANALYSIS

................................ ................................ ........................ 2

- 37

2.6.1 Preliminary Engineering Analysis Approach

................................ .................... 2

- 38

2.6.2 Manufacturing Selling Price Analysis

................................ ............................... 2

- 41

2.6.3 Lumen Maintenance

................................ ................................ ........................... 2

- 42

2.6.4 Representative Wattages and Fixture Types

................................ ...................... 2

- 43

2.6.5 Baseline Models and Candidate Standard Levels Analyzed

.............................. 2

- 44

2.6.6 Candidate Standard Levels

................................ ................................ ................ 2

- 45

2.6.7 Prices and Results

................................ ................................ .............................. 2

- 46

2.6.8 Overall Engineering Summary

................................ ................................ .......... 2

- 47

2.7 ENERGY USE AND END

- USE LOAD CHARACTERIZ ATION

............................. 2

- 47

2.8 MARKUP ANALYSIS

................................ ................................ ................................ .. 2

- 48

2.9 LIFE

- CYCLE COST AND PAYBA CK PERIOD ANALYSES

................................ .. 2

- 50

2.10 SHIPMENTS ANALYSIS

................................ ................................ ............................ 2

- 51

2.11 NATIONAL IMPACT ANAL YSIS

................................ ................................ .............. 2

- 52

2.11.1 National Energy Savings Analysis

................................ ................................ ..... 2

- 52

2.11.2 Net Present Value Analysis

................................ ................................ ............... 2

- 52

2.11.3 Efficiency Scenarios and Trends

................................ ................................ ....... 2

- 53

2.12 LIFE

- CYCLE COST SUBGROUP ANALYSIS

................................ .......................... 2

- 53

2.13 MANUFACTURER IMPACT ANALYSIS

................................ ................................ .. 2

- 54

2.13.1 Sources of Information for the Manufacturer Impact Analysis

......................... 2

- 55

2.13.2 Industry Cash

- Flow Analysis

................................ ................................ ............. 2

- 562

- i i 2.13.3 Manufacturer Subgroup Analysis

................................ ................................ ...... 2

- 56

2.13.4 Competitive Impacts Assessment

................................ ................................ ...... 2

- 56

2.13.5 Cumulative Regulatory Burden

................................ ................................ ......... 2

- 57

2.13.6 Preliminary Results for the Manufacturer Impact Analysis

.............................. 2

- 57 2.13.6.1 System Approach

................................ ................................ ................. 2

- 57

2.13.6.2 Absence of Electronic Ballast ANSI Standards

................................ ... 2

- 58 2.13.6.3 Testing Burden

................................ ................................ ..................... 2

- 58 2.13.6.4 Technology Shift

................................ ................................ .................. 2

- 58 2.13.6.5 Impacts on Profitability

................................ ................................ ........ 2

- 58 2.13.6.6 Product Conversion Costs/Diminishing Returns to Consumers

.......... 2

- 58

2.13.6.7 Product Innovation

................................ ................................ ............... 2

- 59

2.14 UTILITY IMPACT ANALY SIS

................................ ................................ ................... 2

- 59

2.15 EMPLOYMENT IMPACT AN ALYSIS

................................ ................................ ....... 2

- 59

2.16 ENVIRONMENTAL ASSESS MENT

................................ ................................ .......... 2

- 60

2.16.1 Carbon Dioxide

................................ ................................ ................................ .. 2

- 60

2.16.2 Sulfur Dioxide

................................ ................................ ................................ .... 2

- 60

2.16.3 Nitrogen Oxides

................................ ................................ ................................ . 2

- 61

2.16.4 M ercury

................................ ................................ ................................ .............. 2

- 61

2.16.5 Particulate Matter

................................ ................................ ............................... 2

- 61

2.17 MONETIZING CARBON DI OXIDE AND OTHER EMIS SIONS

............................. 2

- 62

2.18 REGULATORY IMPACT AN ALYSIS

................................ ................................ ....... 2

- 63

LIST OF TABLES

Table 2.1 Estimated Historical Shipments of Metal Halide Lamp Fixtures from 1993

– 2008

.. 2

- 25

Table 2.2 Metal Halide Lamp Ballast Technology Options

................................ ...................... 2

- 29 Table 2.3 Equipment Class Summary

................................ ................................ ........................ 2

- 36

Table 2.4 Representative Wattages and Fixtures Types

................................ ............................ 2

- 44

Table 2.5 Baseline Models for the 1000 W Representative Wattage

................................ ........ 2

- 45 Table 2.6 1000 W Representative Wattage Engineering Summary

................................ .......... 2

- 47 Table 2.7 Summary of Baseline and Candidate Standard Levels for Metal Halide Lamp Fixture Equipment Classes

................................ ................................ ............................. 2

- 47 Table 2.8 Summary of Manufacturer Selling Prices for Metal Halide Lamp Fixture Representative Equipment Classes

................................ ................................ .... 2

- 47

LIST OF FIGURES

Figure 2.6.1 Full Production Costs

................................ ................................ ............................ 2

- 41 Figure 2.8.1 Metal Halide Lamp Fixture Distribution Channel

................................ ................ 2

- 492

- 1 CHAPTER 2. ANALYTICAL FRAMEWORK

2.1 INTRODUCTION

Chapter 2 describes the analytical framework that the U.S. Department of Energy (DOE) is using to develop energy conservation standards for metal halide lamp fixtures, including a description of the methodology, the analytical tools, and the relationships among the various analyses that are part of this rulemaking. This chapter also provides an overview of the preliminary activities DOE conducted and discusses the comments it received. In addition, chapter 2 provides additional detail on key issues identifi ed in the executive summary. Finally, chapter 2 provides citations and cross

- references to the other chapters of the preliminary technical support document (TSD) that address DOE ’ s analytical approach, inputs, and findings.

The analyses presented in this preliminary TSD include:

**•** a market and technology assessment that characterizes the metal halide lamp fixtures markets, and reviews technologies and designs that improve ballast efficiency;

**•** a screening analysis that reviews technology options to improve b allast efficiency and considers them according to four prescribed screening criteria;

**•** an engineering analysis that determines the manufacturer selling prices (MSPs) associated with more energy effi cient metal halide lamp fixtures by estimating the

manufact uring production cost (MPC) and applying a manufacturer markup;

**•** an energy use characterization that generates energy use estimates for metal halide lamp fixtures;

**•** a markup analysis that converts average MSPs to consumer installed prices;

**•** a life

- cycle cost (LCC) analysis that calculates, at the consumer level, the discounted savings in operating costs throughout the estimated average life of the fixture, compared to any increase in the installed costs likely to result directly from imposition of the standar d;

**•** a payback period (PBP) analysis to estimate the amount of time it takes consumers to recover the higher purchase expense of more energy efficient fixtures through lower operating costs;

**•** a shipments analysis that estimates shipments of metal halide lamp fixtures over the time period examined in the analysis;

**•** a national impact analysis (NIA) that assesses the aggregate national impacts of potential energy conservation standards as measured by the net present value (NPV) of total consumer economic impacts and national energy savings (NES); and

**•** a preliminary manufacturer impact analysis (MIA) that begins to evaluate the effects on manufacturers that may result from amended energy conservation standard.

DOE may revise any of its analyses based on comments an d new information received. The analyses DOE will perform in the subsequent notice of proposed rulemaking (NOPR) stage

includ e the following :2

- 2 **•** an LCC subgroup analysis that evaluates the economic impacts on identifiable groups

of customers of metal halide lamp fixtures, including various categories of fixtures purchasers or owners who may experience disproportionate impacts from a national energy conservation standard;

**•** a manufacturer impact analysis that estimates the financial impact of standards on

fixtu res and ballast manufacturers and calculates impacts on competition, employment at manufacturing plant s , and manufacturing capacity;

**•** a utility impact analysis that estimates the effects of proposed standards on the installed capacity and the generating bas e of electric utilities;

**•** an employment impact analysis that estimates the impacts of standards on net jobs eliminated or created in the general economy as a consequence of increased spending on the installed price of fixtures and reduced customer spending on energy;

**•** an environmental assessment to provide estimates of the effects of amended energy conservation standards on emissions of carbon (CO 2 ), sulfur dioxide (SO 2 ), nitrogen oxides (NO X

**•** a regulatory impact analysis (RIA) that pre sents major alternatives to proposed standards that may achieve comparable energy savings at a reasonable cost. ), and mercury (Hg); and

DOE developed this analytical framework and documented its findings in the Energy Conservation Standards Rulemaking Framework Document for Metal Halide Lamp Fixtures

, published on Dec ember 18, 2009. a DOE presented the analytical approach to interested parties during a public meeting held on January 26, 2010.

In response to the publication of the framework document and the public meeting, D OE received comments from interested parties on its analytical approach. This chapter summarizes the key comments DOE received, describes DOE’s responses, and summarizes any significant changes in the analytical approach made since DOE published the framew ork document. Lastly, in the executive summary of the preliminary TSD, DOE identifies issues on which it seeks public comment, each of which is explained in the subsequent sections.

2.2 BACKGROUND

2.2.1 History of Standards Rulemakings for Metal Halide Lamp Fixtures and Regulatory Authority
Title III of the Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. No. 94

- 163, (42 United States Code (U.S.C.) 6291 et seq .) established an energy conservation program for major household appliances and industrial and com mercial equipment. More specifically, part A of Title III (42 U.S.C. 6291

- 6309) establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” Subsequent amendments to EPCA have given DOE the authority to regulate the energy ef ficiency of several additional kinds of equipment including certain metal halide lamp fixtures, which are the focus of this document.

a The framewo rk document is available at http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/mh_ecs_framework.pdf

.2

- 3 The following summarizes the pertinent legislative and regulatory history for metal halide lamp fixtures. DOE is conducti ng its first rulemaking cycle 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) , which reads as follows:

(2) Final rule by January 1, 2012.

— (A) In general.

— Not later than January 1, 2012, the Secretary shall publish a final rule to determine whether the standards established under paragraph (1) should be

amended. (B) Administration.

— The final rule shall

— (i) contain any amended standard; and (ii) apply to products manufactured on or after January 1, 2015. (4) D esign and performance requirements.

— Notwithstanding any other provision of law, any standard established pursuant to this subsection may contain both design and performance requirements.

By way of background, on December 19, 2007 the President signed the Energy Independence and Security Act of 2007 (EISA 2007)

, which made numerous amendments to EPCA and directed DOE to undertake several new rulemakings for applia nce energy conservation standards. (Pub. L. No. 110

- 140) The metal halide lamp fixture provisions, section

324 of EISA 2007

, amended EPCA by:

**•** inserting definitions pertaining to “metal halide ballast,” b “metal halide lamp,” c and “metal halide lamp fixtures” d

**•** amending section 323(b) of EPCA to direct DOE to develop a test procedure for metal halide lamp ballasts based on the American National Standar d Institute (ANSI)

Standard C82.6

- 2005, American National Standard for Lamp Ballasts

- Ballasts for High

- Intensity Discharge (HID) Lamps

- Methods of Measurement (42 U.S.C. 6293(b)(18)); (among others) into section 321 of EPCA (42 U.S.C. 6291(62),(63), and (64));

**•** amending section 324(a)(2) of EPCA by directing the Federal Trade Commiss ion (FTC) to conduct a labeling rulemaking for metal halide lamp fixtures (42 U.S.C. 6294(a)(2)(C)); and

**•** amending section 325 of EPCA by prescribing energy conservation standards for metal halide lamp fixtures that require the equipment to contain ballasts that meet or exceed defined efficiency levels. Compliance with the EISA 2007

- prescribed standards was required as of January 1, 2009. (42 U.S.C. 6295(hh)(1)) Additionally, the Secretary is directed to publish a final rule no later than January 1, 2012 to

b “Metal halide ballast” means “a ballast used to start and operate metal halide lamps.” (42 U.S.C. 6291(62))

c “Metal halide la mp” means “a high intensity discharge lamp in which the major portion of the light is produced by radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors.” (42 U.S.C. 6291(63))

d “Metal halide lamp fixt ure” means “a light fixture for general lighting application designed to be operated with a metal halide lamp and a ballast for a metal halide lamp.” (42 U.S.C. 6291(64))2

- 4 determine whether the energy conservation standards established by EISA 2007 for metal halide lamp fixtures should be amended . I f such amended standards are appropriate under the relevant statutory criteria, the final rule shall contain amended

standards f or those products

, which shall apply to products manufactured on or after January 1, 2015. (42 U.S.C. 6295(hh)(2)). The Secretary is further directed to conduct a second rulemaking to determine whether additional amend ment of the energy conservation standa rds for metal halide lamp fixtures is required

, and to publish a corresponding final rule by January 1, 2019. (42 U.S.C. 6295(hh)(3))

The following statutory provisions are directly relevant to the energy conservation standards rulemaking for metal halid e lamp fixtures. As amended by EISA 2007, EPCA regulates metal halide lamp fixtures designed to be operated with lamps rated greater than or equal to 150 watts (W) but less than or equal to 500 W by prescribing performance requirements

for the metal halide lamp ballasts used in those metal halide lamp fixtures. Both metal halide lamps and ballasts are energy

- consuming components of metal halide fixtures. For this metal halide lamp wattage range, metal halide lamp fixtures must contain the following :

(i) a puls e

- start metal halide ballast with a minimum ballast efficiency of 88 percent; (ii) a magnetic probe

- start ballast with a minimum ballast efficiency of 94 percent; or (iii) a nonpulse

- start electronic ballast with

— (I) a minimum ballast efficiency of 92 percent for wattages greater than 250 watts;

and (II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 250

watts.

(U.S.C 6292 (hh)(1)(A))

In addition to prescribing minimum efficiency requirements for the previously

- described

metal halide la mp ballasts contained in metal halide lamp fixtures, EISA 2007 amended EPCA to exclude the following types of metal halide lamp fixtures from the statutorily

- prescribed energy

conservation standards:

(i) fixtures with regulated lag ballasts; (ii) fixtures that use electronic ballasts that operate at 480 volts; or (iii) fixtures that

— (I) are rated only for 150 watt lamps; (II) are rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and (III) contain a ballast that is rated to o perate at ambient air temperatures higher than

50 °C, as specified by Underwriters Laboratories (UL)1029

– 2001 ( “Standard for High

- Intensity

- Discharge Lamp Ballasts” )

.

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

Pursuant to section 310 of EISA 2007, EPCA further directs DOE to incorporate standby mode and off mode energy use in any amended (or new) standard adopted after July 1, 2010. (422

- 5 U.S.C. 6295(gg)(3)) Because this energy conservation standards rulemaking mu st be completed by January 1, 2012

, the requirement to incorporate standby mode and off mode energy use into the energy conservation standards analysis is applicable. The application of standby mode and off mode energy use in this rulemaking is discussed i n detail in section 2.2.3

.

The following statutory provisions (and associated rulemakings) are related to metal halide lamp fixtures but are separate from the current standards rulemaking:

**•** In conjunction with energy conservation standards for metal halide lamp fixtures, EPCA required DOE to undertake a determination to see if energy conservation standards for HID lamps (including metal halide lamps) would be te chnologically feasible and economically justified, and would result in significant energy savings. (42 U.S.C 6317(a)(1)) DOE completed the HID determination and published a final rule on July 1, 2010 tentatively concluding that energy conservation standard s for certain HID lamps are technologically feasible and economically justified.

**•** As discussed in section 2.2.2 , DOE completed a test procedure rulemaking for metal halide lamp ballasts, as required by EPCA through amendments from EISA 2007. (U.S.C 6293(b)(18)) The final rule test procedure for metal halide lamp ballasts was published in the Federal Register on March 10, 2010. 75 FR 10950

.

**•** The FTC is directed to condu ct a labeling rulemaking as part of the requirements set forth by EISA 2007 for metal halide lamp fixtures. (42 U.S.C. 6294(a)(2)(C)) To this end, the FTC published a final rule in the Federal Register on July 9, 2008

, amending 16 CFR part 305, “Rule Conce rning Disclosures Regarding Energy Consumption and Water Use of Certain Home Appliances and Other Products Required Under the Energy Policy and Conservation Act (‘Appliance Labeling Rule’).” 73 FR 39221. On October 23, 2008 the FTC published in the Federal Register additional amendments to 16 CFR part 305 for metal halide lamp fixtures in the form of technical corrections. 73 FR 63066. Both final rules fulfilled the FTC’s obligations under EISA 2007 pertaining to labeling requirements for metal halide lamp fixtures and metal halide lamp ballasts.

2.2.2 Test Procedure
EPCA directs DOE to establish test procedures for metal halide lamp ballasts in

accord ance with ANSI Standard C82.6

- 2005, “Ballasts for High Intensity Discharge Lamps

— Methods of Measurement.” (42 U.S. C. 6293(b)(18)) DOE published the final rule test procedure for metal halide lamp ballasts on March 10, 2010

, which included definitions and test procedures for that equipment. 75 FR 10950. Additionally, the test procedure provides a method for measuring t he standby mode of metal halide lamp ballasts. If these ANSI test procedures are updated during the course of this rulemaking, DOE will consider updating its test procedure for metal halide lamp ballasts.

In response to DOE ’s request for comment on curren t test procedure for metal halide lamp ballast, the National Electrical Manufacturers Association (NEMA) suggested that DOE should continue to use the latest ANSI C82.6 test methods that should be completed in time for inclusion. (NEMA, No. 11.1 at p. 3) D OE recognizes the importance of using the latest accepted industry

- wide testing procedure for metal halide lamp ballast. When the latest version of ANSI2

- 6 C82.6 test methods does become available, DOE will evaluate revising the existing metal halide lamp ballast test procedure. DOE requests comment on the status of revisions to ANSI C82.6 and the expected changes. DOE also seeks comment on any other appropriate changes to its existing test procedure for metal halide lamp ballasts.

Addi tionally, NEMA stated that, when considering testing provisions for energy consumption in standby and off modes, metal halide lamp fixtures predominantly do not use power in the off mode and some metal halide lamp fixtures that include lighting controls ma y use power in the standby mode. (NEMA, No. 11.1 at p. 3) In the current metal halide lamp ballast test procedure, published March 10, 2010, DOE concluded that metal halide lamp ballasts in general do not use power in the off mode, and some ballasts may us e power in the standby mode to run lighting controls such as DALI

. e 75 FR 10950.

Acuity Brands Lighting advised that dimming ballasts should not be penalized in testing procedures for their small standby power consumption

, as the energy savings of operat ing the ballast at a lower wattage outweighs the minimal standby power usage. (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 16

- 17) According to the current March 2010 metal halide lamp ballast test procedure, if the ballast produces anyt hing greater than zero percent light output, it is considered to be in active mode. 75 FR 10950. Therefore, ballasts operating in a dimming mode, thus producing light, are considered to be in active mode. DOE agrees that dimming can decrease a fixture’s ov erall energy use. However, unless the dimming ballast has a control mechanism that uses power with zero percent light output, the current test procedure

treats it the same as a non

- dimming ballast.

Philips Lighting Electronics noted that the challenges af forded by efficiency measurements of electronic ballasts, especially high

- frequency electronic ballasts, require expensive equipment for accurate testing. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 85

- 86) Many organizations forg o this equipment, resulting in measurements that can be off by as much as five percent, a critical margin of error given the proposed delineations of efficiency levels. Philips also pointed out that no existing ANSI standards include a method for testing e lectronic ballasts. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 85

- 86) Additionally, Venture Lighting stated that the forthcoming 2010 version will only include testing requirements for low

- frequency electronic ballasts operating at less than 400 hertz ( Hz ) , leaving the 100 kHz ballasts’ procedure unregulated. (Venture Lighting, Public Meeting Transcript, No. 8 at p. 87) NEMA also pointed out that there are no industry ANSI standards for high

- frequency operation of HID lamps. (NEM A, No. 11.1 at p. 6)

ANSI standards for metal halide lamp ballasts , and the DOE test procedure based upon them, allow for only minimal testing variance. Faulty measurements taken with noncompliant equipment are not acceptable for making comparisons to sta ndardized levels. DOE conducted a full rulemaking f or the metal halide lamp ballast test procedure, taking the differences between electromagnetic and electronic ballast testing into consideration. DOE requested comments from industry with regard to the pr oposed test procedure and incorporated manufacturers’ comments

e DALI stands for the “Digital Addressable Lighting Interface.” It represents a syst em that enables communication between a central lighting controls system and the individual components, including the ballasts.2

- 7 into the analyses. The final rule for the test procedure was published on March 10, 2010

. 75 FR 10950. However, during the preliminary interviews

, manufacturers stated that most shipments of

el ectronic ballast s are in the low

- frequency range. The ballasts in the high

- frequency range, typically high

- wattage electronic ballasts, are not being manufactured at the same pace as low frequency

, and ballasts previously manufactured are being held in inv entory until they are sold.

For the metal halide lamp ballast test procedure final rule , DOE did not differentiate between high

- and low

- frequency electronic ballasts. Due to the lack of industry

- wide accepted testing methods for high

- frequency electronic ballasts and the infancy of the market, DOE relies on existing testing methods. W hen the forthcoming 201 1 version of ANSI C82.6 test method becomes available, DOE will evaluate revising the current metal halide lamp ballast test proced ure.

A joint comment from Pacific Gas and Electric Company, Southern California Edison, Southern California Gas Company, and San Diego Gas and Electric (hereafter “California

Investor Owned Utilities ” (CA IOUs)) recommended DOE incorporate requirements in its test procedure for measuring the power draw of controls that are integral to the fixture in order to remove the potential for gaming or confusion. (CA IOUs, No. 17.2 at p. 6) Currently, metal halide lamp fixture performance is measured by evaluating t he performance of the ballast

included in the fixture, without any other fixture component or combination of components. The DOE test procedure for metal halide lamp ballasts only include s the additional power draw of

controls in standby mode.

2.2.3 Standby an d Off Mode Energy Consumption
DOE is directed to incorporate standby mode and off mode energy use in any amended energy conservation standard adopted after July 1, 2010. (42 U.S.C. 6295(gg)(3)) As t his energy conservation standards rulemaking will be compl eted by January 1, 2012

, the requirement to incorporate standby mode and off mode energy use into the energy conservation standards analysis is applicable.

In amending 42 U.S.C. 6295(gg)(1)(A)(i), (ii), and (iii), section 310 of EISA 2007 defined

the terms “active mode,” “off mode,” and “standby mode.” “Active mode” is defined as the condition in which an energy

- using piece of equipment is connected to a main power source, has been activated, and provides one or more main functions. “Off mode” is defin ed as 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 defined as the condition in which an energy

- using piece of equipment is connect ed 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.

In developing the metal halide lamp ballast test procedure, DOE proposed adopting the statutory definitions of “active mode,” “off mode,” and “standby mode” and analyzed them to determine their applicability to metal halide lamp ballasts. DOE tentatively found that while it is possible for metal halide ballasts to operate in active mode and standby mode, the off mode2

- 8 condition d oes not apply because it addresses a mode of energy use in which metal halide ballasts do not operate. 74 FR 33171, 33175 (July 10, 2009). The definition of “off mode” requires that ballasts be connected to a main power source and not provide any standby m ode or active mode function. (42 U.S.C. 6295(gg)(1)(A)(ii)) As discussed in the current test procedure, DOE does not believe 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. Therefore, for this energy conservation standard rulemaking , DOE is only considering 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 th is rulemaking. DOE has tentatively concluded that no further consideration of power consumption in off mode is necessary.

Philips Lighting Electronics stated it was unaware of metal halide luminaires consuming power in the standby mode unless they were us ing lighting controls. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p.42) Acuity Brands Lighting noted that while not many products today have power

- consuming lighting controls while in standby mode, these products have the potential for growth in the market and sizable energy savings; these energy savings make up for power used in standby mode. (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 43

– 44) Energy Solutions requested additional information on the energy

consum ption of control components within a fixture in order for DOE to properly assess their significance. (Energy Solutions, Public Meeting Transcript, No. 8 at pp. 47

– 48) Lutron Electronics Co., Inc. added that it appeared premature to define standby limits fo r a product class that does not yet exist in the market. (Lutron Electronics Co., Inc., Public Meeting Transcript,

No. 8 at p.42)

DOE recognizes that metal halide ballasts can be designed with auxiliary control devices, which could consume energy in stan dby mode. One example of this ballast design is a DALI

enabled ballast. These ballasts may consume power in standby mode, as the internal circuitry remains on and active even when the ballast is not driving any lamps. However, through research and testing

, DOE has yet to encounter such a ballast that it could purchase . DOE continues to

search for and consider DALI

- enabled ballasts, as well as other types of metal halide lamp ballasts, to evaluate the issue of standby mode energy use in metal halide lamp fix tures. DOE tentatively concludes that it cannot establish a separate standard that incorporates standby mode energy use. DOE invites comments on the issue of standby mode and ballast designs that incorporate it.

Energy Solutions raised the question of wh ether standby power consumption includes additional sensors in a fixture, or just the ballast. Energy Solutions requested additional information on the energy consumption of other components in order for DOE to properly assess their significance. (Energy S olutions, Public Meeting Transcript, No. 8 at pp. 47

– 48) Based on manufacturer interviews and lighting control research, DOE has found that the energy consumption from additional sensors is negligible compared to the energy consumption while in

active mode. DOE has learned from interviews that the components in lighting controls other

than ballasts consume approximately two watts or less during standby m ode. The preliminary analysis TSD chapter 3 discusses the power consumption behind lighting controls in more depth.2

- 9 2.3 SCOPE OF COVERAGE

2.3.1 Scope of Existing Energy Conservation Standards

As noted in section 2.2.1 , the existing energy conservation standards for metal halide lamp fixtures are established by EPCA through amendments made by EISA 2007. ( 42 U.S.C

. 629 5 (hh)(1)(A)) EISA 2007 prescribed energy conservation standa rds for metal halide lamp fixtures by setting minimum ballast efficiency requirements for new fixtures. The performance requirements prescribed by EISA 2007 pertain to new fixtures manufactured after January 1, 2009. Currently, coverage is limited to certa in rated wattages of lamps used in the metal halide lamp fixtures (150

– 500 W ). Such lamps must be equipped with a ballast with a designated starting method (pulse

- start and probe

- start) and electronic configuration (magnetic and electronic). However, the s tatute excludes from coverage metal halide lamp fixtures with regulated lag ballasts, 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

, f and (3) contain a ball ast that is rated to operate at ambient air temperatures greater than 50 °C. g

2.3.2 Scope of Energy Conservation Standards Rulemaking
EPCA gives DOE authority to determine whether current energy conservation standards for metal halide lamp fixtures should be ame nded. (42 U.S.C. 6295(hh)(2)(A)) DOE notes that although metal halide fixtures may include both a lamp and ballast, in establishing metal halide fixture energy conservation standards

, EPCA set minimum efficiency requirements for only the ballast component of the fixture. For the framework document and during the public meeting, 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 using a system approach h

2.3.2.1 System Approach to set minimum energy conservation standards, us ing an alternative metric for metal halide lamp fixture minimum efficiency requirements, and expan ding scope to include additional fixture rated lamp wattages and EISA 2007 exempted fixtures. The following sections are the summary of comments received from interested parties and corresponding responses from

DOE

.

As previously stated, altho ugh metal halide fixtures may be composed of a metal halide lamp, ballast, and other fixture components, in establishing metal halide fixture energy conservation standards, EPCA set minimum efficiency requirements for only the ballast. In response to DOE’s request for comments on its approach to amend minimum efficiency requirements for only the ballast component of the fixture, stakeholders raised the issue of developing alternative approaches to minimum performance requirement s . In alternative approaches, DOE would develop standards that incorporated not only the ballast efficiency, but possibly the whole system including lamp efficacy, luminaire efficiency, or efficiency of other components that can be included in fixtures.

f Specifications for “wet locations” are from the National Electrical Code 2002, section 410.4(A).

g Specifications for ballas ts that operate at ambient air temperatures above 50 °C are found in UL 1029

- 2001.

h “System Approach” refers to setting an efficiency standard that applies a system of energy

- consuming components (e.g., lamp, ballast, and fixture) instead of demanding tha t any one component meet a given standard.2

- 10 The American Council for an En ergy Efficient Economy (ACEEE) ; Earthjustice and

National Consumer Law Center (NCLC) (hereafter “Earthjustice and NCLC ”) ; and a joint comment produced by the ACEEE, the Appliance Standards Awareness Project (ASAP), NCLC and the Northeast Efficiency Partner ships (NEEP) (hereafter “Joint Comment”), urged DOE to expand the proposed approach of the rulemaking beyond ballast efficiency to cover other components of metal halide lamp fixtures, such as lamps, that would represent opportunities for additional energy savings. ACEEE , Earthjustice and NCLC, and the Joint Comment warned that to not analyze other components would be counter to DOE’s mandate to establish standards that achieve the maximum technically

- feasible and economically

- justified level of energy effi ciency. (ACEEE, Public Meeting Transcript No. 8 at pp. 24

– 25 ; Earthjustice and NCLC , No. 15.1 at p. 1; Joint Comment, No. 16.1 at p. 2) ASAP noted that a system approach would allow manufacturers more opportunities to optimize efficiency according to their individual specialt ies and at the lowest cost. (ASAP, Public Meeting Transcript, No. 8 at p. 25) Acuity Brands Lighting commented that a fixture level system approach would add significant complexity to DOE’s analysis through the creation of several appli cation

- specific equipment classes . (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 26

– 27) Edison Electric Institute ( hereafter “ EEI ”) disagreed with pursuing a system approach, stating that only looking at ballast efficiency is the best approach. (EEI, No. 10.1 at p. 1) DOE recognizes that it has the authority to consider standards beyond the efficiency of the ballast included in a fixture. DOE discusses the issues associated with a system approach in the remainder of this section 2.3.2.1

.

If DOE implemented a system approach, it would need to confirm the system standards are more stringent than the existing standards. EPCA contains what is commo nly known as an

‘‘anti

- backsliding’’ provision. (42 U.S.C. 6295(o)(1)) This provision 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. Taking into consideration the backsliding provisions, an alternative system approach would need to be correlated with existing standards so that amendments do not set lower performance requirements than existing ones. Manufacturers of lamp

- ballast systems have reported that existing systems provide higher overall efficiency than high efficiency ballasts alone on a lumens per watt basis. However, if only the ballast component is examined, efficiencies are less than the

EISA 2007 establi shed standards.

Lamp

- Ballast System

In a lamp

- ballast system approach, metal halide lamp fixture s would be required to include specific lamp and ballast pairs that comply with a system lumens per watt standard. Currently, fixture manufacturers commonly ship the fixtures with the ballast installed to en sure that the fixture is compliant with fire safety requirements and meets energy conservation standards. However, there are no requirements for the same fixture to be shipped with a lamp. In general, fixture manufacturers responded that only a few fixtures are sold with lamps, thus giving consumers flexibility to choose lamps from a variety of manufacturers. In a system approach, fixture manufacturers would be requi red to provide fixtures with installed lamps and ballasts, and consumers would be limited to manufacturers that produce lamp

- ballast systems. DOE has learned that there are several metal halide lamp ballast manufacturers that do not manufacture

metal halid e lamps. In a system approach, these manufacturers could have a competitive2

- 11 disadvantage and would need to design ballasts to operate with competitors’ system specific lamps and not metal halide lamps in general. Several manufacturers reported during inter views that lamp and ballast compatibility is already a problem and that a system approach would only complicate compatibility. Furthermore, fixture manufacturers that are not vertically integrated (i.e., fixture manufacturers that do not also produce lamps and ballasts) could find sourcing lamp

- ballast systems problematic as only a few manufacturers have the capability to provide

them.

In the framework public meeting, Philips Lighting Electronics commented that looking at lamps and ballasts together when a dopting more efficient technology was necessary in order to

ensure compatibility . Even though some of the higher energy efficiencies are realized by high

frequency electronic ballasts, there are no ANSI standards for these ballasts. Therefore, compatibilit y is only established through individual agreements between ballast and lamp manufacturers, heavily complicating the ballasts’ wider adoption. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 88) DOE agrees that lamp and ballast compat ibility could be an issue with high

- frequency electronic ballasts in the context of a system approach to energy conservation standards. Under a system or ballast efficiency approach , DOE would need to consider the feasibility and market impact of a standard that would encourage wide

- spread use of high

- frequency electronic ballasts due to lamp

- ballast compatibility concerns and lack of industry

- endorsed ANSI standards.

Fixture manufacturers stated during interviews that different distributors often p refer different lamp manufacturers and do not want to be told which manufacturer s ’ equipment to

carry . Currently, distributors have a variety of lamps available to be installed in fixtures. In a system approach, the fixture manufacturer would have to choos e the appropriate system to match with the fixture. It is possible that the appropriate system is not from a distributor

- preferred lamp manufacturer or would limit the number of available lamps for distributors to carry. In this

scenario

, the fixture manuf acturer could possibly be at a competitive disadvantage if the fixture does not have a lamp or lamp

- ballast system that the distributor would like to carry. Concurrently, consumers that purchase from a preferred manufacturer could be forced to purchase fro m another because of the lack of a specific lamp

- ballast system from the preferred

manufacturer. Additionally, when replacing a lamp, consumers c ould be limited to only purchasing the same lamp from the same manufacturer. This approach c ould limit consumer s from buying a newer, more efficacious lamp once available.

NEMA commented that the metal halide lamp fixture rulemaking should not include specific standards for lamp efficacy , in part due to the possibility of additional lamps standards being set in a subsequent HID lamps rulemaking. (NEMA, No. 11.1 at p. 1) OSRAM

SYLVANIA of Siemens AG (hereafter “ OSRAM SYLVANIA ”) felt positively about the total system approach, but also commented that the HID lamp rulemaking is the correct place to address lamp effic iency and suggested that the standards remain separate from luminaire and ballast efficiency. (OSRAM SYLVANIA, Public Meeting Transcript, No. 8 at pp. 22

– 23, 25

– 26)

DOE notes that it cannot establish efficiency requirements for one product ( metal halide lamps) in simultaneous rulemakings. Additionally, if DOE were to establish lamp efficiency requirements in this metal halide lamp fixtures rulemaking, DOE would need to establish a test2

- 12 procedure for HID lamps in time for the NOPR analysis of this fixtures rulemaking. Therefore, DOE will not examine efficiency requirements for metal halide lamps in this current metal halide lamp fixture rulemaking. After it held the metal halide lamp fixtures rulemaking framework public meeting, DOE published the final HID determination on July 1, 2010 in the Federal Register . 75 FR 37975. In the final HID determination, DOE concluded that energy conservation standards for certain HID lamps are technologically feasible and economically justified and would likely result in si gnificant energy savings. DOE is currently proceeding with a full rulemaking for HID lamps (hereafter “ HID rulemaking ” ), which includes metal halide lamps. In the rulemaking, DOE will possibly establish efficacies for metal halide lamps that are operated i n metal halide lamp fixtures covered by the metal halide lamp fixtures rulemaking.

DOE has preliminarily decided not to implement a lamp

- ballast system approach. Most fixture manufacturers do not currently ship lamps with their fixtures, so many manufact urers would be unprepared to supply and specify standards compliant fixtures. Second, energy conservation standards for metal halide lamps are currently being considered as part of the HID lamps rulemaking. A lamp

- ballast system standard in addition to a l amp standard could create a burdensome and complicated regulatory framework.

Lamp

- Ballast System

- Table of Standard Lamps

As part of the outdoor lighting legislation negotiation process, some parties suggested the use of a table of standard lamps so tha t fixture performance could 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 a lumens per watt metric for determination of compliance with a lamp

- ba llast system standard. Acuity Brands Lighting, OSRAM SYLVANIA, Lutron Electronics Co., Inc., and Philips agreed that standard lamps work in theory, but cautioned DOE to wait until pending outdoor lighting legislation passes

, as two sets of lamp standards w ould be untenable. (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 28

– 29; OSRAM SYLVANIA, Public Meeting Transcript, No. 8 at p. 30; Lutron Electronics Co., Inc., Public Meeting Transcript, No. 8 at p. 29; Philips, Public Meeting Transcrip t, No. 8 at p. 91, 145)

DOE notes that the proposed outdoor lighting legislation referenced in public comments is currently no longer part of an active proposed legislation. DOE agrees that a table of standard lamps would allow fixture manufacturers that do not include lamps with the fixture to indicate compliance with standards. This approach could be more acceptable to the fixture industry as shipping fixtures with lamps would not be a requirement. DOE notes that b ecause the performance of the lamp would be specified by the table, the standard would essentially be a ballast efficiency standard for fixture manufacturers who do not include lamps. DOE invites comment on the specific values that could be included in a table of standard lamps. While DOE has pr eliminary determined not to use a lamp

- ballast system approach (with or without a table of lamps), it invites comment on examples of system s that could benefit from this approach. DOE also invites comment on the manufacturer impact s and feasibility of a la mp

- ballast system standard in addition to a lamp

- specific standard that could result from the ongoing HID lamps rulemaking. Finally, DOE also seeks comment on the potential for a standard s complaint fixture

to be relamped with a different lamp that reduces system efficacy after the first lamp failure and the impact on energy savings

.2

- 13 California Title 20 System Approach

Philips Lighting Electronics noted that one way to connect lamp efficiency to ballast efficiency would be to follow the California Title 20 in making allowances for slightly lower ballast efficiencies if the ballast is designed to operate lamp categories that are more efficacious. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 24) Progress Energy Carolinas was strongly opposed to a rulemaking requiring the use of certain wattages similar to California’s Title 20, and instead supported a system approach to efficiency. Progress Energy Carolinas added that while substituting lower wattage products saves energy, the approach does not take into account the need to provide adequate light to an area. (Progress Energy Carolinas,

No. 14.1 at p. 2) CA IOUs suggested DOE follow standards within California’s Title 20

, as their multiple compl iance pathways regarding ballast and system efficiencies would allow manufacturers to individually choose the most suitable way to comply. (CA IOUs, No. 17.2 at p. 2)

DOE agrees that while the reduced wattage versions of commonly used metal halide lamps are often (though not always) more efficacious, lumen output is often slightly less than the full wattage version. In some cases, fixture spacing and placement could resolve the change in light output, but it is possible that some applications would not be well served by these reduced

wattage systems. DOE may consider a federal design standard similar to California’s Title 20 and requests comments on the feasibility of this action and the expected consumer preferences for occupancy sensors, dimming, or redu ced wattage lamp pairings. DOE also seeks comment on the expected change in lumen output and initial efficacy when moving from regular to reduced wattage versions of lamps.

Fixture Systems

– Including Optics and Controls

Similar to the lamp

- ballast appro ach, ACEEE, the Joint Comment, and Earthjustice and

NCLC urged DOE to expand the proposed approach of the rulemaking to cover the entire luminaire, including optics and controls, in order to gain additional energy savings. (ACEEE, Public Meeting Transcript , No. 8 at pp. 24

– 25; Joint Comment, No. 16.1 at p. 2; Earthjustice and

NCLC , No. 15.1 at p. 1) Progress Energy Carolinas felt that efficiency and efficacy improvements should be based on the complete luminaire because system efficiency is what utilities deal with on the grid and what customers pay for in their energy bills. (Progress Energy Carolinas, No. 14.1 at p. 1) However, Philips questioned if it was truly within the scope of EISA to look at luminaire efficiency in detail, and suggested including only ballast efficiency, or lamp and ballast efficiency

, with in the scope. (Philips, Public Meeting Transcript, No. 8 at p. 32)

Currently, DOE has not established a test procedure for measuring efficiency of a metal

hali de lamp fixture as a system, and thus this rulemaking will not establish energy conservation standards for metal halide lamp fixtures based on a fixture efficacy metric. However, DOE has established a test procedure for ballasts included in metal halide la mp fixtures, which is based on

ANSI Standard C82.6

- 2005. 75 FR 10950. DOE believes that using a system approach would require the use of alternative metric s , such as Target Efficacy Rating ( TER ) and Fitted Target2

- 14 Efficacy ( FTE ) , which are not currently bei ng used in prescribing minimum efficiency requirements for metal halide fixtures. In order to include a fixture efficiency metric, and thus include optics and controls in the approach, DOE would need to initiate a new test procedure rulemaking. Additionall y, DOE is not aware of any industry

- accepted fixture efficiency metric that could be incorporated by reference. However, to maintain consistency with the approach set forth by EISA 2007 and its current test procedure for metal halide lamp ballasts that are included in metal halide lamp fixtures, DOE continues to consider amending only minimum ballast efficiency requirements.

There are numerous fixture designs currently available in the market and only a limited number of possible design improvements to in crease fixture efficiency. Manufacturers can use available lighting design software to design efficient reflectors or diffusers. However, fixture efficiency is highly dependent on the fixture application and certain fixtures types, such as wallpacks , are i nherently less efficient by design. Even within a certain type of fixture, such as a high

- bay fixture, fixture efficiency significantly changes depending on the application and

diffuser or reflector installed. For example, a high

- bay fixture in a retail ap plication, using the desired acrylic diffuser, would have a relatively low fixture efficiency. T he same fixture in a warehouse using a reflector would efficiently direct light downwards.

Another key issue reported by manufacturers during interviews is te sting burden and UL certification. All manufacturers reported that any changes in efficiency, regardless of whether it

was ballast

- based or fixture

- based, would require significant investment in testing and UL certification. On average, manufacturers repor ted that 20

– 30 fixture families would need to be tested and reevaluated for UL certification. Given a fixture efficiency approach, manufacturers reported on average 50

– 60 families ( i.e

., all fixture families manufactured) would need to be tested and reevaluated for UL certification. Given the amount of engineering effort and time for each test, each manufacturer would spend close to a full man

- year to test and certify all of its

fixtures.

Alternative Metric for Energy Conservation Standards

Earthjustice and NCLC , Energy Solutions, the Joint Comment, and the CA IOUs encouraged DOE to adopt system requirements based on the TER or FTE metrics, thereby capturing energy savings opportunities from the entire metal halide lamp fixture. The Joint Comment pointed out that the proposed metrics assess the efficiency with which a fixture delivers light to the intended target area and would offer manufacturers some flexibility to make

tradeoffs betwe en lamp, ballast, and fixture efficiency to meet any minimum TER or FTE requirement. Earthjustice and NCLC noted that adopting performance standards based on TER or FTE would also ensure that the lumens generated by an otherwise efficient lamp and ballast combination are not wasted by the other components of the fixture. However, because these are application

- specific metrics, the Joint Comment predicted that adoption would likely introduce some added complexity to the analysis and may require changes in th e equipment classes proposed for this rulemaking. (Energy Solutions, Public Meeting Transcript, No. 8 at pp. 30

– 31; Joint Comment, No. 16.1 at pp. 2

– 3; Earthjustice and NCLC , No. 15.1 at p. 1; CA IOUs, No.

17.2 at p. 3

– 5) Earthjustice and NCLC noted that F TE and TER metrics may not be sufficiently developed at this time, in which case DOE should consider specifying design requirements2

- 15 similar to those in California Title 20 to meet EPCA obligations to save energy. ( Earthjustice and

NCLC , No. 15.1 at p. 1) T he Joint Comment recommended that if DOE found the use of distribution metrics unworkable, it should explore other methods to incorporate a luminaire efficiency requirement. Similarly, to minimize the complexity of the analysis, the CA IOUs suggested apply ing the fixture metrics only to fixtures with the most significant market share or the most significant spread of efficiency, and using a ballast efficiency standard for all new fixtures. (Joint Comment, No. 16.1 at p. 3 ; CA IOUs, No. 17.2 at p. 3

– 5)

DOE analyzed the proposed alternative metrics by conducting independent research and

interview ing manufacturers. DOE found that in general, overall fixture energy use depends on four areas of importance , as follows : lamp efficacy, ballast efficiency, light ab sorption by the fixture, and usefulness of light emitted by the fixture (direction or light distribution pattern). TER and FTE metrics treat each area of importance more effectively in some ways than others.

A lthough metal halide lamp fixtures ’ minimum per formance requirements are measured by the efficiency of the ballast included in the fixture, DOE and the fixture industry has researched alternative metrics for fixture efficiency. For the solid state lighting ( SSL ) ENERGY STAR ®

p rogram, DOE has developed the FTE metric. NEMA, along with its luminaire division, has developed TER. The following sections describe each metric and explain how they account for the four areas of importance.

Fitted Target Efficacy

The FTE metric was used by DOE in the proposed ENERGY STAR requirement for outdoor pole

- mounted area and roadway luminaires, specifically for SSL. The FTE metric measures the luminaire performance by fitting a rectangle to a uniform “pool” of light specifi c to
each luminaire ; it multiplies the lumens delivered to this pool by the percent coverage of the rectangular target and divid es that by input watts to the luminaire. Uniformity criteria are derived

from the most lenient Illuminating Engineering Society ( IES ) recommendations for roadway and parking lot applications in order to include the majority of usefully distributed flux. Because FTE was developed for roadway and parking lot applications, separate algorithms for each respective application would need to be calculated and verified. FTE takes into account electrical components using total input power that is determined by the lamp and ballast.

Unlike TER , in which different categories of luminaires are identified, FTE is application neutral. This prese nts some issues when a luminaire is designed to have specific light patterns that not only light a horizontal plane, but light the vertical plane or even above the luminaire. Also, because FTE is calculated using a rectangular area, a luminaire that is des igned to have a

non

- rectangular area or that produces a large amount of unlighted area within the rectangle will

be at a disadvantage. FTE addresses the four areas of importance as follows:

**•** Lamp Efficacy: FTE takes into consideration lamp efficacy by eval uating light delivered to the target. A source has to have a reasonably high efficacy to score a high

FTE value.

**•** Ballast Efficiency: FTE incorporates ballast efficiency by incorporating total wattage of the luminaire that is dependent on the ballast input watts. The more efficient the ballast, the closer to the lamp wattage the total wattage of the luminaire will be.2

- 16 **•** Light Absorption: FTE takes into account absorption of light by the fixture by evaluating light delivered to the target. A less efficient opti cal system yields a lower

FTE value.

**•** Light Distribution: FTE only accounts for light hitting a specific target (rectangle) and does not take into account other surfaces where light is desired and the luminaire is design ed to light.

Through using uniformit y and rectangularity of distribution as the criteria for useful luminous flux, the same method of calculation can be applied to luminaires of all IES types (Types I through V), and no project

- specific geometries or criteria are required. However, FTE only accounts for light hitting the specified target area and does not take into account other

surfaces that the luminaire is designed to light. FTE was designed for some outdoor applications but may not be appropriate for all other application types.

DOE has learned from NEMA and from NEMA member manufacturers that FTE was rejected by manufacturers as an appropriate measure of luminaire efficiency in general. DOE is also aware that FTE was not finalized by the ENERGY STAR p rogram and therefore has not

been acc epted by the industry. According to interviewed manufacturers, NEMA, the U

. S

. Environmental Protection Agency ( EPA ) , and various manufacturers are coordinating on an effort to propose a revised metric for the ENERGY STAR p rogram called Optical Power Density (OPD). According to manufacturers, OPD is technology neutral and applicable to standards for certain fixture types . However, a finalized version of the metric is not currently available. DOE will continue to investigate OPD as it develops.

Target Efficacy Rating

The TER i metric was developed by NEMA’s luminaire division to succeed the previous

metri c, Luminaire Efficacy Rating (LER). TER calculates fixture efficacy by multiplying the light leaving the luminaire by a value, also known as the Coeffi cient of Utilization (CU) , that factors in the distribution of light. CU calculates the percentage of rated lamp lumens reaching a

fixture

- specific target. TER defines different targets depending on the application of fixture s

. The calculation of efficacy for TER also separately takes into account electrical component efficiency (lamp and ballast). TER addresses the four areas of importance as follows:

**•** Lamp Efficacy: TER indirectly considers lamp efficacy by accounting for lumen output from the lamp. Lumen output for the lamp component is based on manufacturer published data only.

**•** Ballast Efficiency: TER incorporates ballast efficiency by using the total wattage of the luminaire that is dependent on the ballast input watts. The more efficient the ballast, the closer to the lamp wattage the total wattage of the luminaire will be.

**•** Light Absorption: TER accounts for thermal and optical losses by evaluating the portion of rated lamp lumens delivered to the workplane.

i NEMA issued a revised version of the Target Efficacy Rating metric in 2009 , LE 6

- 2009, available here: http://www. nema.org2

- 17 **•** Light Distribution: TER builds upon LER. While LER considers only the amount of light leaving a luminaire

, TER factors in the light distribution using CU. The light reaching the target is most important for a fixture. TER defines different targets f or different fixture types.

Alternative Metric General Discussion

DOE learned through research and interviews with manufacturers that although recognized by the fixture industry (primarily manufacturers), TER is seldom used in manufacturing literature to show performance. During the framework public meeting, Acuity Brands Lighting stated that FTE or TER metrics were for market transformation and not appropriate for a regulatory process (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at p. 31). Additionally, many consumers a nd non

- manufacturers in the lighting industry are not

familiar with the metric. DOE also learned that some lighting software commonly used in the industry cannot perform the necessary TER calculations. Finally, a ll interviewed fixture

manufacturers were co ncerned that a fixture efficiency approach would increase compliance and

enforcement complexity. Manufacturers predicted significant enforcement issues because numerous possibilities of equipment classes exist, and those standards would need to be set

base d on application rather than product.

TER has 22 different types of luminaire classifications , each with a different TER calculation method and value. Classifying fixture s by application is difficult. During the framework public meeting and in written com ments, NEMA and Philips Gardco urged caution in adopting such metrics as TER and FTE because their application

- specific nature would make this approach very complicated and add difficulty to developing definitions for each class without

allow ing loopholes. (NEMA, No. 11.1 at p. 1; Philips, Public Meeting Transcript, No. 8 at p. 32) All interviewed fixture manufacturers agreed that even though fixtures generally will fall within one of the different classifications for TER purposes, there are certain fixture s that can fall within multiple classifications . This mak es it difficult to determine which minimum performance standard to follow and possibly allow s for less stringent requirements than intended. Therefore,

DOE believes FTE and TER has the potential for confusion in compliance and enforcement issues. Additionally, Acuity Brands Lighting stated during the framework public meeting that the implementation of FTE or TER would obsolete niche products that may be critical for certain applications. (Acuity Brand s Lighting, Public Meeting Transcript, No. 8 at p. 31) DOE agrees with Acuity Brands Lighting that fixtures that are designed for specialty applications or applications that do not fall under the FTE and TER classification s , such as outdoor floodlights

,

c o uld be disproportionally harmed because luminaire classifications under TER are general in

nature

.

For this rulemaking, DOE has preliminarily decided to not adopt the FTE or TER metrics for assessing performance of metal halide lamp fixtures

. DOE based this determination primarily on concerns stemming from the subjectivity of assigning standards to particular application types and niche applications being disadvantaged

. The subjectivity of classifying applications types

could lead to issues wit h compliance and enforcement of standards. Another important concern for the use of TER is that it requires the use of manufacturer published data, specifically the2

- 18 lumen output of the lamp used in the fixture, that is not measured using a DOE published te st procedure. Therefore, DOE would not have a means to verify the manufacturer dat a, meaning

TER would need to be technically amended and a full test procedure rulemaking would be required to develop a test procedure for metal halide lamps. DOE requests co mments on its preliminary decision not to use TER and FTE as metrics used to calculate metal halide lamp fixture minimum performance requirements.

Conclusion

Based on information gathered through research and discussions with fixture manufacturers, DOE p reliminarily determined to continue setting metal halide lamp fixtures standards based on the efficiency of the ballast included in the fixture. Therefore, in the preliminary analysis , DOE continue s to evaluate amending energy conservation standards for

me tal halide lamp fixtures by amending performance requirements for ballasts included in

covered fixtures

, using ballast efficiency as the relevant metric.

2.3.2.2 Expansion of Coverage of Energy Conservation Standards

DOE interprets its statutory mandate as permitting consideration of changes to the existing scope of energy conservation standards to include currently excluded equipment or equipment not captured in the existing regulation (due to the 150

– 500 W lamp wattage limitation) that could provide signif icant energy savings. A wide variety of metal halide lamp fixtures are not covered by existing energy conservation standards. Accordingly, these metal halide lamp fixtures are potential candidates for expanded coverage pursuant to 42 U.S.C. 6295(hh)(2)(A). Significant additional energy savings may be possible by expanding ballast efficiency regulat ions to cover fixtures that operate lamps rated outside the current wattage

limitation and use metal halide ballasts exempted by EISA 2007

.

Additional Rated Lamp Wattages

DOE is considering expanding its coverage of energy conservation standards to include metal halide lamp fixtures that operate lamps rated 50

– 150 W and fixtures that operate lamps

rated greater than 500 W . DOE believes there is potential for significant energy savings. Similar to the current standards, energy savings would be achieved through requirements on the ballasts

for those fixtures. At the time of the framework public meeting, DOE’s review of ballast manufacturer catalog s (an indication of product availability) showed many types of metal halide lamp ballasts for fixtures operating lamps rated outside the currently regulated wattage range. The catalogs showed that approximately 30 percent 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 amount of ballasts outside of the existing scope of coverage, DOE believed there was p otential for significant energy savings

and considered including the entire range of lamp rated wattage in the analysis.

NEMA and Philips Lighting Electronics advised against expanding scope of coverage because lower wattage models ( less than 150 W ) only make up about 6 percent of energy use and higher wattage models ( more than 500 W ) are already quite efficient. Both NEMA and Philips Lighting Electronics thought that there would be a negligible impact o n energy savings that2

- 19 would not warrant addition al rulemaking. (NEMA, No. 11.1 at p. 2 , 6 ; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 36

– 37) NEMA put forward the importance of expanding the scope not based on the number of catalogued ballasts availability, but on actual

wattag e range usage in the market. (NEMA, No. 11.1 at p. 2) Additionally, EEI felt that a scope expansion would result in more work for DOE with only incremental energy savings. (EEI, No.

10.1 at p. 1)

Through further market research and information provided d uring interviews, which

occurred 8

– 10 months after the framework document public meeting, manufacturers reported a significant increase in shipments for fixtures and ballasts rated less than 150 W . Manufacturers cited an expanding market due to consumers r eplacing halogen lamps with metal halide. As lower wattage models increase in prevalence, so does the potential for energy savings by expanding scope of coverage to include them. For the higher wattages, Philips Lighting

Electronics noted that when conside ring market shares of fixture classifications, the >500 W
range represents roughly 40

– 41 percent of energy usage. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 50)

CA IOUs supported expanding the wattage scope and believed that it would provide an important opportunity to capture additional energy savings. (CA IOUs, No. 17.2 at p. 6) Earthjustice and NCLC supported expanding the wattage scope

, provided energy savings are technologically feasible, economically justified, and nontrivial. ( Earthjustice and NCLC , No.

15.1 at p. 3) Georgia Power Company and Progress Energy Carolinas suggested that fixtures of

1000 W or more continue to be exempt because currently there is no proven pulse start ballast availability. (Georgia Power Company, No. 12.1 at p. 1; Progress Energy Carolinas, No. 14.1 at p. 1) DOE tentatively decided no t to specify the starting method when setting standards for metal halide lamp ballasts rated for la mps of 1000 W or greater. However, n ot only has DOE found catalog data for metal halide lamp ballasts rated for lamps higher than 1

, 000 W, but DOE has tested multiple 1

, 000 W pulse start ballasts from different manufacturers. Additionally,

California Title 20 has completely eliminated probe start ballasts rated for any wattage. 20 CCR 1605.3(n)(2)

.

DOE developed the preliminary analysis to include metal halide lamp fixtures that operate lamps ≥50 W and <150 W , 150

– 500 W, and greater than 500 W

. Research a nd interviews have so far confirmed that this expansion of scope is warranted and will provide additional energy savings.

EISA 2007 Exempted Metal Halide Lamp Fixtures

Additionally, DOE is consider ing expanding its energy conservation standards to cover metal halide fixtures excluded by EISA 2007 including fixtures with regulated lag ballasts ; electronic ballasts that operate at 480 V ; and ballasts that are rated only for 150 W lamps, use in wet locations, and opera tion in ambient air temperatures higher than 50 °C. (42 U.S.C

. 6292(hh)(1)(B))

NEMA and Philips Lighting Electronics pointed out that regulated lag ballasts are such a small market share that they do not represent significant energy savings, and should therefore2

- 20 continue to be excluded. (NEMA , No. 11.1 at p. 3; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 66

– 67) Through further market research and information gathered in manufacturer engineering interviews, DOE learned that regulated lag ballasts are mainly used for

sp ecialty 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. However, to be able to withstand large variations, the ballast is si gnificantly larger and has poor efficiency, attributes that only customers requiring low lamp input variation disregard. Manufacturers and market research also showed there was no significant market shift to regulated lag ballasts due to EISA’s exemption. DOE intends to continue the exemption for regulated lag ballasts.

NEMA and Philips Lighting Electronics are not aware of any 480 V electronic ballasts on the market, and therefore see no need to include them under the rulemaking. (NEMA, No. 11.1 at p. 3; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 66 ) Manufacturer interviews and additional research has not returned any evidence of these ballasts on the market. Therefore, DOE agrees that the 480 V electronic metal halide l amp ballasts should continue to be exempted from this rulemaking.

EEI questioned whether outdoor fixtures “rated for use in wet locations” are excluded from the rulemaking and requested clarification on whether th e EPCA provision regarding such

fixtures would lead to all or only some outdoor fixtures being exempt. (EEI, No. 10.1 at p. 1)

As previously stated, EISA 2007 amended EPCA to include a set of exempted fixtures. The third type of fixture specifically exempted from energy conservation standards m ust meet all

of the follow ing stipulations :

fixtures that

— (I) are rated only for 150 watt lamps; (II) are rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and (III) contain a ballast that is rated to op erate at ambient air temperatures higher than

50 °C, as specified by UL 1029

– 2001.

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

Although there are several 150 W outdoor fixtures, DOE is aware that not all outdoor fixtures are rated only for 150 W. Additionally, even if an outdoor fixture meets one or two requirements, not all fixtures meet all three requirements. Therefore, not all outdoor fixtures are exempt from energy conservation standards.

CA IOUs specifically urged DOE to assess the common category of 150 W outdoor

fixtures that are presently exempted. (CA IOUs, No. 17.2 at p. 6) Georgia Power Company and Progress Energy Carolinas warned that including 150 W rated fixtures would eliminate the usage of magnetic pulse start ballasts and require electronic pulse start b allasts for pole mounted

fixtures , although these ballasts have not been designed or tested for outdoor use. Georgia Power Company therefore suggested continuing the exemption for pole mounted fixtures as defined by2

- 21 recent NEMA documents. (Georgia Power Co mpany, No. 12.1 at p. 1; Progress Energy Carolinas, No. 14.1 at p.1) NEMA and Philips Lighting Electronics noted that the exemption of

150 W lamps facilitated the market move to 150 W pulse start upon the elimination of 175 W probe start under EISA 2007. I f the 150 W exemption is eliminated, the 150 W pulse start design may have to become much larger and increase in cost to a point exceeding any potential energy savings over luminaire lifetime. (NEMA, No. 11.1 at p. 3; Philips Lighting Electronics, Public

M eeting Transcript, No. 8 at pp. 66

– 67)

DOE is aware that EISA 2007 and California Title 20 defined the exemption of 150

- W

only fixtures rated for wet location use (as specified by the National Electrical Code 2002, section 410.4(A)) and containing a ball ast rated to operate in ambient air temperature higher than

50 °C (as specified by UL 1029

– 2001. (42 U.S.C. 6292(hh)(1)(B))

. DOE was presented with

data from interviews that show an increase in shipments for these exempted fixtures

. DOE has

learned from manufacturer interviews that this exemption has been heavily used as manufacturers can essentially exempt any fixture by rating it for 150 W and wet location use. However, i f DOE eliminates the exemption at this time, manufacturers cou ld potentially have to

either redesign both the ballasts and the fixtures that house them

, or move to electronic ballasts

that are specially adapted to the conditions

. DOE notes that both these options would involve

increased cost to the manufacturer. DOE invites further comment on extending or eliminating this exemption.

OSRAM SYLVANIA emphasized the importance of clarity when applying the rulemaking to “ general lighting applications, ” to ensure that no specialty lighting is unintentionally included. ( OSR AM SYLVANIA , Public Meeting Transcript, No. 8 at pp. 37

– 38 ; NEMA, No. 11.1 at p. 3 ) ACEEE felt that the term “general lighting applications” clearly excludes niche products, while ASAP thought the definition could be enhanced. (ACEEE, Public Meeting Transc ript, No. 8 at p. 39; ASAP, Public Meeting Transcript, No. 8 at p. 40) “General lighting applications” are defined in EISA 2007 as “lighting that provides an interior or exterior

area with overall illumination.” DOE’s interpretation is that t he term should not include specialty or niche lighting.

2.3.3 Summary
In summary, DOE is considering extending the scope of energy conservation standards to the following list of metal halide lamp fixtures

.

(1) all metal halide lamp fixtures that operate lamps rated ≥50 W and < 150 W ; and (2) all metal halide lamp fixtures that operate lamps rated higher than 500 W

.

DOE is considering exempting the following metal halide lamp fixtures:

(1) fixtures that use regulated lag ballasts; and (2) fixtures that use electronic ballasts that operate at 480 V.

As DOE is evaluating minimum efficiency requirements for metal halide lamps in a separate rulemaking (the HID rulemaking), DOE has decided that in amending metal halide

fixture efficiency standards, it will only evaluate amending minimum ballas t efficiency2

- 22 requirements, consistent with the current statutory approach. DOE invites comment on its rationale for extending coverage and also its preliminary determination of the scope of energy

conservation standards.

2.4 MARKET AND TECHNOLOG Y ASSESSMENT

When DOE begins an energy conservation standards rulemaking, it gathers information that provides an overall picture of the market for the equipment concerned, including the nature

and market characteristics of the equipment and the industry structure. This activity consists of both quantitative and qualitative analysis based primarily on publicly available information. The subjects addressed in the market and technology assessment in the preliminary TSD analysis include the major manufacturers, equipment classes, retail market trends, shipments of covered equipment , regulatory and non

- regulatory programs, and technologies that could be used to improve the efficiency of metal halide lamp fixtures through the metal halide ballasts included in

fixtu res . This information serves as a resource throughout the rulemaking.

DOE reviewed existing literature and spoke with manufacturers to g ain an understanding

of the metal halide lamp fixture and ballast industr ies in the United States. Industry publications ( e.g

. , manufacturer catalogs, trade journals), government agencies, and trade organizations provided the bulk of the information . Using this information

, DOE assessed the overall state of

the industr ies

, fixture and ballast manufacturing and market shares, shipments by ballast type, general technical information on ballasts, and industry trends.

The following discussion summarizes the analytical approach and the comments DOE received in response to the framewor k document. j

2.4.1 Market Assessment A more detailed discussion on DOE’s approach can be found in the market and technology assessment (chapter 3 of the preliminary TSD).

The market assessment focuses on developing a qualitative and quantitative

characterization of the metal halide lamp fixture and ballast industry. It characterizes the market structure based on publicly available information and data supplied by manufacturers and other interested parties. T he market assessment also includes information about man ufacturers of metal

halide lamp fixtures and ballasts, equipment classes, fixture and ballast shipments, and existing regulatory and non

- regulatory efficiency improvement initiatives.

2.4.1.1 Manufacturers of Metal Halide Lamp Fixtures

The majority of the domestic market share of metal halide fixtures is held by eight major manufacturers: GE Consumer and Industrial of General Electric, Inc. ( hereafter “GE”)

, OSRAM

j For more information on the framework document, visit http://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_fixtures.html2

- 23 SYLVANIA

, Siemens AG (hereafter “ OSRAM SYLVANIA ”); Gardco of Philips Light ing (hereafter “ Gardco ”)

, Acuity Brands Lighting (hereafter “Acuity”)

, Cooper Lighting

, Hubbell Lighting

, Juno Lighting Group (hereafter “Juno”)

, and Venture Lighting. T he lighting divisions of several of these companies manufacture other products such a s HID ballasts and lamps, fluorescent lamps, and light

- emitting diode ( LED ) lighting i n addition to the metal halide lamp

fixtures listed under this rulemaking.

Not all of these major companies are members of NEMA, a trade association that

represents metal halide lamp fixtures manufacturers. NEMA provides an organizational framework for manufacturers of lighting products to work together on projects that affect their industry and business.

Although the metal halide lamp fixtures market is predominantly supp lied by large manufacturers, DOE intends to conduct a study of small businesses that manufacture metal halide lamp fixtures for the NOPR stage of this rulemaking analysis. The Regulatory Flexibility Act (5 U.S.C. 601 et seq .) requires preparation of an initial regulatory flexibility analysis for every 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 nu mber of

small entities. A regulatory flexibility analysis examines the impact of the rule on small entities and considers alternative ways of reducing negative impacts. The Small Business Administration defines small business manufacturing enterprises for metal halide lamp fixtures under the North American Industry Classification System (NAICS) product code 335122, Commercial, Industrial, and Institutional Electric Lighting Fixture Manufacturing , which has a size standard of 500 employees or fewer. This inc ludes the total number of employees in the parent company, not only those in the division that produces metal halide lamp fixtures. DOE invites interested parties to provide names and contact information for any small businesses that manufacture

metal hali de lamp fixtures and should be consulted before DOE publishes a NOPR.

2.4.1.2 Manufacturers of Metal Halide Lamp Ballasts

The majority of the domestic market share of metal halide lamp ballast is held by both

NEMA and non

- NEMA member manufacturers including GE

, OS RAM SYLVANIA

, Advance Transformer of Philips Lighting (hereafter “Advance”)

, Universal Lighting Technologies, and Venture Lighting International. Similar to metal halide lamp fixture manufacturers, the lighting divisions of several of these compa nies manuf acture other products such as fluorescent lamps, high

- intensity discharge lamps, and LED lighting in addition to the ballasts listed under this rulemaking

.

Similar to metal halide lamp fixtures, the metal halide lamp ballast market is predominantly suppli ed by large manufactu rers and DOE intends to conduct a study of small

businesses that manufacture metal halide lamp ballasts for the NOPR stage of this rulemaking analysis. The Small Business Administration defines small business manufacturing enterprises for metal halide lamp ballasts under the NAICS product code 335311

, Power, Distribution, & Specialty Transformer Manufacturing , which has a size standard of 750 employees or fewer

. This includes the total number of employees in the parent company, not only those in the division that produces metal halide lamp ballasts . DOE invites interested parties to provide2

- 24 names and contact information for any small businesses that manufacture metal halide lamp

ballasts and should be consulted before DOE publishes a NOPR.

2.4.1.3 Regulatory and Non

- Regulatory Programs

Several Federal

, state, and international regulatory and non

- regulatory programs affect the markets for metal halide lamp fixtures and ballasts. U.S. and Canadian regulatory initiatives relevant to fixtures and ballasts covered by this rulemaking are currently in place or under development . While the following summary is not exhaustive in describing all regulatory action related to metal halide lamp fixtures and bal lasts, it indicates notable initiatives that characterize recent developments in the lighting market. Chapter 3 of the preliminary TSD discusses these programs and initiatives in additional detail.

In the United States, EPCA established an energy conserva tion program for major household appliances. Subsequently, EISA 2007 expanded DOE’s authority to regulate the energy efficiency of several equipment types , including metal halide lamp fixtures. EISA 2007 prescribed standards and required DOE to conduct two rulemakings on metal halide lamp

fixtures ; t he first of which is the subject of th e current rulemaking.

Prior to the enactment of EISA 2007

, the California Energy Commission (CEC) adopted regulations for m etal h alide fixtures that took effect on Januar y 1, 2006. California’s metal halide fixture energy conservation standards were amended in August 2009 with the adoption of CEC

2009 Appliance Efficiency Regulation

. According to section 1605.3(n) of California Title 20, effective January 1, 2010, metal ha lide lamp fixtures manufactured and sold in the state of California may not be sold with probe

- start ballasts, and in addition, must meet at least one of four requirements as defined in chapter 3

.

In Canada, the Natural Resources Canada (NRCan ) Office of Energy Efficiency regulates

the energy efficiency of several consumer and industrial products. O n May 10, 2010 NRCan published a bulletin on developing standards that included NRCan’s proposal to amend Canada’s Energy Efficiency Regulations to cover metal halide lamp ballasts. NRCan proposed that standards would apply to products manufactured on or after July 14, 2012.

2.4.1.4 Metal Halide Lamp Fixture Shipments

To calculate the national energy savings from an energy conservation standard for metal

halide lamp fixtures , DOE utilizes shipment estimates disaggregated by equipment class. In

c hapter 3 of the preliminary TSD, DOE presents historical shipment data for metal halide lamp

fixtures from 1993

– 2009 based on publicly available HID lamp fixture sh ipments from the U.S.

Census from 1993

– 2001

, 1 lamp shipment data from the HID determination

, k confidential lamp shipments from 2002

– 2008 from NEMA, and market trend information from manufacturers

.

k A f inal d etermination c oncerning the p otential for e nergy c onservation s tandards for H ID Lamps was published in

the Federal Register on July 1, 2010. 75 FR 37975 . The document in its entirety can be found at http://www1.eere.energy.gov/buildings/appliance_standards/commercial/high_intensity_discharge_lamps.html2

- 25 DOE used this data for three main purposes. First, the sh ipment data and market trend information contributed to the shipments analysis and base

- case forecast for fixtures ( c hapter 9 of the preliminary TSD). Second, DOE used the data to select the representative equipment classes and representative units for analysis ( c hapter 5 of the preliminary TSD). Third, DOE used the data to develop the installed stock of fixtures for the national impact analysis ( c hapter 10 of the preliminary TSD).

The U.S. Census historical shipme nt data for HID lamp fixtures is broken down into market sectors including commercial and institutional

, industrial

, and outdoor lighting. Under

each market sector the shipments are categorized by a variety of applications. Different applications under com mercial and institutional include surface or pendant, indirect lighting, recessed insulation contact (IC), and recessed non

- insulation contact ( Non

- IC)

. Under industrial, shipments are broken into applications including general lighting and hazardous light ing. For outdoor lighting, shipments are broken into street and highway lighting, general purpose floodlighting, HID sports lighting, and HID area and site lighting. Although the Census data includes metal halide lamp fixtures in the figures, it does not s eparate metal halide lamp fixtures from other sources such as high

- pressure sodium or mercury vapor lamps. However, by combining Census data with information from other sources such as NEMA and industry

experts, major trends in the market can be analyzed. Table 2.1 shows the estimated historical shipments of metal halide lamp fixtures from 1993

– 2008

.

Table 2

. 1 Estimated Historical Shipments of Metal Halide Lamp Fixtures from 1993

– 200 8

Year Estimated Total Metal Halide Lamp Fixture Shipments*

1993 2,701,000

1994 3,219,000

1995 3,885,000

1996 4,292,000

1997 4,884,000

1998 5,698,000

1999 6,697,000

2000 6,697,000

2001 6,771,000

2002 6,956,000

2003 7,102,000

2004 7,362,000

2005 7,866,000

2006 8,108,000

2007 8,157,000

2008 7,552,000

2009 7,741,000 * Shipments rounded to the nearest thousand

Based on the effects of the overall market downturn expressed by manufacturers during interviews, DOE estimates shipments significantly decreased in 2008 . Also, manufacturers estimate that alternative technologies such as fluorescent lamps and LEDs have captured significant market share. Fluorescent technol ogy has improved and its lower cost has attracted consumers. Additionally, LED fixture costs have significantly decreased due to competition in2

- 26 the market along with an increase in consumers’ demand for low er maintenance and more efficacious technologies. In general, manufacturers predict that HID applications will eventually be overtaken by LEDs

, but the market will have to go through a transitional period. For a complete explanation of how DOE estimated hist orical shipments and additional information on

such shipments, see c hapter 9 of the preliminary TSD.

2.4.2 Technology Assessment
In the technology assessment, DOE identifies technology options that appear to be a feasible means of improving equipment efficiency . This assessment provides the technical background and structure on which DOE bases its screening and engineering analyses. The following discussion provides an overview of the salient aspects of the technology assessment, including issues on which DOE se eks public comment. Chapter 3 of the preliminary TSD provides detailed descriptions of the basic construction and operation of metal halide lamp ballasts, followed by a discussion of technology options to improve the efficiency of metal halide lamp ballast s

.

In the framework document, DOE requested comments on a list of preliminary technology options that DOE intended to study further. These technology options included electronic ballasts, integrated circuits, higher grade components, and improved circui t designs.

NEMA and Philips Lighting Electronics discouraged rulemakings specifying technology on the basis of frequency . They not ed that high

- frequency electronic ballasts are generally more

efficient than low

- frequency electronic ballasts not due to the frequency itself, but the configuration of the ballasts, specifically the high

- frequency ballasts’ use of a two

- stage rather

than th ree

- stage design. (NEMA, No. 11.1 at p. 6; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 61

– 62)

DOE agrees that high

- frequency electronic ballasts have the potential to be more efficient

than low

- frequency electronic ballasts. How ever, based on the testing of several manufacturers’ electronic ballasts and research of both types of electronic ballasts for the same rated lamp wattage, DOE has found instances where the low

- frequency electronic ballast design is more

efficient than the high

- frequency design. Therefore, DOE does not consider output frequency to be a technology option

. DOE will consider electronic ballasts to be a technology option

, regardless of operating frequency, and will develop electronic ballast efficiency level s for metal

halide ballasts included in metal halide lamp fixtures

.

NEMA, Philips and Philips Lighting Electronics disagreed with simply replacing magnetic ballasts with electronic ballasts . They noted that a certain wattage might be available in magneti c but not electronic ballasts

, purely because of electronic ballasts’ form factor and temperature ratings . This issue might require manufacturers to redesign fixtures. (NEMA, No.

11.1 at p. 2, 6; Philips, Public meeting Transcript, No. 8 at pp. 62

– 63; Phil ips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 29

– 30, 33

– 34, 55, 64, 75, 84) Philips noted that switching from magnetic to electronic ballasts particularly affects system costs in exterior fixtures as the redesign involves not only the h ousing

, but also the supporting poles, increasing system cost up to ten times. (Philips, Public Meeting Transcript, No. 8 at p. 34) Acuity Brands Lighting felt that electronic ballasts are still an emerging technology due to thermal management2

- 27 issues and l ow tolerance for poor power quality. These issues have caused failures, especially in outdoor environments, which could lead to safety and security problems. (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 63

– 64) Georgia Power Company note d that electronic ballasts simply have not been designed and tested to withstand the environmental and electrical surges in the outdoor environment. (Georgia Power Company, No. 12.1 at p. 1) Philips Lighting Electronics elaborated that while electromagneti c ballasts can withstand well in excess

of 10 kV transients, electronic ballasts are typically rated for 6 kV transients and w ould likely need additional line transient protection. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 64) N EMA and Cooper Lighting also noted that in addition to the thermal factors and redesign of products, added cost s of electronic ballasts are shorter operating lives and lower reliability. (NEMA, No. 11.1 at p. 6; Cooper Lighting, Public meeting Transcript, No. 8 at pp. 72

– 73)

DOE agrees that electronic metal halide ballasts have lower tolerances of voltage

transient s and high temperatures than magnetic ballasts do

. However, these susceptibilities can

be mitigated with technology such as transient suppress ors and heat sinks. For fixtures under

threat of high

- voltage surges and spikes, an electronic ballast can be easily coupled with a transient arrestor (e.g., a silicon oxide varistor) that can withstand 10 kV and larger transients

. For fixtures in locations wit h higher temperatures, DOE tentatively concludes that protecting against thermal factors is currently technologically possible, but DOE has limited information and limited ability to estimate the thermal properties of fixture designs. DOE welcomes comment

and information on heat sink s and other methods of heat dissipation and temperature control. DOE also requests comment on typical applications in which transients over 6kV are a particular concern. Finally, DOE requests commen t on specific sources of reliability concerns (relative to magnetic ballasts) for electronic ballasts.

NEMA suggested DOE consider dimming technology. Although dimming does not improve system efficiency, it has the potential to save much more energy than improvements in ballast efficiency and can be very cost effective. (NEMA, No. 11.1 at p. 7) DOE agrees that dimming technology, which is currently already incorporated into HID ballasts, has the potential to save energy in general regardless of energy con servation standards. Ballast efficiency is measured at full light output, and therefore the current test procedure does not give efficiency credit for dimming . DOE understands that metal halide lamps are often dimmed using motion sensors, photocells, and i n the case of magnetic ballasts, relays and bi

- level capacitors. DOE requests comment on the specific costs of employing these features to save energy, and on dimming generally.

Philips Lighting Electronics noted that while integrated circuits allow opt imization of ballasts, the integrated circuit itself does not have a direct impact on ballast efficiency. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 62) DOE agrees that not all integrated circuits directly influence ballast effic iency

, but their inclusion is often paired with other circuit topologies and optimization processing that can increase efficiency.

The Joint Comment and CA IOUs agreed with the technology options that DOE had initially identified for further consideratio n, but believed that DOE has an obligation to consider approaches beyond ballast efficiency and should therefore expand the list of technology options2

- 28 to include improvements in luminaire efficiency and controllability. ACEEE gave a detailed list

of additi onal options. CA IOUs mentioned that fixture efficiency might be improved with faceted metal domes, inner reflectors, glass

- lined domes, and clear ribbed an d prismatic reflectors. (ACEEE , No. 16.1 at p. 2; CA IOUs, No. 17.2 at p. 8)

As discussed in secti on 2.3.2 , DOE is not considering setting energy conservation standards for metal halide lamp fixture s based on fixture efficiency or using a metric that incorporates fixture optical designs. DOE under stands that fixture optical design optimization could improve the overall ability of the fixture to deliver light to the desired area. However, for today’s energy conservation standards, DOE maintains it will set minimum efficiency requirements for ballast s included in covered metal halide lamp fixtures. DOE research ed several fixture improvements and additional components, including some of the previously mentioned fixture optical improvements ; a summary can be found in chapter 3 of the preliminary TSD. As for controllability,

DOE invites comments on all of the technology options it considered for metal halide lamp fixtures (listed in Table 2.2 ), inclu ding any omissions or revisions necessary to have a more comprehensive technology assessment. In the context of commenting on technology options, DOE also requests information on the feasibility, performance improvement, and cost of the technology options, as well as any recent developments in their technical maturity. More information concerning these technology options can be found in chapter 3 of the preliminary

TSD.2

- 29 Table 2

. 2 Metal Halide Lamp Ballast Techn ology Options

Relevant Ballast Type Technology Option Description

Magnetic Improved Core Steel Use a higher grade of electrical steel, including grain

- oriented silicon or amorphous steel, for lower core losses.

Copper Wiring Use copper wiring in place of aluminum wiring for lowered resistive

losses.

Increased Stack Height To a point, adding steel laminations

results in lowered core loss.

Increased Conductor Cross

- Section To a point, increasing conductor cross section results in lowered winding loss.

Electronic Ballast Use an electronic ballast in place of a magnetic ballast.

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.

To a point, adding steel laminations

results in lowered core loss.

To a point, increasing conductor cross section results in lowered winding loss.

Diodes Use d io des 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.

2.4.3 Equipment Classes
When necessary, 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 conducts its analysis and considers establishing or amending standards to provide separate standard levels for each equipment class.

In the framework document, DOE considered amending the existing equipment classes for metal halide lamp fixtures. DOE believed that the existing class divisions did not properly account for expected market changes due to existing standards

, n or did they account for a potentially expanded scope of energy conservation standards. DOE soug ht comments on prospective class

- setting factors, specifically rated lamp wattage and input voltage. DOE received several comments on its approach to defining equipment classes.

Wattage2

- 30 Metal halide lamp ballasts are available for lamps with rated wattages as low as 20 W and as high as 2,000 W

. Depending on the application, a specific or minimum light output is

necessary. Lamp wattage affects light output with increasing wattage lamp and ballast systems generally producing increasing amounts of ligh t

. Consumers require varying amounts of light depending on application. For example, low

- wattage (less than 150 W) lamps are mainly used in commercial and some residential applications for general lighting purposes. Medium

- wattage (150

- 500 W) lamps are the most widely used and include warehouse, street, and general commercial lighting. High

- wattage (greater than 500 W) lamps are mainly used in searchlights, stadiums, stage applications, and other applications that require powerful white light. The

wattage o f the lamp and ballast system provides a consumer utility based on its impact on light output. DOE also determined that the wattage of the lamp and ballast system also impacts the efficiency of the ballast. Generally, ballast efficiency increases with incr easing power. Philips Lighting Electronics agreed, commenting that ballast efficiency generally increases with higher lamp powers. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 89) For electronic ballasts, this efficiency gain can b e attributed to the proportion of fixed losses to total losses. For low wattage electronic ballasts, fi xed losses contribute to a larger proportion of total losses than in a high wattage ballast. Magnetic ballasts are essentially transformers (sometimes

wi th capacitors for power correction and ignitors for pulse

- starting), which are understood to have proportionally lower losses with increased wattage

. B ecause wattage can affect both consumer utility (light output) and efficiency, DOE has preliminarily deci ded to establish separate equipment classes on the basis of wattage.

E ISA 2007 defines equipment classes with a single rated lamp wattage range (150

– 500 W) for both pulse

- start and probe

- start metal halide lamp ballasts. For non

- pulse

- start metal halide lamp ballasts, EISA 2007 separates equipment classes into two rated lamp wattage ranges ( ≤250 W and >250 W ). For the framework document, DOE considered defining metal halide lamp fixture equipment classes by including additional lamp wattage ranges. DOE considered

includin g : (1) <150 W ; (2) ≥150 W and ≤250 W ; (3) >250 W and ≤500 W ; and

, (4) >500 W as separate wattage bins to establish a separation of equ ipment classes.

NEMA and OSRAM SYLVANIA suggested that the <150 W class be divided as < 50 W

and 5 0

– 150 W because < 50 W is very low wattage with a very wide range of efficacies. (NEMA,

No. 11.1 at p. 5; OSRAM SYLVANIA, Public Meeting Transcript, No. 8 at p. 77) Acuity added

that even within a 50

– 150 W class, there is a significant degree of variability. Therefore, Acuity suggested using 50

– 70 W as the baseline, rather than 150 W . (Acuity, Public Meeting Transcript,

No. 8 at p. 78)

DOE carried out additional analysis on the shipment volume and range of efficiencies

available in a <150 W class. DOE ’s efficiency test results for a ballast wattage representative of

the low

- wattage class ( 70 W ) confirmed that lower wattage ballasts have significant difference s in efficiency depending on the technology ( i.e

., electronic or magnetic ballast ). In terms of shipment volume, m anufacturers indicated during interviews that lower wattage shipments predominantly fall between 50 W and 150 W

, rather than the <50 W category

. Based on the shipment volume and comments received, DOE is considering ≥50 W and <150 W as the lowest wattage bin range

. DOE selects a representative unit in the engineering analysis to ensure2

- 31 technological feasibility of all produ ct s in the ≥50 W and <150 W class. For today’s rule

, DOE is considering defining the metal halide lamp fixture equipment classes by the rated lamp wattage ranges ≥ 50 W and <150 W

, ≥150 W and ≤250 W

, >250 W and
≤500 W , and >500 W

. DOE requests comment on the wattage ranges under consideration, and in particular the ≥ 50 W to <150 W and >500 W classes.

Input Voltage

For the framework document, DOE’s initial review of manufacturer catalogs showed that various metal halide lamp fixt ures are equipped with metal halide lamp ballasts that operate at several different input voltages. Voltage affects the power the ballast uses, as well as I 2 R losses, l
and therefore affects efficiency. Generally, as voltage increases, current decreases, th ereby reducing current losses and increasing ballast efficiency. Metal halide lamp ballast input voltages range by application and are commonly available from the typical residential 120 V up to industrial applications of 480 V. Additionally, there are typ es of niche equipment that can

operate at a 600 V input voltage. For the framework document, DOE determined that metal halide lamp ballasts could be grouped into three main input voltage ranges: (1) residential/commercial (retail) at less than 150 V

, (2) commercial/industrial at ≥150 V and ≤ 300

V

, and (3) commercial/industrial at greater than 300 V. For the framework document, DOE considered establishing the separation of metal halide lamp fixture equipment classes by including the separation of balla st input voltages. Voltage ranges would include common residential to commercial voltages in the less than 150 V category, the ≥ 150 V and ≤ 300 V category, and the greater than 300 V category

.

Philips suggest ed simplifying the equipment classes by distin guishing voltage as only either greater than 300 V or less than 300 V. (Philips, Public Meeting Transcript, No. 8 at p. 76) Philips Lighting Electronics did not agree with using voltage as a class separator. (Philips Lighting Electronics, Public Meeting Tr anscript, No. 8 at p. 57) NEMA and Philips Lighting Electronics pointed out that multiple voltages are typical for electromagnetic and electronic

ballasts and benefit consumers and manufacturers by decreasi ng SKU m

l I 2 R losses are the power losses due to the flow of current through conductors. As current flows through wires and electrical components, the resistance causes some of the power to dissipate as heat. count, allowing the operation of auxiliary equipment, and lowering costs. They also may have an efficiency penalty,

but it is only around a half a percent. (NEMA, No. 11.1 at p. 4

– 5; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 55

– 56, 60) NEMA also noted that universal/mul ti

voltage ballasts allow for the production of stock fixture s, which further save users money. (NEMA, No. 11.1 at p. 4) NEMA added that the efficiency of each ballast should be determined at the highest rated voltage of that ballast (NEMA, No. 11.1 at p. 4) Philips felt that any standard that penalized universal/multi

- voltage ballasts would, in effect

, penalize electronic ballasts. (Philips, Public Meeting Transcript, No. 8 at p. 59) Based on experience with California Title 20, Venture Lighting suggested using fewer voltage bins for separation and not making divisions based on insignificant efficiency variations. (Venture Lighting, Public Meeting Transcript, No. 8 at p. 58) EEI stated that if the efficiency values are significantly different in the various voltage bins, the equipment classes could create loss of “economies of scale” for manufacturers. (EEI,

No. 10.1 at p. 1)

m “Stock Keeping Unit” refers to an alphanumeric identi fier unique to each product that can be purchased.2

- 32 During interviews and further research of the market, DOE learned that the majority of available metal halide ballasts have the capab ility to operate at different voltages or have multiple voltage “taps” with different voltages for each tap. As noted above by interested parties,

the multi

- tap s and multiple voltages benefit consumers and manufacturers by decreasi ng SKU count, allowing th e operation of auxiliary equipment, and lowering costs by decreasing part counts and variations of ballasts. DOE’s test results for ballast efficiency showed that although voltage can correlate weakly to efficiency, there is no prevailing relationship ( e.g ., higher voltages are not always more efficient) across ballast designs. Therefore, DOE preliminarily plans to not separate equipment classes by voltages.

T o further consider Philips’ suggestion to distinguish between input voltages above and below 300, however, DOE examined test results for 1000 W ballasts. The first comparison DOE drew was between quad

- input

- voltage ballasts (ballasts able to operate at 120, 208, 240, and 277 V) and dedicated 480 V units. DOE found that the quad

- input

- voltage ballasts were, on average, 1.2% more efficient. DOE also compared quad

- and quint

- input

- voltage ballasts (ballasts that are able to operate at 120, 208, 240, 277, and 480 V). DOE found that the quad

- input

- voltage ballasts were, on average, 0.4% more efficient. DOE is interested in additional information about these efficiency variations and how they originate. DOE requests comment on whether, why, and to what degree quad

- input

- voltage, quint

- input

- voltage, and dedicated 480 V ballasts have

different characteristic e fficiencies. DOE further requests comment on whether it would be appropriate to establish a separate equipment classes for ballasts operating above 300 V and, if so, why quint

- input

- voltage ballasts belong in one class or the other.

In reference to the in put voltage at which a multiple input voltage ballast should be tested, DOE plans to propose an am endment to the existing test procedure

. DOE disagrees with NEMA’s comment to test metal halide ballasts at the highest voltage they are designed to operate. I nstead, DOE is planning an amendment that would require multiple input voltage

ballasts be tested at each input voltage . The reported efficiency value would be equal to the average of the tested efficiency at each input voltage

. This amendment could more a ccurately assess the performance of the ballast in practice as ballasts are frequently operated at input voltages other than the highest possible. DOE requests comment on this planned amendment to the test procedure.

Number of Lamps p er Ballast

Metal halide lamp ballasts are commonly designed to operate with a single lamp because of lamp characteristics such as re

- striking and voltage regulation. However, a review of manufacturer catalogs shows that while a majority of available ballasts only operate one lamp, a limited number are designed for two lamps.

For today’s rule, DOE believes it is not necessary to further divide metal halide lamp fixtures equipment classes by including separate equipment classes for ballasts that are designed

to be operated with multiple lamps ( e.g. , two lamp ballasts). The limited information DOE has gathered shows little to no change in efficiency between a one

- lamp and two

- lamp metal halide

ballast. Also, DOE did not receive any comments warranting separation of e quipment classes by2

- 33 the number of lamps that a ballast operates. DOE see ks further comment on the differences

between one

- lamp and two

- lamp metal halide ballasts and whether DOE should separate metal halide lamp fixture equipment classes by this feature.

Starting Method

Metal halide lamp ballasts currently available in the market are specifically designed to operate with either a probe

- start or pulse

- start lamp, but not both types of lamps at the same time.

The main differences between these types of sta rting methods is the inclusion of a third probe in probe

- start lamps, the need for an igniter circuit for pulse

- start lamps, and the different wiring specification for ballasts of each starting method. Most new applications in the market are pulse

start du e to its inherently better efficacy. However, with minor changes to the wiring specification and configuration within a fixture as well as the swap of lamp type, probe

- start ballasts can be replaced by pulse

- start ballasts. Manufacturers also have develope d pulse

- start retrofit kits for existing probe

- start applications.

The Joint Comment, ACEEE , and CA IOUs questioned whether eliminating starting method and electronic configuration as class

- setting factors would violate anti

- backsliding provisions under EISA standards that require a minimum 94 percent ballast efficiency for

fix tures with probe

- start ballasts. ACEEE recommended banning the use of probe

- start ballasts or establishing a separate product class for metal halide lamp fixtures with these ballas ts. (Joint Comment, No. 16.1 at p. 3; ACEEE, Public Meeting Transcript, No. 8 at p. 56; CA IOUs, No.

17.2 at p. 5)

For today’s rule DOE does not further divide equipment classes by the ballast starting method ( e.g

. , pulse

- start or probe

- start). DOE’s ini tial view is that equipment classes should not be further divided by starting method due to their interchangeability and lack of unique or separate utility that would affect efficiency. To prevent violat ion of anti

- backsliding provisions under EISA, DOE will maintain EISA minimum ballast efficiency requirements for fixtures with probe

- start ballasts if the analysis in this rulemaking does not support amending stan dards to a more stringent level relative to EISA. DOE is considering whether a design standar d that would eliminate probe start would result in significant energy savings. Additional detail on the potential for a design standard is included in section 2.6.3

.

Electronic Configuration and Circuit Type

Metal halide lamp ballasts have two distinct types of electronic configuration: electronic and electromagnetic (magnetic). The more commonly used magnetic ballasts are typically composed of transformer

- like co pper windings on a steel or iron core. The newer and more efficient electronic ballasts rely on electronic filters, switches, and capacitors/inductors to control current and voltage to the lamp.

In metal halide lamp fixtures, electronic ballasts can be used to achieve higher efficiency than magnetic ballasts. In the current metal halide lamp fixtures market, electronic ballasts are direct replacements for magnetic ballasts for most lower to medium wattage applications (up to

500 W ). DOE’s r eview of manuf acturer catalogs shows that at higher wattages, few electronic2

- 34 ballasts are available due to the significantly higher cost of components. For electronic ballasts, the only difference in circuit type is either “high” or “low” frequency circuit type. Due to acoustic resonance issues and electromagnetic interference (EMI) effects, ballast frequencies above 300 Hz become difficult to manufacture and have difficulty complying with Federal Communications Commission (FCC) standards. n For low

- frequency electronic b allasts, a square current waveform is used to diminish acoustic resonance and maintain lamp life. Though electronic ballasts are commonly more efficient than magnetic ballasts, neither configuration provides a distinct consumer utility over the other. Both types are capable of producing the same amount of light and can be used interchangeably.

EISA 2007 distinguishes non

- pulse

- start electronic equipment classes by separati ng them into two rated lamp wattage ranges ( ≥150 W and ≤250 W , and >250 W and ≤500 W ). According

to DOE’s review of manufacturer catalogs and information provided by manufacturers during

interviews , non

- pulse

- start electronic metal halide lamp ballasts are not available in the market. While EISA 2007 provisions may have been intended to c apture alternative technologies that could be available in the near term, DOE has no information that indicates differences in efficiency or consumer utility based on pulse versus non

- pulse

- start ballasts . Therefore, D OE does not believe equipment classes should be divided by electronic configuration. DOE seeks comment on the different electronic configurations and the separation of metal halide lamp fixtures equipment classes by these ballast features.

Magnetic metal halide lamp 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) ba llasts. Each magnetic circuit type listed has different characteristics that could have separate applications. These characteristics include size, efficiency, and power regulation. Each of these characteristics is discussed in chapter 3 of the preliminary TSD. 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).

Because electronic ballasts can provide the utility included in any magnetic circuit type

, can be used as substitutes in all applications, and are generally more efficient than magnetic ballasts, DOE is not setting separate equipment classes based on electronic configuration (magnetic vs. electroni c) or on circuit type. However, if appropriate, DOE could further divide equipment classes by either of these parameters based on any new data indicating that separation

is warranted. DOE seeks comment on electronic configuration and circuit types and the need for additional separation of metal halide lamp fixture equipment classes by this feature

.

Fixture Application

n FCC regulations at 47 CFR part 18, subpart C set forth technical standards for industrial, scientific, and medical equipment that specify frequency bands and ranges tolerances as well as electromagnetic fields strength limits. Some metal halide lamp ballasts may be covered under the se “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 18.111.2

- 35 In response to the framework document, some interested parties indicated preference in further dividing metal halide lamp fixture equipme nt classes by application

, such as indoor and

outdoor.

Progress Energy Carolinas recommended separate efficiency standards for indoor and outdoor fixtures. Progress Energy Carolinas felt that currently there is a significant difference between the produc t types and the conditions of their use. (Progress Energy Carolinas, No. 14.1 at p. 1) Similarly, CA IOUs felt that DOE should create temporary indoor and outdoor classes for this standard to give electronic ballasts time to develop better outdoor compatib ility. (CA IOUs,

No. 17.2 at p. 7) Earthjustice and NCLC added that electronic ballasts are poorly suited to operate under certain electrical supply and environmental conditions, but suggested that if these concerns warranted a distinct product class, the product class in question would be fixtures for outdoor applications, not fixtures equipped with electronic ballast s . ( Earthjustice and NCLC , No.

15.1 at p. 3)

The Joint Comment suggested basing equipment classes on product type and application

with the largest market share and specific operating conditions that influence the types of energy saving technology options available for those product classes. The Joint Comment suggested application based equipment classes for high

- bay, low

- bay, other interior, and exterior metal halide luminaires (Joint Comment, No. 16.1 at p. 3)

DOE notes that it has preliminarily determined to set energy conservation standards

based on a ballast efficiency metric. DOE’s research has tentatively determined that the same efficiencies can be achieved in all applications (including outdoor and indoor) by the same or similar products. DOE also found that electronic ballasts have been successfully applied to a variety of both indoor and outdoor applications where temperature and other limiting conditions could hinder their implementation. In the context of a ballast efficiency metric, DO E also

believes defining product types and applications for equipment classes is difficult and subjective. For today’s rule DOE does not plan to further divide equipment classes by application. DOE seeks comment on the different applications for metal hali de lamp fixtures and the need for additional separation of equipment classes by this feature.

In summary, after considering all potential class

- setting factors, DOE decided to define equipment classes based on rated lamp wattage. Th is class

- setting fact or created four equipment classes, summarized in Table 2

. 3 . DOE requests comment on these equipment classes. A more

detailed discussion of each class

- setting factor t hat DOE considered can be found in chapter 3 of this preliminary TSD.2

- 36 Table 2

. 3 Equipment Class Summary

Equipment

Class Rated Lamp Wattage

1 ≥50 W and <150 W

2 ≥150 W and ≤250 W

3 >250 W and ≤500 W

4 > 500 W

2.5 SCREENING ANALYSIS

After DOE identified the technologies that might improve the energy efficiency of metal halide lamp ballasts included in covered metal halide lamp fixtures, DOE conducted the screening analysis. The purpose of the screening analysis is to determine which options to consider further and which to screen out. DOE consults with industry, technical experts, and other interested parties in developing a list of design options. DOE then applies the follow ing set of screening criteria to determine which design options are unsuitable for further consideration in the rulemaking 10 CFR p art 430, subpart C, appendix A at 4(a)(4) and 5(b):

**•** Technological Feasibility: DOE will consider only those technologies inc orporated in commercial equipment or in working prototypes to be technologically feasible.

**•** Practicability to Manufacture, Install, and Service: If mass production of a technology in commercial equipment and reliable installation and servicing of the

techno logy could be achieved on the scale necessary to serve the relevant market at the time of the effective date of the standard, then DOE will consider that technology practicable to manufacture, install, and service.

**•** Adverse Impacts on Equipment Utility or E quipment Availability: DOE will not further consider a technology i f DOE determines it will have a significant adverse impact on the utility of the equipment to significant subgroups of consumers . DOE will also not further consider a technology that will r esult in the unavailability of any covered equipment type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as equipment generally available in the United States at the time

.

**•** Adverse Impacts on Health or Safety: DOE will not further consider a technology i f

DOE determines that the technology will have significant adverse impacts on health or safety

.

ASAP considered only analyzing current domestic technology to be unjustified and recommended that DOE analyze technologies available internationally

, as the lighting market is largely made up of multinational companies competing on a global scale. (ASAP, Public Meeting Transcript, No. 8 at pp. 68

– 69) The Joint Comment urged DOE to examine the international market and not to screen out technology based on availability in the domestic

market

, as those limits could result in missed opportunities for greater energy savings. ( Joint

Comment , No. 16.1 at p. 4) Philips Lighting Electronics stated that it was unaware of technology2

- 37 used abroad that was not also available domestically. (Philips Lighting Electronics, Public Meeting Transcript, No. 8 at p. 69) Acuity Brands Lighting noted that trade agreemen ts and stimulus funds have certain requirements about buying components manufactured domestically

that might prove problematic if DOE shifted regulations to analyzing foreign

- sourced components. (Acuity Brands Lighting, Public Meeting Transcript, No. 8 at pp. 69

– 70) NEMA encouraged consideration of the impact of global technologies on domestic manufacturing, and

stated that F ederal government emphasis on domestic materials makes it more challenging to meet domestic material, production, and procurement requ irements. (NEMA, No. 11.1 at p. 7)

When DOE conducts the screening analysis, it applies the four listed screening criteria to determine which design options are unsuitable for further consideration in the rulemaking . The four criteria are technological f easibility ; practicability to manufacture, install and service ; adverse impacts on equipment utility or equipment availability ; and adverse impacts on health or safety. The technology of concern has to be readily available in the United States regardless o f where it was manufactured. According to all interviewed manufacturers, a significant portion of ballasts, regardless of technology ( e.g ., electronic or magnetic)

, are built abroad. The technology options analyzed for this rulemaking are all readily avail able and already incorporated into ballast designs currently installed in a wide variety of fixtures. DOE analyzed all domestically available technologies and is not aware of additional international technologies. DOE seeks

comment on whether there are tec hnologies available abroad not included in the analysis.

After examining all of the options presented in the technology assessment, DOE determined that none of the technology options should be screened out. Therefore all of these options will be considere d in the engineering analysis. Because these options are in commercial use today, DOE concluded that they are technologically feasible and practicable to manufacture, install, and service. DOE is not aware of any adverse impacts on consumer utility, reliab ility, health, or safety associated with the design options identified. For a complete discussion of the screening analysis, refer to c hapter 4 of the preliminary TSD. DOE requests comment on whether interested parties agree that amorphous steel and electr ical components more efficien t than those currently incorporated into metal halide ballasts are technologically feasible and practicable to manufacture technology options. In addition, DOE requests comment on the anticipated incremental costs and efficienc y improvements from implementing these options.

2.6 ENGINEERING ANALYSIS

DOE performed an engineering analysis to establish the relationship between the manufacturer production cost (MPC) and the energy efficiency of metal halide lamp fixtures.

The relationshi p between the MPC and energy efficiency serves as the basis of the cost

- benefit calculations for individual consumers, manufacturers, and the n ation. This section provides an overview of the engineering analysis, discusses the representative equipment clas ses, establishes baseline unit specifications for those equipment classes, discusses incremental efficiency levels,

and discusses the analysis and results for the representative equipment classes.

The primary inputs to the engineering analysis are the design options from the screening analysis (see chapter 4 of the preliminary TSD). Additional inputs include cost and efficiency data derived from the physical teardowns

, a price analysis, and test data from independent labs.2

- 38 The primary output of the engi neering analysis is a set of cost

- efficiency points. In a subsequent

life

- cycle cost analysis (chapter 8 of the preliminary TSD), DOE used the cost

- efficiency points to determine customer prices for each equipment type by applying the appropriate distribut ion channel markups. The cost

- efficiency relationships will also inform the decisions of how to possibly set standards for the wattage

- defined equipment classes. For further discussion on the engineering analysis, see chapter 5 of the preliminary TSD.

The Joint Comment

, ASAP

, and CA IOUs suggested basing the requirements on an equation rather than wattage bins because a step function is limited in capturing energy savings and generally causes product clusters at the lowest possible efficiency in each wattag e bin. (Joint Comment, No. 16.1 at p. 3 ; ASAP, Public Meeting Transcript, No. 8 at pp. 58

– 59; CA IOUs, No.

17.2 at p. 7)

Through testing and market research, DOE preliminarily determined that efficiencies of metal halide lamp ballasts vary minimally with in most of the established equipment classes and that efficiencies can be improved within a particular class at similar cost. Therefore, DOE has preliminarily chosen to set standards using bins for all equipment classes, but requests comment

on whether any particular wattage bin would require the use of an equation to accurately represent the relationship between wattage and efficiency

.

2.6.1 Preliminary Engineering Analysis Approach
DOE typically structures its engineering analysis around one of the following th ree methodologies:

(1) the design

- option approach, which calculates the incremental cost of adding specific design options to the baseline model; (2) the efficiency

- level approach, which calculates the relative costs of achieving increases in energy effic iency levels, without regard to the particular design options used to achieve such increases; or (3) the reverse engineering cost

- assessment approach, which involves a “bottom

- up” manufacturing cost assessment based on a detailed bill

of materials (BOM) de rived from teardowns of equipment being analyzed.

In evaluating the most appropriate methodology for the engineering analysis, DOE determined that an efficiency level approach paired with reverse engineering cost estimates would yield the most realistic data. In this way, DOE would not solely rely on prod uct lists or minimum cost data supplied by manufacturers. Because DOE was unable to reverse engineer some ballasts analyzed in the rulemaking due to potting (a tar

- like fill material that inhibits the visual observation of the components), DOE conducted te ardowns for only unpotted ballasts and ballasts removed from a manufacturing facility before the potting procedure. The following discussion summarizes the general steps of the engineering analysis:

Representative Equipment C lasses , Ballasts, and Fixture s : DOE first reviews covered metal halide lamp fixtures and the associated equipment classes. When many equipment classes exist, DOE selects certain classes as “representative” and concentrates its analytical effort on these. DOE selects representative equ ipment classes primarily because of their high market volumes. For the metal halide lamp fixture rulemaking, DOE analyzed all equipment classes.2

- 39 Baseline M odel s

To develop the engineering analysis, DOE purchased a range of commercially available

ballasts included in covered metal halide lamp fixtures, and tested them at a n accredited testing laboratory for ballast efficiency. All tes t results are presented in appendix 5A of the preliminary

TSD. For the baseline model , DOE selected specific characteristics such as wattage, voltage ( dedicated, multi

- tap

, or multi

- voltage), electronic configuration (electronic or magnetic)

, starting meth od (pulse

- and probe

- start)

, and circuit design to characterize the most common

ballast contained in covered metal halide fixture s

. : DOE establishes baseline models f or each analyzed equipment class

. The baseline serves as a reference point for each equipment class, against which DOE measures changes resulting from potential amended energy conservation standards. To determine energy savings and changes in price, DOE compares each energy efficiency leve l with the baseline unit. Generally, a baseline model is a commercially available model that just meets existing Federal energy conservation standards and provides basic consumer utility. If no standard exists for the

chosen baseline model , it represents t he typical fixture sold within an equipment class with the lowest tested ballast efficiency. NEMA and Philips Lighting Electronics stressed the importance of relying only on test data from certified labs, and not basing results on reported efficiency

value s or marketing claims from manufacturers. (NEMA, No. 11.1 at p. 7; Philips Lighting Electronics, Public Meeting Transcript, No. 8 at pp. 79

– 80) DOE agrees with NEMA and Philips Lighting Electronics, and therefore has not reported information from product c atalogs as ballast efficiency.

Candidate M odel D esigns: DOE selects commercially available models with higher

ballast efficiency as replacements for each baseline model in the equipment classes by considering the design options identified in the technology assessment and screening analysis (preliminary TSD chapter 4). DOE is able to explicitly identify many of the disting uishing design options associated with each ballast contained in the covered fixtures. However, at some levels, these design options are considered to be implicitly used in the ballast to achieve higher ballast efficiency. o In identifying more efficient substitutes, DOE uses a database of commercially available metal halide fixture ballasts. DOE then tests these ballasts to establish ballast efficiency. All test results are presented in appendix 5A

.

Acuity advised taking sales into account when considerin g more efficient technology options to avoid highlighting technology with severely limited applications. (Acuity, Public Meeting Transcript, No. 8 at pp. 78

– 79) NEMA and OSRAM SYLVANIA also suggested standards be based on the more prevalent universal/multi

- voltage ballasts rather than the single voltage type. (OSRAM SYLVANIA, Public meeting Transcript, No. 8 at p. 57; NEMA, No. 11.1 at p. 4) DOE agrees with these comment s and has selected common circuit types when selecting representative units in each equipment class. DOE selected multiple input voltage representative units for each CSL for each equipment class. For the ≥150 W and ≤250 W

, >250 W and ≤500 W

, and >500 W equ ipment classes, DOE selected the CWA circuit type as representative of magnetic ballasts. As discussed in chapter 3 of the preliminary TSD, DOE determined that CWA magnetic ballasts are the most common for these wattage ranges. For the ≥ 50 W and <150 W

o Ballast catalogs usually designate whether the ballast is magnetic or electronic and the ANSI designated lamp it is designed to operate. The catalogs do not, however, specify the quality of components used or all aspects o f the circuit design.2

- 40 cla ss, DOE considered both high reactance autotransformer and CWA magnetic ballasts as representative.

Candidate S tandard L evels

. After identifying the more efficient substitutes for each

baseline model , DOE develops candidate standard levels (CSLs). DOE bas ed its analysis on two factors: (1) the design options associated with the specific models studied, and (2) the maximum technologically feasible efficiency level.

DOE is required by section 325(o) of EPCA to determine the maximum improvement in

ballast e fficiency that is technologically feasible (“max

- tech”) for metal halide lamp ballasts included in covered metal halide lamp fixtures. (42 U.S.C. 6295(o)). To determine this level, DOE conducted a survey of the metal halide lamp ballast market and the rese arch fields that support the market. DOE believes that within a given equipment class, no working equipment or prototypes exist that ha ve a distinguishably higher ballast efficiency than commercially available ballasts. Therefore, the highest CSL presented , which represents the most efficient commercially available ballasts included in covered fixtures, is the max

- tech level that DOE determined for this preliminary rulemaking. DOE requests comment on whether the efficiency of magnetic and

electronic ballast can be increased beyond that commercially available, and the associated costs and design pathways required.

DOE considers proprietary designs in its engineering analysis only if there are other technology pathways to meet that efficiency level. DOE does not regard a standard level that can be met by only one proprietary design to be economically justified. DOE believes that no CSL in this rulemaking requires the use of a proprietary technology. DOE requests comment on this

conclusion

.

Manufacturing Selling Price A nalysis

2.6.2 . After identifying both the baseline model and the more efficient substitutes at each CSL, DOE generate d a BOM by disassembling multiple

manufacturers’ ballasts and fixtures that span a range of efficiency levels for ea ch of the representative equipment classes. The BOMs describe the equipment in detail, including all manufacturing steps required to make or assemble each part. DOE then develo ped a cost model that converted the BOMs into MPCs. By applying derived manufact urer markups to the MPCs,

DOE calculated the MSPs and constructed industry cost

- efficiency points using the ballast efficiency test results. For a few CSLs, DOE was not able to generate a BOM. In these cases, DOE used scaling relationships between cost and efficiency and distribution chain markups to

estimate an MPC. For more information on DOE’s pricing analysis, see section or chapter 5 of the preliminary TSD.

As noted in section 2.2.1

, EISA 2007 grants DOE the authority to consider a “design

standard” in the metal ha lide lamp fixture energy conservation standard rulemaking. A design standard is a regulation that prohibits use of a certain technology in a type of equipment. In the preliminary analysis, DOE considers the use of a design standard in a ddition to a ballast efficiency

- based performance standard.2

- 41 2.6.2 Manufacturing Selling Price Analysis
Developing the manufacturer selling price for different metal halide lamp fixtures involved two main inputs, a teardown analysis to develop the manufacturer equipment costs and a markup analysis to arrive at the MSP. Figure 2.6

. 1 shows the general breakdown of costs and profit associated with manufacturing and selling equipme nt. The full cost of production is broken down into two main costs, the full production cost or manufacturing production cost and the non

production cost. The non

- production cost is equal to the manufacturer markup minus profits.

DOE totaled the cost of ma terials, labor, and direct overhead used to manufacture equipment in

order to calculate the MPC. p

Figure 2.6

. 1 Full Production Costs

The MPC is composed of direct labor, direct material, and overhead costs. 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 ballast s , direct material costs represent the purchase price of steel lamination s, copper wires, and other components. DOE used a 5

- year

average of material prices from mid

- 2006 to mid

- 2010. To estimate direct labor costs

, DOE used

current domestic labor rates of factory floor workers and supervisors for the fixture components’ MPCs, and foreign labor rates for ballasts’ MPCs, as the vast majority of ballast manufacturing

occurs overseas . Manufacturer overhead costs were estimated using a representative electronic fabrication company’s information

.

DOE carefully selected fixtures and ballasts for the teardown analysis to create useful data to estimate manufacturer production costs. DOE mapped out a matrix of equipment specifications and then compared ballasts that differ by only one attribute. Ballasts are described by a long list of specifications, so DOE concentrated on the specifications it expected to have the greatest effect on efficiency. This list included high versus regular advertised efficiency, rated wattage, input voltage, starting method, electronic configuration, and circ uit type. DOE

submitted 20 ballasts for teardown.

For fixtures, DOE tore down fixture types that represented the vast majority of the covered market, as given and validated by manufacturers. DOE submitted 8 fixtures for

teardowns. Because a variety of met al halide lamp fixture types may be used in an equipment

p 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.2

- 42 class, DOE averaged the cost of multiple fixture types when defining the representative empty fixture cost. DOE averaged the teardown cost of the fixture types identified in Tab le 2

. 4 to calculate the representative empty fixture MPC for that equipment class. For the 1000 W representative wattage, DOE scaled the empty fixture MSP from the 400 W representative

wat tage using a retail ratio. DOE believes the fixture types used in the >250 W and ≤500 W equipment class are similar to those used in the >500 W class . As discussed in section 2.6.4

, DOE assigned the same empty fixture MSP to all CSLs within an equipment class, regardless of whether the representative unit at that CSL was electronic or magnetic. Chapter 5 of the prelimin ary TSD provides more detail on the development of representative empty fixture MSP s

.

As mentioned in section 2.6.1

, DOE was able to select only unpotted electroni c ballasts for the teardown analysis. Some ballast manufacturers add potting, a type of black pitch, to the ballast enclosure to improve durability and manage heat distribution. Because the sticky potting inhibits visual observation of the components, DOE was unable to reverse engineer many electronic ballasts through a teardown analysis. DOE was able to perform a teardown analysis for all selected fixture types and calculated MPCs using BOMs and cost models, and then calculated MSPs using markups based on manufacturer

- given information.

As discussed in more detail in preliminary TSD Chapter 5, t o estimate MPCs for representative units that were not directly submitted for teardowns, DOE used several estimating techniques . In some cases , DOE marked down a di stributor price to an MSP and performed a linear interpolation between two adjacent CSL teardown MSPs.

Once MPCs were assigned to each CSL, DOE applied a manufacturer markup to scale the MPCs to MSPs. To calculate the manufacturer markup, DOE relied on mu lti

- year average financial data found in 10

- K reports from publicly owned ballast and fixture manufacturing companies, and revised the data based on information provided during interviews.

Using confidential data, DOE was able to verify scaled prices and a ppropriate markup and overhead estimates. When calculating the MPC through the BOM, DOE assigned prices to components based on high

- volume purchasing. DOE believes this method generated an accurate

estimation of the MSP.

2.6.3 Lumen Maintenance
DOE may set desig n standards, in addition to performance standards, for metal halide lamp fixture s. A design standard is a regulation that prohibits or mandates certain features in a type of equipment, which DOE may choose to set when such features affect performance of th at equipment but not its utility to consumers. One such feature may be starting method and, although DOE has not initially set a design standard related to starting method, it is interested in receiving comment on specific differences in efficacy and lumen maintenance across probe

- and pulse

- start systems

.

Although pulse

- start ballasts may not, themselves, be tested to be more efficient than probe

- start ballasts, DOE understands that they may operate more efficacious lamps . A consumer wishing to reduce ene rgy consumption while maintaining light levels might choose to replace probe

- start ballasts of a given wattage with either (1) fewer pulse

- start ballasts of the same wattage or (2) the same number of pulse

- sta rt ballasts of reduced wattage. In new construc tion,2

- 43 the former might allow a reduction in fixture count and produce the greatest cost savings. In a retrofit, the latter might allow a consumer to reduce energy without buying new fixtures.

DOE is aware that differences in lumen maintenance between pulse

- and probe

- start lamps may vary with wattage and, specifically, that the difference may be less pronounced at higher wattages. Progress Energy Carolinas suggested that fixtures of 1000 W not be subject to a pulse start ballast

- only requireme nt because of the limited pulse start ballast availability in the market. (Progress Energy Carolinas, No. 14.1 at p. 1) However, DOE has identified and tested multiple 1000 W pulse start ballasts from different manufacturers. DOE requests comment on specif ic, characteristic differences in lumen maintenance and efficacy across probe

- and pulse

start lamps rated for 70, 250, 400, and 1000 W. DOE also requests comment on setting a design standard that prohibits probe

- start ballasts in new fixtures, if differen ces in lumen maintenance and efficacy suggest doing so would produce significant energy savings.

2.6.4 Representative Wattages and Fixture Types
As discussed in the market and technology assessment (preliminary TSD chapter 3), DOE revised the existing equipment classes for metal halide lamp fixtures to include four equipment classes, defined by wattage range only

. DOE analyzed all four equipment classes and

create d a separate engineering analysis that established standards for each class

. For each equipment clas s, DOE selected a representative wattage ballast to analyze as a proxy for the entire equipment class. This wattage represents the most common wattage sold in a particular equipment class based on shipment volume. In addition, DOE received generally positi ve feedback on its selection of representative wattages during interviews with manufacturers. Table

2

. 4 summarize s the equipment classes and their corresponding repres entative wattages.

Regardless of whether total luminaire efficiency falls under the rulemaking, Philips noted that when developing cost

- efficiency relationships, DOE should analyze the cost of the total luminaire because ballast efficiency can affect luminaire cost. (Philips, Public Meeting Transcript, No. 8 at pp. 83

– 84) DOE agrees that in order to meet amended energy conservation standards, manufacturers could potentially change existing ballast design footprints. Depending on the fixture designs, th ese changes in ballast designs could require changes in fixture designs. Therefore, in the preliminary engineering analysis

, DOE included a fixture component cost and a ballast component cost to derive the total fixture manufacturing production cost and to investigate the necessary changes in the fixture. Table 2

. 4 summarizes the representative fixture types identified for each equipment class.

When determining wheth er a fixture must be altered to accommodate a given ballast,

DOE considered two issues . Most important is whether the ballast will physically fit within the space allotted to it. For all efficiency levels analyzed, DOE found that each fixture type was

capa ble of physically containing the ballast with minimal or no modification. The second consideration is, particularly in the case of electronic ballasts, whether the fixture can dissipate enough heat to keep the ballast at an acceptable temperature. This con sideration is much more difficult to explore, as it varies with each particular ballast/fixture combination and requires simultaneously monitoring temperature at several different points within the fixture.2

- 44 Instead of performing fixture

- specific thermal t esting, DOE preliminarily concluded that thermal management would not require significant fixture modification based on two observations. The first observation is that, at lower wattages, electronic ballasts are already quite prevalent in a variety of fixt ures. Many manufacturers of electronic metal halide lamp ballasts

als o manufacture electronic ballasts for fluorescent lamp fixtures of similar wattage. Though the two lighting types are not identical, they face some similar thermal challenges and having s olved the problem in one lighting realm suggests it may be tractable in the other. The second observation is that, at medium and higher wattages, fixtures tend to be less space

- constrained or “open.” This could allow a manufacturer to more easily thermally connect the hot ballast to the cooler fixture or in the open case, to add heat sinking directly to the ballast itself. Based on review of product catalogs, DOE discovered that manufacturers have already employed heat sinking for most 400 W ballasts curren tly on the market.

Based on DOE’s conclusions that magnetic fixtures can accommodate the space constraints and thermal requirements of electronic ballasts, DOE did no t apply empty fixture

incremental costs . The empty fixture MPC for a representative watt age was calculated as the average teardown cost of each of the fixture types identified as representative. This resulted in a “composite” fixture price representative of all the fixture types commonly used at a particular representative wattage. Therefore any changes in the total fixture MSP is only based on change

in ballast cost.

Table 2

. 4 Representative Wattages and Fixtures Types

Equipment

Class Rated Lamp Wattage Representative Wattage Representative Fixture Types

1 ≥50 W and <150 W 70 W Canopy

2 ≥150 W and ≤250 W 250 W Low

- bay, Canopy, Wallpack

3 >250 W and ≤500 W 400 W Flood, High

- bay, Canopy

4 >500 W 1000 W Flood, High

- bay, Canopy

DOE requests comment on its selection of representative wattages and fixtures for each equipment class.

2.6.5 B aseline Models and Candidate Standard Levels Analyzed
For each equipment class, DOE selected a baseline model as a reference point against which to measure changes resulting from energy conservation standard s. Typically, a baseline

model fixture will contain a ballast that just meets current Federal energy conservation standards and provides basic consumer utility. DOE considered the metal halide lamp fixture ballast s ’ characteristics in choosing the most app ropriate baseline for each equipment class

. These characteristics include the ballast’s input voltage ( dedicated, multi

- tap, or universal q

q Universal voltage ballasts can operate at 120 V or 277 V. ), wattage

, electronic configuration (electronic or magnetic)

, starting method, and circuit design

. To determine energy savings and changes in price, DOE compared each higher energy efficiency

level with the baseline unit.2

- 45 After choosing a baseline model , DOE surveyed and tested many manufacturers’ equipment offerings for ballast efficiency to identify the efficiency levels corresponding to the highest number of models. Then, DOE established CSLs based on the se ballast efficiency values and equipment

.

As an example, t he following discussion outlines DOE’s choice of baseline models and

CSLs for the ≥50 0 W equipment class. A review of catalog data indicates that 1000 W rated lamp wattage represented a significant portion of equipment available in the market. During

interview s manufacturers confirmed that 1000 W fixtures had the most shipments for the ≥500

W equipment class. Therefore, DOE selected 1000 W rated fixtures as the representative equipment for the ≥500 W equipment class . A discussion of the other three equipment classes can be found in Chapter 5 of the preliminary TSD.

DOE chose to analyze one baseline ballast for the 1000 watt representative wattage

. Although ballasts above 500 W are currently unregulated, they tend to be efficient relative to

smaller wattage units . DOE did not test any ballasts below 91% in efficiency. At the 1000 W level, most ballasts can operate on at least four input voltages, and the CWA circuit predominates. As discussed in chapter 3 of the preliminary TSD, DOE determined that CWA circuits are commonly used because it provides the lamp with a stable wattage (reducing the impact of input voltage variation on light output). Although p robe

- start ballasts are most

common at the 1000 W level, pulse

- start ballasts are widely available. Because the least efficient, quad

- voltage, CWA ballast tested was pulse

- start, DOE selecte d the pulse start ballast

as the baseline model for the 1000 W representative wattage.

Table 2

. 5 Baseline Models for the 1000 W Representative Wattage

Type Starting Method Input Power

W Ballast Efficiency Current Federal Standard

Magnetic Pulse 1088.1 91.9 % (none)

2.6.6 Candidate Standard Levels

For the 1000 W representative wattage

, DOE surveyed and tested many manufacturer product offerings for ballast efficiency to identify the efficiency levels corresponding to the highest number of models. DOE identified the most prevalent ballast efficiency values in the range of available equipment and established CSLs based on that equipment. DOE identified no 1000 W electronic ballasts on the market . This could be p artly because magnetic ballasts can be quite efficient at the 1000 W level and partly because of thermal challenges for high wattage

electronic ballasts

. A 1000 W electronic ballast dissipates a significant amount of heat which can lead to premat ure failure of electrical components and ultimately the ballast itself. D OE determined the maximum improvement in ballast efficiency that is technologically feasible (“max

- tech”) for metal halide lamp fixtures, as required by section 325(o) of EPCA. (42 U. S.C. 6295(o)). To determine this level, DOE conducted a survey of the metal halide lamp fixture market and the research fields that support the market. DOE believes that, within a given equipment class, no working prototypes exist that have a distinguishab ly higher ballast efficiency than currently available equipment. Therefore the highest CSL presented, which represents the most efficient tier of commercially available equipment, is the max

- tech level that DOE2

- 46 determined for this preliminary rulemaking. D OE requests comment on whether 1000 W electronic metal halide ballasts are technologically feasible

, and the potential for this technology to emerge in the future.

The following section identifies the steps and technologies associated with each CSL

DOE considered for the 1000 W representative wattage . As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher ballast efficiency than the baseline model. Efficiency improvements to the magnetic baseline unit required a higher grade of steel , copper windings, and more overall conductor material.

CSL 1 . Efficiency: 92.6 percent.

This level requires a ballast with a less lossy grade of steel, which may have thinner laminations. The stack height is maintained, and so is the ballast footprint. A decrease in steel thickness due to the steel grade and no change in the stack height equates to additional laminations and thus an improvement in efficiency. Conductor may be added and partially or wholly chan ged from aluminum to copper.

CSL 2 . Efficiency: 93.3 percent

CSL 2 represents the maximum technologically feasible level for the 1000 W representative wattage. CSL 2 requires an even better grade of steel, which may have thinner laminations. The stack height is maintained, and so is the ballast footprint. A decrease in steel thickness due to the steel grade and no change in the stack height equates to additional laminations and thus an improvement in efficiency. Conductor may be added to reach this efficiency , and it is almost certainly copper.

Chapter 5 of the preliminary TSD provides a more detailed discussion on how DOE selected baselines and CSLs for all equipment class es and which technologies they represent

. Table 2

. 7 outlines the CSLs for all equipment classes:

2.6.7 Prices and Results

Table 2

. 6 presents the engineering results for the 1000 W representative wattage. DOE presents the tested efficiency associated with each representative unit

. Input power values were normalized by dividing rated lamp wattage by efficiency, instead of using tested input wattage values directly. Although the input power derived this way can differ from a particular tested input power, DOE believes that ballasts are generally designed to operate lamps at their rated wattages. DOE sought to present an input power representative of the efficiency level and n ot an artifact of the particular model chosen. DOE reviewed its test data and found no evidence of a trend or correlation between efficiency and the ratio of rated lamp power to tested ballast output

power. DOE requests comment on the use of normalized inp ut power in its analysis.2

- 47 Table 2

. 6 1000 W Representative Wattage Engineering SummaryCandidate StandardLevelBallast EfficiencyNormalized InputPowerBallastManufacturerProduction Cost($)Empty FixtureManufacturerProduction Cost ($)FixtureManufacturerSelling Price($)

Baseline 91.9% 1088.1 40.02 132.77 254.00

CSL1 92.6% 10 79.9 46.26 132.77 263.18

CSL2 93.3% 107 1.8 49.32 132.77 267.68

2.6.8 Overall Engineering Summary

Table 2

. 7 and Table 2

. 8 summarize the ballast efficiencies and manufacturer selling prices associated with each CSL for all four equipment classes. Chapter 5 of the preliminary TSD provides additional detail on the development of these data.

Table 2

. 7 Summary of Baseline and Candidate Standard Levels for Metal Halide L amp Fixture Equipment Classes

Equipment Class (Rated Lamp Wattage) Ballast Efficiency (%)

Baseline CSL1 CSL2 CSL3 CSL4
≥50 W and <150 W 72.3 76.1 89.3 91.1
≥150 W and ≤250 W 88.0 90.5 91.5 92.1 93.6

>250 W and ≤500 W 88.0 90.0 91.7 92.7 93.9

>500 W 91.9 92.6 93.3

Table 2

. 8 Summary of Manufacturer Selling Prices for Metal Halide Lamp Fixture Representative Equipment Classes

Equipment Class (Rated Lamp Wattage) Manufacturer Selling Prices ($)

Baseline CSL1 CSL2 CSL3 CSL4
≥50 W and <150 W 51.53 52.23 54.69 61.12
≥150 W and ≤250 W 106.38 112.49 119.17 137.88 134.41

>250 W and ≤500 W 135.72 148.24 156.72 184.63 204.44

>500 W 254.00 263.18 267.68

DOE requests comment generally on its development of CSLs in all equipment classes and the accompanying MSPs. In addition, DOE noted in section 2.3.2.1 that high f requency operation could create challenges with respect to lamp/ballast compatibility. DOE uses a high frequency electronic ballast as a representative unit for CSL4 in the >250 W and ≤500 W class. DOE requests comment on the appropriateness of using high frequency ballasts as representative

units

.

2.7 ENERGY USE AND END

- USE LOAD CHARACTERIZ ATION

The energy use characterization provides estimates of annual energy use for representative metal halide lamp fixtures that DOE evaluates in the LCC and PBP analyses an d2

- 48 the NIA. To develop annual energy use estimates, DOE multiplied annual usage (in hours per year) by the system input power (in watts).

M etal halide lamps will not be regulated under the proposed metal halide lamp fixture rulemaking; however, the input power of the complete lamp

- and

- ballast system is considered for the energy use analysis because fixture ballasts are not intended to operate without lamps. DOE developed fixture ballast efficiencies in the engineering analysis (chapter 5 of the preliminary TSD) that, along with rated lamp wattages

, were used to estimate system input power for the representative fixture types . To characterize the country’s average use of lamp

- and

- ballast systems for a typical year, DOE developed annual operating hours by sec tor, using data published in the U.S. Lighting Market Characterization: Volume I (LMC), the Commercial Building Energy Consumption Survey (CBECS) , and the Manufacturer Energy Consumption Survey (MECS)

.

In response to DOE’s framework document, Georgia Powe r Company and Progress Energy Carolinas commented that DOE should use operating profiles for pole mounted fixtures. (Georgia Power Company, No. 12.1 at p. 1; Progress Energy Carolinas, No. 14.1 at p. 2) For the preliminary analysis, DOE addressed pole

- mounted fixtures in developing average annual operating hours for the “outdoor stationary” sector, based largely on LMC data for roadway and parking lot lighting.

CA IOUs noted that controls for both inte rior and exter ior lighting have the potential to save a significant amount of energy, and requested that DOE consider a compliance pathway involving controls similar to California’s Title 20. (CA IOUs, No

. 17.2 at p. 5) Title 20 requirements include compliance options for o ccupancy

- based and daylight

- based dimming of

interior metal halide fixtures. 3 In the preliminary analysis, DOE included operating profiles

where interior metal halide fixtures (commercial and industrial) were operated in a dimmed state (lamp input power re duced by 40 percent) for an assumed 30 percent of their annual operating

schedule . The resulting reduction in annual energy use and its effects on LCC results are examined in chapter 8 of the preliminary TSD. Upon further research and comment from

interest ed parties, DOE will consider the effects of controls and dimming on NIA results in the NOPR stage of this rulemaking. To further refine its analyses, DOE requests comment on the relationship between dimming and metal halide ballast efficiency, as well as representative operating profiles ( e.g. , percentages of full

- output versus dimmed operation) for occupancy

based and daylight

- based dimming metal halide applications.

See chapter 6 of the preliminary TSD for additional detail on the energy use

characterization.

2.8 MARKUP ANALYSIS

In this rulemaking, DOE performed teardown and price analyses and a manufacturer markup analysis to develop MSPs for representative fixture designs (chapter 5 of the preliminary TSD). DOE then applied distribution channel markups and sales tax to derive end

- user prices. By combining the engineering analysis results and the distribution channel markups analysis, DOE derived typical inputs for use in the LCC analysis and the NIA.2

- 49 The end

- user equipment price depends on how the end

- user purchases the equipment. As

illustrated in Figure 2.8

. 1

, metal halide lamp fixtures are typically sold by an original equipment manufacturer (OEM)

— in thi s case, the fixture manufacturer

— who in turn sells it to an electrical wholesaler ( i.e. , distributor), then to a contractor, and finally to the end

- user.

Figure 2.8

. 1 Metal Halide Lamp Fixture Distributi on Channel

Publicly owned companies are required to disclose financial information on a regular basis by filing various forms with the U.S. Securities and Exchange Commission (SEC). Filed annually, SEC form 10

- K provides a comprehensive overview of the c ompany’s business and financial conditions. To estimate OEM and wholesaler markups, DOE used financial data from

10

- K reports from publicly owned lighting fixture manufacturers and electrical wholesalers, respectively. DOE assumed a contractor markup consi stent with that used in the 2000 Ballast

Rule

, 4 and developed sales tax values using current State and local sales tax data.

DOE received comments regarding fixture pricing and distribution channels in response

to its framework document. Progress Energy Carolinas stated that many utilities purchase fixtures on longer term contract s that, with high

- volume purchases

, might allow for discount ed fixture pricing for the utility. (Progress Energy Carolinas, No. 14.1 at p. 2) DOE acknowledges

that actual end

- use r pricing for fixtures can vary widely, and welcomes comment on the representative MSPs and markups developed for the preliminary analysis. While affirming the primary distribution channel identified by DOE , the CA IOUs noted that fixtures are also shipped directly to contractors from manufacturers. (CA IOUs, No. 17.2 at p. 8) Based on its research, DOE agrees that manufacturers can ship fixtures directly to contractors, but contends the related fixture purchases generally occur via electrical wholesalers, with no direct transaction between manufacturer and contractor. Therefore, DOE believes its primary distribution channel is appropriate for developing price markups for metal halide lamp fixtures.

DOE seeks comment on typical markups, as well as fixture pricing data that DOE could use to verify its preliminary price markups. Chapter 7 of the preliminary TSD provides details of the markups analysis. OEM FIXTURE

MANUFACTURER

ELECTRICAL WHOLESALER

CONTRACTOR

END

- USER OF LIGHTING SYSTEM2

- 50 2.9 LIFE

- CYCLE COST AND PAYBA CK PERIOD ANALYSES

Energy conservation standards on equipment usually reduce operating expenses and

increase end

- user prices. DOE analyzed the net effect of amended standards on end

- users by evaluating the net LCC using the cost

- efficiency relationship derived in the enginee ring analysis, as well as the energy usage and costs derived from the energy use characterization. Inputs to the

LCC calculation include the installed cost to the end

- user (purchase price plus installation cost), operating expenses (energy expenses and mai ntenance costs), the lifetime of the equipment , and a discount rate. Chapter 8 of the preliminary TSD describes these inputs.

In the LCC analysis, all replacement options are designed around p urchasing events when consumers can be affected by an amended e nergy conservation standard. Commenting on the framework document, Philips disagreed with DOE’s assumption that metal halide lamp fixtures

are replaced upon ballast failure, contending that fixtures typically have one or more ballast replacements during th eir service lifetimes . (Philips, Public Meeting Transcript, No. 8 at pp. 91

– 92) DOE acknowledges that consumers can replace failed ballasts in existing fixtures, and considered two purchasing events

— ballast replacement ( i.e. , within an existing fixture) and

fixture installation

— in the preliminary analysis. The fixture installation event addresses situations where the available substitute lamp

- and

- ballast system is not compatible with the existing fixture, as well as retrofits

, new construction , or renova tion. The LCC spreadsheet calculates the LCC impacts for each scenario.

DOE estimates electricity prices for commercial and industrial consumers by using Energy Information Administration (EIA) data. EIA’s Annual Energy Outlook was the default source of p rojections for future electricity prices. Progress Energy Carolinas commented that utilities may use different rates for metered and non

- metered service , differing by a factor of 2 or more, depending on the utility. (Progress Energy Carolinas, No. 14.1 at p. 2) DOE acknowledges that electricity prices can vary by customer and location, and will consider this variability in its LCC sensitivity analyses for the NOPR stage of this rulemaking.

In response to the framework document, DOE received a number of com ments on equipment lifetimes, which affect the LCC analysis period and its inputs. Progress Energy

Carolinas stated that the lifetime of fixtures , ballasts

, and lamps can vary widely depending on equipment and operating conditions . (Progress Energy Carolin as, No. 14.1 at p. 3) The physical lifetime ( e.g. , years until ballast or fixture failure) and “economic lifetime” ( e.g. , years until retrofit) of lighting equipment can vary greatly; consequently, DOE uses average ballast and fixture lifetimes in its prel iminary LCC analysis to illustrate representative effects on individual consumers. In contrast, DOE uses a distribution of equipment lifetimes in the NIA to account for aggregate energy usage and economic effects on the n ation. NEMA also suggested that DOE examine the effects of ballasts on lamp life in metal halide lamp fixtures. (NEMA, No. 11.1 at p. 9) For the preliminary analysis, DOE researched lamp manufacturer data to assign median lamp lifetimes for each fixture equipment class, but could not establ ish a technical basis for varying lamp life between CSLs ( i.e. , ballast designs) within equipment classes. DOE welcomes comments on its assumed lifetimes for fixtures, ballasts

, and lamps, and how they may vary within the representative equipment classes.2

- 51 DOE developed discount rates by estimating the cost of capital to purchasers of the equipment covered under this rulemaking. For commercial and industrial end users, DOE used the cost of capital to estimate the present value of cash flows to be derived fr om a typical company project or investment. Most companies use both debt and equity capital to fund investments, so the cost of capital is the weighted

- average cost to the firm of equity and debt financing. This corporate finance approach is referred to as the weighted

- average cost of capital. DOE used currently available economic data in developing discount rates and will update the data as appropriate for the NOPR stage of this rulemaking.

For more detail on the LCC and PBP analyses, see chapter 8 of th e preliminary TSD.

2.10 SHIPMENTS ANALYSIS

Shipments of metal halide lamp fixtures are key inputs to the national energy savings and net present value calculations in the NIA model. Shipments are also a necessary input to the MIA, which DOE will conduct for the NOPR stage of this rulemaking. DOE was not able to obtain manufacturer historical shipment data for fixtures from NEMA in the preliminary analysis ; however, DOE did obtain limited historical shipment data for fixtures from the U.S.

Census. Consequ ently, DOE followed a three

- step process to forecast ballast shipments. First,

DOE correlated historical metal halide lamp shipment data provided by NEMA in the HID lamps determination with fixture shipments for the Census data to estimate the total histor ical shipments of each fixture type. Second, DOE calculated an installed stock for each fixture type
based on fixture service lifetimes . Third, by modeling purchasing events for ballast replacement

and fixture installation and applying assumptions on growt h rate

, replacement rate, and emerging technolog y ( i.e. , solid

- state lighting) penetration rate, DOE developed annual shipment projections.

Several comments to the framework document addressed existing and potential incentive programs for improving metal halide lamp fixture efficiency, which could affect future fixture shipments. Progress Energy stated that as the baseline efficiency increases through legislation and rulemaking, the incentive qualifications for rebate programs would also increase. (Progres s Energy Carolinas, No. 14.1 at p. 3) NEEP and CA IOUs provided summaries of metal halide

related incentives in their respective regions . (NEEP, No. 16.1 at p. 1 ; CA IOUs, No. 17.2 at p. 9) For its preliminary analysis, DOE conducted market and technology research, manufacturer interviews, and regulatory review to help identify future shipment trends . DOE assumes that these trends integrate various regulatory and non

- regulatory initiatives in the lighting marketplace. DOE seeks comment on the trends and mag nitude of its metal halide lamp fixture shipment projections, as well as historical shipment fixture data to help validate its methodology.

To determine the cumulative NES and NPV of amended standards, DOE compared

forecasted shipments of a base to a standards case over the NIA analysis period. Chapter 9 of the preliminary TSD provides details on the shipments analysis.2

- 52 2.11 NATIONAL IMPACT ANAL YSIS

The national impact analysis assesses the net present value of total end

- user LCC and

NES. DOE determined bo th the NPV and NES for the performance levels considered for the fixture equipment classes analyzed. To make the analysis more transparent to all interested parties, DOE prepared an NES spreadsheet model to forecast energy savings and the national

economic costs and savings resulting from amended standards. With the exception of equipment lifetimes, t he NES model does not use probability distributions for inputs or outputs. To assess the impact of input uncertainty on the NES and NPV results, DOE can conduc t sensitivity analyses by running scenarios on input variables relevant to interested parties. DOE assessed the aggregate economic impacts at the national level for this preliminary analysis.

2.11.1 National Energy Savings Analysis
The inputs for determining NES are (1) annual energy consumption per unit

, (2) shipments

, (3) equipment stock

, (4) national energy consumption (calculated from consumption per unit and equipment stock )

, (5) site

- to

- source conversion factors

, (6) a heating, ventilation, air conditioning (HVAC) factor

, and (7) rebound rates.

DOE calculated the national energy consumption by multiplying the number of units, or stock, of metal halide lamp fixtures by the unit energy consumption. Then, DOE calculated national annual energy savings from the difference between national energy consumption in the base case (without amended efficiency standards) and in each higher

- efficiency standards case. DOE estimated energy consumption and savings based on site energy, and converted the electricity consumpti on and savings to source energy. DOE also examined potential energy savings due to HVAC interactions, as well as rebound effects (an energy savings “take

- back”) based on consumer usage patterns. Cumulative energy savings are the sum of the annual NES,

whic h DOE determined over specific time periods.

2.11.2 Net Present Value Analysis
The inputs DOE used to determine the NPV were (1) total annual installed cost, (2) total annual operating cost savings, (3) discount factor, (4) present value of costs, and (5) presen t value of savings. DOE calculates net savings each year as the difference between total operating cost savings and increases in total installed costs (including equipment price and installation cost). DOE calculates savings over the life of the equipment, accounting for differences in yearly energy rates. DOE calculates NPV as the difference between the present value of operating cost savings and the present value of increased total installed costs. DOE discounts future costs and savings to the present wit h a discount factor.

DOE calculate d increases in total installed costs as the product of the difference in the

total installed cost between the base case and standards case

, and the annual shipments in the standards case. Because purchase costs of the hig her

- efficiency equipment in the standards case are generally greater than the purchase costs of equipment in the base case, price increases appear as negative values in the NPV. DOE expressed operating cost savings as decreases in operating costs associate d with the lower energy consumption of equipment in the standards case2

- 53 compared to the base efficiency case. Total operating cost savings are the product of savings per unit and the number of units surviving in a particular year.

2.11.3 Efficiency Scenarios and Trends
Several of the inputs for the determination of 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. Thus, DOE developed base ca se and standards case efficiency trends. These trends specified the annual historical and forecasted shipment

- weighted average equipment efficiencies.

For metal halide lamp fixtures , DOE developed two shipment scenarios: “roll up” and

“shift.” The roll

- up scenario represents a standards case in which all equipment efficiencies in the base case that do not meet the standard would roll up to meet the new standard level. Consumers in the base case who purchase equipment above the standard level are not affect ed as they are assumed to continue to purchase the same base

- case equipment . The roll

- up scenario characterizes consumers primarily driven by the first

- cost of the analyzed equipment.

In contrast, the shift scenario models a standards case in which the s tandard affects all

base

- case consumer purchases (regardless of whether their base

- case efficiency is below the standard). In this scenario, any consumer may purchase a more efficient fixture or ballast. As the standard level increases, market share increm entally accumulates at the highest standard level because it represents max tech ( i.e. , moving beyond this efficiency level is not achievable with today’s technology). The shift scenario characterizes consumers primarily concerned with system energy consumption and reflects an upper bound scenario.

Chapter 10 of the preliminary TSD provide s additional details on the national impacts analysis.

2.12 LIFE

- CYCLE COST SUBGROUP ANALYSIS

The LCC subgroup analysis evaluates economic impacts on selected groups of consumers who might be adversely affected by a change in the national energy conservation st andards for

the considered equipment . DOE evaluates impacts on particular subgroups of consumers in part by analyzing the LCC impacts and PBP for those particular consumers.

In response to the framework document, NEMA suggested that DOE evaluate the

follo wing subgroups: medium to high

- end retail, grocery, big

- box retail, schools, community centers, sport facilities including clubs, industrial, warehousing, various types of facilities with outdoor area lighting, and owners of streets and roadways ( for examp le

, property owners, municipalities, or state and federal departments of transportation ). (NEMA, No. 11.1 at p. 11) Georgia Power Company and Progress Energy Carolinas advocated that utility

- owned

- and

operated systems be considered as a n LCC subgroup. (Geo rgia Power Company, No. 12.1 at p. 1; Progress Energy Carolinas, No. 14.1 at p. 2) DOE will consider these suggested subgroups, and welcomes additional suggestions for its LCC subgroup analysis.2

- 54 As part of the NOPR analyses, DOE will analyze the LCC for each identified subgroup by applying the LCC spreadsheet model to only that subgroup. DOE is particularly sensitive to increases in the consumer price of the considered equipment as it wishes to avoid a negative economic impact on any identified consumer subgroup. See chapter 11 of the preliminary TSD for more information on the LCC subgroup analysis.

2.13 MANUFACTURER IMPACT ANALYSIS

The purpose of the MIA is to identify the likely i mpacts of higher energy conservation standards on manufacturers. The Process Rule provides guidance for conducting this analysis with input from manufacturers and other interested parties. DOE will apply this methodology to

its evaluation of standards for metal halide lamp fixtures and ballasts. The Process Rule gives guidelines for considering financial impacts and a wide range of quantitative and qualitative industry impacts that might occur after adoption of a standard. For example, a particular standard level could require changes to manufacturing practices of metal halide lamp fixtures and ballasts. DOE will identify and discuss these impacts in interviews with manufacturers and other interested parties during the NOPR stage of the analysis.

DOE will conduct the MIA in three phases, and will further tailor the analytical framework based on the comments it receives. In Phase I, DOE creates an industry profile to characterize the industry and identify important issues that require consideration. In Phase II, DOE prepares an industry cash

- flow model and an interview questionnaire to guide subsequent discussions. In Phase III, DOE interviews manufacturers and assesses the impacts of standards both quantitatively and qualitatively. DOE assesses industry and subgroup cash flow and NPV using the Government Regulatory Impact Model (GRIM). DOE then assesses impacts on competition, manufacturing capacity, employment, and regulatory burden based on manufacturer

interview feedback and discussions.

Until recently, DOE reported MIA results in its standards rulemakings only in the NOPR phase of the rulemaking. However, DOE is now evaluating and reporting preliminary MIA information at this preliminary analytical phase. DOE gathered the information for the analysis

dur ing the manufacturer interviews conducted after the engineering analysis. See Chapter 12 of the preliminary TSD for more detail on the MIA.

CA IOUs recommended DOE reach out to smaller manufacturers for information on their products and technologies in addition to the major manufacturers. (CA IOUs, No. 17.2 at p. 7) DOE agrees with the suggestion, and for the MIA DOE interviewed and researched both major

and smaller manufactur ers. DOE also tested equipment from both major and smaller

manufacturers.

NEM A stated that if the new standards drive the costs of metal halide systems so high that they are not cost justified versus other technologies based on the end user's standards, end users will use the other technologies that yield shorter paybacks. (NEMA, N o. 11.1 at 10) Philips pointed out that setting standards may specifically put low

- wattage products at a competitive disadvantage to the less efficient incandescent products they often replace. (Philips, Public Meeting Transcript, No. 8 at pp. 74

– 75) DOE u nderstands that new energy conservation2

- 55 standards could cause the equipment cost to increase, which could cause some consumers to move to less expensive alternatives. However, DOE has learned that there is already underway a market shift away from incandes cent or halogen to lower wattage metal halide technologies. Lower wattage metal halide technologies are already more expensive than the incandescent or halogen technologies that they are replacing. For the NOPR, DOE will further investigate this

trend and the possible impacts the new standards may have.

The Joint Comment, ACEEE, Earthjustice and NCLC , and CA IOU advised DOE to look outside the covered equipment category when calculating the industry net present value. ACEEE suggested DOE consider gains an d losses in manufacturers’ other product lines and company divisions when looking at the cumulative impact of standards affecting other business lines. If stronger standards would result in a market shift to other lighting products, Earthjustice and

NCLC n oted that DOE must take into account both negative and positive impacts on

manufacturers

, as sales revenue from substitute products could offset, in whole or in part, any

decline in revenue from decreased metal halide sales. The Joint Comment and ACEEE

com mented that looking at manufacturer impacts more broadly would be consistent with the methodology for analyzing cumulative regulatory burden. (ACEEE, Public Meeting Transcript,

No. 8 at pp. 147

- 148; Joint Comment, No. 16.1 at p. 4; Earthjustice and NCLC , N o. 15.1 at p. 3

– 4; CA IOUs, No. 17.2 at p. 9)

DOE agrees that amended energy conservation standards could impact the covered equipment market and cause possible shifts in technologies. These other technologies may or may not be manufactured by the same c ompanies that manufacture metal halide technologies. For the NOPR, DOE will investigate the potential for market shifts due to standards and if and how manufacturers will be impacted by such projected shifts. DOE will also further evaluate the

cumulative r egulatory burden affecting manufacturers of metal halide lamp fixtures.

2.13.1 Sources of Information for the Manufacturer Impact Analysis

T he se analyses provide important information applicable to the MIA. Such information includes manufacturing costs and pri ces from the engineering analysis, retail price forecasts, and shipment forecasts. DOE will supplement this information with company financial data and other information gathered during interviews with manufacturers.

The interview process plays a key rol e in the MIA. DOE aggregates information across manufacturers, creating a combined opinion or estimate for DOE. DOE conducts detailed interviews with manufacturers to gain insight into the range of potential impacts of standards. Typically, DOE solicits both quantitative and qualitative information during the interviews on the potential impacts of efficiency levels on sales, direct employment, capital assets, and industry competitiveness. DOE prefers an interactive interview process, rather than a written response to a questionnaire, because it helps clarify responses and identify additional issues. Before the

interv iews, DOE will circulate a draft document showing estimates of the financial parameters based on publicly available information. DOE will solicit comment on these estimates during the

interviews. See c hapter 12 of the preliminary TSD for more detail on the methodology used in

the MIA.2

- 56 2.13.2 Industry Cash

- Flow Analysis
The industry cash

- flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of more stringent energy conservation standards on the industries

.

The GRIM analysis uses several factors to determine annual cash flows from an amended energy conservation standard: annual expected revenues; manufacturer costs ( including cost of goods sold, depreciation, research and development, selling, and general and administrative

expenses ) ; taxes; and conversion capital expenditures. DOE co mpares the results against base case projections that involve no amended energy conservation standards. The financial impact of amended energy conservation standards is the differ ence between the two sets of discounted annual cash flows. Other performance metrics, such as return on invested capital, also are

available from the GRIM. See c hapter 12 of the preliminary TSD for more information on the industry cash

- flow analysis.

2.13.3 Manuf acturer Subgroup Analysis
Industry cost estimates are inadequate to assess differential impacts among subgroups of manufacturers because these subgroups may have different cost structures or regulatory frameworks that affect their respective business mode ls. For example, small and niche manufacturers, or manufacturers whose cost structure differs significantly from the industry average, could experience a more negative impact. Ideally, DOE would consider the impact on every firm individually; however, beca use this usually is not possible, DOE typically uses the results of the industry characterization to group manufacturers exhibiting similar characteristics.

NEMA and Philips argued that manufacturers of outdoor luminaires or luminaires for

extreme enviro nments, such as inside freezers and refineries, are disproportionately affected and should be analyzed as a subgroup. There is some overlap in lamp wattages used in outdoor and

indoor

- extreme applications, but there are very different requirements for fixt ure designs due to

the ambient conditions and electrical protections required. (NEMA, No. 11.1 at p. 11; Philips, Public Meeting Transcript, No. 8 at p. 145)

During the interview process, DOE will discuss the potential subgroups and subgroup

members it has identified for the analysis. DOE will encourage manufacturers to recommend subgroups or characteristics that are appropriate for the subgroup analysis. See c hapter 12 of the preliminary TSD for more detail on the manufacturer subgroup analysis.

2.13.4 Competi tive Impacts Assessment
EPCA directs DOE to consider any lessening of competition likely to result from the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General to determine in writing the impacts, if any, of any lessening of competition. (42 U.S.C. 6295(o)(2)(B)(ii))

DOE will make a determined effort to gather firm

- specific financial information and impacts and report the aggregated impact of the amended standard on manufacturers. The competitive impacts analy sis will focus on assessing the impacts on smaller manufacturers. DOE will base the assessment on manufacturing cost data and information collected from interviews with manufacturers. The manufacturer interviews will focus on gathering information that wou ld2

- 57 help in assessing asymmetrical cost increases to some manufacturers, an increase in the proportion of fixed costs ( with the potential to elevate business risk ) , and potential barriers to market entry ( e.g. , proprietary technologies). DOE will provide th e Attorney General with a copy of the NOPR for consideration in his evaluation of the impact of standards on the lessening of competition. DOE will publish the Attorney General’s letter and address any related comments

in the final rule.

2.13.5 Cumulative Regulat ory Burden
Other regulations may apply to the metal halide lamp fixtures and ballasts covered under this rulemaking, and to other equipment produced by metal halide lamp fixture and ballast

manufacturers. NEMA wanted to confirm that DOE would consider how the expansion of this rulemaking may overlap with other F ederal regulations and requirements. (NEMA, No. 11.1 at p.

1 ) DOE recognizes that multiple regulations could result in a significant, cumulative regulatory

burden on manufacturers and

, i n response, DOE’s initial analysis of regulations affecting metal

halide fixtures and ballasts is located in the market and technology assessment ( c hapter 3 of the preliminary TSD). During the NOPR, DOE plans to investigate the regulations that

manufacture rs mentioned in interviews and the public meeting, and will further analyze and consider the impact of multiple, equipment

- specific regulatory actions on metal halide lamp

fixture and ballast manufacturers

.

2.13.6 Preliminary Results for the Manufacturer Impact Analysis

One important aspect of the preliminary MIA is the opportunity it creates for DOE to identify key manufacturer issues early in the development of amended energy conservation

standards. During preliminary interviews manufacturers identified seven major areas of concern: (1) system approach, (2) absence of American National Standards Institute (ANSI) standards for

electronic ballasts , (3) testing burden, (4) technology shift, (5) impacts on profitability, ( 6 ) conversion costs, and ( 7 ) product innovation.

2.13.6.1 System Approach

Many manufacturers were conflicted over the decision to use either ballast or system efficiency metric s when determining fixture efficiency classification. Manufacturers commented that there is a greater potential for efficiency improvement when looking at a system than when considering only the incremental improvements possible with ballasts alone. However, manufacturers stated that existing fixture metrics are complicated and ambiguous, with definitions of products or applicati ons proving difficult to correctly assign. While a few ballast manufacturers favored a system approach, fixture and ballast manufacturers generally preferred exclusively using ballast efficiency. Manufacturers were concerned that a metric including the

lam p and ballast together could possibly favor specific combinations and penalize companies that did not package lamps with their ballasts. Developing specific lamp and ballast combinations could also mean that the consumer would be forced to replace lamps in an identical

manner , possibly requiring more effort to be spent on consumer education.2

- 58 2.13.6.2 Absence of Electronic Ballast ANSI Standards

S ome manufacturers worried about setting efficiency standards for electronic ballasts when ANSI currently has no standards for such high

- f requency ballasts. ANSI has attempted to address the issue, but as yet has been unable to reach a consensus. Manufacturers observed that without a standard, efficiency measurement for these ballasts poses challenges and requires special, ex pensive equipment.

2.13.6.3 Testing Burden

When mentioning regulatory burden, manufacturers spoke of the accompanying testing burden. There are already numerous testing requirements for certifications and compliance, and many manufacturers asserted that there ar e major problems with labeling and enforcement.

Manufacture r s stated that the new rulemaking would not only add another standard to meet, but would necessitate an estimated thousands of hours of testing at great expense for product development and redesign . Manufacturers also expressed concerns over additional testing for further requirements

, such as optics and thermal testing. If the rulemaking uses a lamp and ballast efficiency approach, some manufacturers felt they would be pressured into additional

lam p compatibility testing as well.

2.13.6.4 Technology Shift

Separate from this rulemaking or other standards related to metal halide lamp fixtures, manufacturers reported that a technological shift is already occurring away from metal halide in general. According t o manufacturers, LEDs and fluorescent technologies are capturing significant market share of new construction in both indoor and outdoor applications. Manufacturers are concerned that standards will accelerate this migration to alternative technologies due to price increases of standard

- compliant equipment. Additionally, manufacturers commented that with current migration in the industry towards LED and fluorescent technologies, the rulemaking forces resources away from the innovation process and responding to the market’s needs in order to spend time and money on a product with diminishing market share

.

2.13.6.5 Impacts on Profitability

Some manufacturers commented that profit margins would decrease with the implementation of amended energy conservation standards, especially for the OEM distribution

channels . For example, a higher standard could cause business to shift to overseas companies

that can compete on a cheaper level.

2.13.6.6 Product Conversion Costs/Diminishing Returns to Consumers

Certain manufacture r s commented that amended energy conservation standards would

force them to invest in more expensive and energy efficient components , improve existing product line s, and design new product lines. The majority of th ese product conversion costs
would be attributed to en gineering and testing, plant equipment, finer grade materials, production personnel and sales force retraining, and consumer education. Those manufacturers that expected2

- 59 significant product conversion costs commented that the large investments would ultima tely result in more expensive products for consumers.

2.13.6.7 Product Innovation

Manufacturers also expressed concern over the impact of amended energy conservation standards on product innovation. Employees may need to spend more time redesigning products

to com ply with standards. Thus, the resources available for the development of new products

would significantly decrease. This concern particularly involves some manufacturers’ efforts in researching and developing LED technology, predicted to eventually replace metal halide in many applications. Manufacturers were uneasy that this standard may force them to reallocate

resources away from LED to make expensive changes to their metal halide products that could

then drive consumers into the LED market.

2.14 UTILITY IMPACT ANALY SIS

The utility impact analysis includes an analysis of the effect of amended energy conservation standards on the electric and gas ut ility industries. For this analysis, DOE will use a

variant of the National Energy Modeling System ( NEMS )

, a large multi

- sectoral, partial

equilibrium model of the U.S. energy sector that the EIA has developed throughout the past decade, primarily for prep aring EIA’s AEO . In previous rulemakings, a variant of NEMS (currently termed NEMS

- BT, BT referring to the DOE’s Building Technologies Program version of NEMS), was developed to better address the specific impacts of an energy conservation

standard.

Avail able in the public domain, NEMS produces a widely

- recognized baseline energy forecast for the United States through 2030. T ypical NEMS outputs include forecasts of electricity sales, prices, and electric generating capacity. DOE conducts the utility impact analysis as a scenario that departs from the latest AEO reference case. In other words, the energy savings impacts from amended energy conservation standards are modeled using NEMS

- BT to generate forecasts that deviate from the AEO reference case.

Chapte r 13 of the preliminary TSD provides additional details on the utility impact analysis.

2.15 EMPLOYMENT IMPACT AN ALYSIS

The imposition of standards can affect employment both directly and indirectly. Direct employment impacts are changes in the number of employees at the plants that produce the covered equipment and at affiliated distribution and service companies. DOE evaluates the direct employment impacts in the MIA. Indirect employment impacts may result from expenditures shifting between goods (the su bstitution effect) and changes in income and overall expenditure levels (the income effect). As part of the NOPR stage of this rulemaking, DOE will seek input from interested parties on the potential employment impact, and DOE will investigate the

combined direct and indirect employment impacts in the employment impact analysis using the Pacific Northwest National Laboratory’s “Impact of Sector Energy Technologies” (ImSET)2

- 60 model. The ImSET model was developed for DOE’s Office of Planning, Budget, and Analys is to estimate the employment and income effects of energy

- saving technologies on buildings, industry, and transportation. Compared to simple economic multiplier approaches, ImSET allows

for more complete and automated analysis of the economic impacts of e nergy conservation investments. Details can be found in chapter 14 of the preliminary TSD.

2.16 ENVIRONMENTAL ASSESS MENT

Pursuant to the National Environmental Policy Act of 1969 and the requirements of 42 U.S.C. 6295(o)(2)(B)(i)(VI) and 6316(a), DOE intends to prepare an environmental assessment of the impacts of amended energy conservation standards for metal halide lamp fixtures. The primary environmental effects of these standards would be reduced power plant emissions resulting from reduced consumption of e lectricity. DOE will assess these environmental effects by using NEMS

- BT to provide key inputs to its analysis. The portion of the environmental assessment that will be produced by NEMS

- BT considers carbon dioxide (CO 2 ), nitrogen oxides ( NO

x ), and mercury (Hg). The environmental assessment also considers impacts on SO 2

2.16.1 Carbon Dioxide emissions and discusses particulate matter (PM) emissions. After a brief discussion of general methodology, this section will address each of the relevant emissions. The following section s explain how DOE plans to monetize the benefits associated with emissions reductions.

In the absence of any Federal emissions control regulation of power plant emissions of

CO 2 , a DOE standard is likely to result in reductions of these emiss ions. The CO 2 emission reductions likely to result from a standard will be estimated using NEMS

- BT and national energy savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the difference between emissions estimated by NEMS

- BT at each standard level considered and the

AEO Reference Case. NEMS

- BT tracks CO 2

2.16.2 Sulfur Dioxide emissions using a detailed module that provides results with broad coverage of all sectors and inclusion of interactive effects.

SO 2 emissions from affe cted electric generating units (EGUs) are subject to nationwide and regional emissions cap and trading programs, and DOE has preliminarily determined that these programs create uncertainty about the potential standards’ impact on SO 2 emissions. Title

IV of the Clean Air Act sets an annual emissions cap on SO 2 for affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). SO 2 emissions from 28 eastern states and D.C. are also limited under the Clean Air Interstate Rule (CAIR, 70 Fed. Reg. 25162 (May 12, 2005)), which created an allowance

- based trading program. Although CAIR has been remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), see

North Carolina v. EPA , 550 F.3d 1176 (D.C. Cir. 2008), it remains 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,

which would limit emissions from E GUs in 32 states, potentially through the interstate trading of allowances, among other options. 75 FR 45210 (Aug. 2, 2010).

The attainment of emissions caps is typically flexible among EGUs and is enforced through the use of emissions allowances and tra dable permits. Under existing EPA regulations,2

- 61 and under the Transport Rule if it is finalized, any excess SO 2 emissions allowances resulting from the lower electricity demand caused by the imposition of an efficiency standard could be used to permit offse tting increases in SO 2 emissions by any regulated EGU. However, if the standard resulted in a permanent increase in the quantity of unused emissions allowances, there

would be an overall reduction in SO 2 emissions from the standards. While there remains so me uncertainty about the ultimate effects of efficiency standards on SO 2 emissions covered by the existing cap and trade system, the NEMS

- BT modeling system that DOE uses to forecast emissions reductions currently indicates that no physical reductions in p ower sector emissions

would occur for SO 2

2.16.3 Nitrogen Oxides .

NEMS

- BT also has an algorithm for estimating NO

x emissions from power generation.

As with SO 2 emissions, these emissions will be affected by CAIR and its replacement.

Much like SO 2 emissions, a ca p on NO

x emissions would mean that the energy conservation standards for metal halide lamp fixtures may have little or no physical effect on

these emissions in the 28 eastern states and Washington, D

. C ., which are covered by CAIR

, or any states covered by the proposed Transport Rule. Because all states covered by CAIR opted to

reduce NO

x emissions through participation in cap

- and

- trade programs for EGUs, emissions from these sources are currently capped across the CAIR region.

DOE plans to use NEMS

- BT to estimate the emissions reductions from possible standards in the states where emissions are not capped.

2.16.4 Mercury

Similar to emissions of SO 2 and NO

x , future emissions of Hg would have been subject to emissions caps. In May 2005, E PA issued the Clean Air Mer cury 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. Envi ronmental Protection Agency , in which it vacated CAMR. 517 F.3d 574 (D.C. Cir. 2008). EPA has decided to develop emissions standards for power plants under the Clean Air Act (Section 112), consistent with the D.C. Circuit’s opinion

on CAMR. See http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf . Pending EPA's forthcoming revisions to the rule, DOE is excluding CAMR from its environmental

assessment. In the abs ence of CAMR, a DOE standard would likely reduce Hg emissions and DOE plans to use NEMS

- BT to estimate these emission reductions. However, DOE continues to review the impact of rules that reduce energy consumption on Hg emissions, and may revise its

assess ment of Hg emission reductions in future rulemakings.

2.16.5 Particulate Matter
DOE acknowledges that particulate matter (PM) exposure can impact human health. Power plant emissions can have either direct or indirect impacts on PM. A portion of the pollutants emitted by a power plant are in the form of particulates as they leave the s moke stack. These are direct, or primary, PM emissions. However, the great majority of PM emissions associated with power plants are in the form of secondary sulfates, which are produced at a significant distance from power plants by complex atmospheric ch emical reactions that often2

- 62 involve the gaseous (non

- particulate) emissions of power plants, mainly SO 2 and NO

x . The quantity of the secondary sulfates produced is determined by a very complex set of factors including the atmospheric quantities of SO 2 and NO

x , and other atmospheric constituents and conditions. Because these highly complex chemical reactions produce PM comprised of different constituents from different sources, EPA does not distinguish direct PM emissions from power plants from the secondary sulfate particulates in its ambient air quality requirements, PM monitoring of ambient air quality, or PM emissions inventories. For these reasons, it is not currently possible to determine how the amended standard impacts either direct or indirect PM

emi ssions. Therefore, DOE is not planning to assess the impact of these standards on PM emissions. Further, as described previously, it is uncertain whether efficiency standards will result in a net decrease in power plant emissions of SO 2

2.17 MONETIZING CARBON DI OXIDE AND OTHER EMIS SIONS , which are now lar gely regulated by cap and trade systems.

DOE plans to consider the estimated monetary benefits likely to result from the reduced

emissions of CO 2 and other pollutants that are expected to result from each of the standard levels

considered.

In order to estimate the monetary value of benefits resulting from reduced emissions of

CO 2 , DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed to by an interagency process. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, bu t not limited to, net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of science, economics, and ethics. But with full regard for the limits of both quantification and monetization, the SCC can be used to provide

estimates of the social benefits of reductions in GHG emissions.

At the time of this notice, the most recent interagency estimates of the potential global benefits resulting from reduced CO 2 emissions in 2010, expressed in 2009$, were $4.9, $22.1, $36.3, and $67.1 per metric ton avoided. For emission 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, although DOE will give preference to consideration of the global ben efits of reducing CO 2 emissions. To calculate a present value of the stream of monetary values, DOE will discount the values in each of the four cases using the discount rates that had been used to

obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to

the contribution of CO 2 and other GHG to changes in the future global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.

DOE als o intends to estimate the potential monetary benefit of reduced NO X emissions resulting from the standard levels it considers. For NO

x emissions, available estimates suggest a very wide range of monetary values for NO X emissions, ranging from $447 to $4,59 1 per ton in2

- 63 2009$). r In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE will conduct two calculations of the monetary benefits derived using each of the economic values

used for NO

x , one using a real discount rate of 3 percent and another using a real discount rate of 7 percent. s

DOE does not plan to monetize estimates of Hg in this rulemaking. 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.

2.18 REGULATORY IMPACT AN ALYSIS

In the NOPR stage of this rulemaking, DOE expects to prepare a regulatory impact analysis (RIA) pursuant to Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (October 4, 1993), which is subject to review under the Executive Order by the Office of Information and Regulatory Affairs at t he Office of Management and Budget. The RIA addresses the potential for non

- regulatory approaches to supplant or augment energy conservation standards to improve the energy efficiency or reduce the energy consumption of metal halide lamp fixtures covered u nder this rulemaking.

Voluntary and other non

- regulatory efforts by manufacturers, utilities, and other interested parties can result in substantial improvements to energy efficiency or reductions in energy consumption. DOE intends to consider the likely effects of non

- regulatory initiatives on ballast energy use, consumer utility, and LCCs. DOE will base its assessment on the actual impacts of any such initiatives to date, but also will consider information about the impacts that any existing initiative m ight have in the future.

For more information, refer to the regulatory impact analysis report in the preliminary

TSD.

r F or 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 Entitie s , Washington, DC

. s OMB, Circular A

- 4: Regulatory Analysis ( Sept. 17, 2003).2

- 64 REFERENCES

1. U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics

. Current Industrial Reports, Electric Lamp Fixtures, MA335L. (Last accessed April 26, 2010). http://www.census.gov/mcd/

.

2 . California Energy Commission. 2009 Appliance Efficiency Regulations . CAL. CODE REGS

title 20, § 1605.3(n)(2) (2010)

. http://www.energy.ca.gov/2009publications/CEC

- 400

- 2009

- 013/CEC

- 400

- 2009

- 013.PDF.

3 . U.S. Department of Energy

– Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Products: Technical Support Document: Energy Efficiency Standards for Consumer Products; Fluorescent Lamp Ballast Proposed Rule. January 2000. http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf.