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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 Standby 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 TECHNOLOGY 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 Ballasts...................................... 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 ENGINEERING 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 CHARACTERIZATION ............................. 2-47

2.8 MARKUP ANALYSIS.................................................................................................. 2-48

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .................................. 2-50

2.10 SHIPMENTS ANALYSIS ............................................................................................ 2-51

2.11 NATIONAL IMPACT ANALYSIS.............................................................................. 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............................................................................. 2-56
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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 ANALYSIS................................................................................... 2-59

2.15 EMPLOYMENT IMPACT ANALYSIS....................................................................... 2-59

2.16 ENVIRONMENTAL ASSESSMENT .......................................................................... 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 Mercury.............................................................................................................. 2-61

2.16.5 Particulate Matter............................................................................................... 2-61

2.17 MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS............................. 2-62

2.18 REGULATORY IMPACT ANALYSIS ....................................................................... 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................................................ 2-49
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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 identified 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 ballast efficiency and 

considers them according to four prescribed screening criteria;

• an engineering analysis that determines the manufacturer selling prices (MSPs) 

associated with more energy efficient metal halide lamp fixtures by estimating the 

manufacturing 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 standard;

• 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 and new information received. The 

analyses DOE will perform in the subsequent notice of proposed rulemaking (NOPR) stage 

include the following: 
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• 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 

fixtures and ballast manufacturers and calculates impacts on competition, 

employment at manufacturing plants, and manufacturing capacity;

• a utility impact analysis that estimates the effects of proposed standards on the 

installed capacity and the generating base 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 (CO2), sulfur dioxide (SO2), nitrogen 

oxides (NOX

• a regulatory impact analysis (RIA) that presents 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 December 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, DOE 

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 framework 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 commercial 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 efficiency of several additional kinds of equipment including 

certain metal halide lamp fixtures, which are the focus of this document.

 a The framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/mh_ecs_framework.pdf.
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The following summarizes the pertinent legislative and regulatory history for metal halide 

lamp fixtures. DOE is conducting 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) Design 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 appliance 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 Standard 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 Commission 

(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 lamp” means “a high intensity discharge lamp in which the major portion of the light is produced by 

radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors.” (42 

U.S.C. 6291(63))

d

 “Metal halide lamp fixture” 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))
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determine whether the energy conservation standards established by EISA 2007 for 

metal halide lamp fixtures should be amended. If such amended standards are 

appropriate under the relevant statutory criteria, the final rule shall contain amended 

standards for 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 amendment of the energy 

conservation standards 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 halide 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 pulse-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 lamp 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 operate 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. (42 
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U.S.C. 6295(gg)(3)) Because this energy conservation standards rulemaking must 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 in 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 technologically 

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 standards 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 conduct 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 Concerning 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 

accordance 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 the 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 current 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) DOE recognizes the importance of using the latest accepted 

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

Additionally, 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 may 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 use 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 operating 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 anything 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 overall 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 afforded 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 forgo 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 electronic 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. 

(NEMA, 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 standardized levels. DOE conducted a 

full rulemaking for 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 proposed test procedure and incorporated manufacturers’ comments 

 e DALI stands for the “Digital Addressable Lighting Interface.” It represents a system that enables communication 

between a central lighting controls system and the individual components, including the ballasts.
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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 

electronic ballasts 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 inventory 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. When the forthcoming 2011 version of ANSI C82.6 test method 

becomes available, DOE will evaluate revising the current metal halide lamp ballast test 

procedure.

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 the 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 includes the additional power draw of 

controls in standby mode.

2.2.3 Standby and 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 this energy 

conservation standards rulemaking will 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.

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 defined 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 connected to a main power source and offers one or 

more of the following user-oriented or protective functions: facilitating the activation or 

deactivation of other functions (including active mode) by remote switch (including remote 

control), internal sensor, or timer; or providing continuous functions, including information or 

status displays (including clocks) or sensor-based functions.

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 mode 
2-8

condition does 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 mode 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 this 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 using 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 

consumption 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 for 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 standby mode. One example of this ballast design is a DALIenabled 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 fixtures. 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 whether 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 Solutions, 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 mode. The preliminary 

analysis TSD chapter 3 discusses the power consumption behind lighting controls in more depth.
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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.

6295(hh)(1)(A)) EISA 2007 prescribed energy conservation standards 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 certain 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 statute 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 ballast 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 amended. (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 approachh

2.3.2.1 System Approach

to set minimum energy conservation standards, using an alternative metric for 

metal halide lamp fixture minimum efficiency requirements, and expanding 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, although 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 requirements. 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 ballasts 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 that any one component meet a given standard.
2-10

The American Council for an Energy 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 Partnerships (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 efficiency. 

(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 specialties

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 application-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 commonly 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 established standards. 

Lamp-Ballast System

In a lamp-ballast system approach, metal halide lamp fixtures 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 ensure 

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 required 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 halide lamps. In a system approach, these manufacturers could have a competitive 
2-11

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 interviews 

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 adopting more efficient technology was necessary in order to 

ensure compatibility. Even though some of the higher energy efficiencies are realized by highfrequency electronic ballasts, there are no ANSI standards for these ballasts. Therefore, 

compatibility 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 compatibility 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 prefer 

different lamp manufacturers and do not want to be told which manufacturers’ 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 choose 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 manufacturer 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 from another because of the lack of a specific lamp-ballast system from the preferred 

manufacturer. Additionally, when replacing a lamp, consumers could be limited to only 

purchasing the same lamp from the same manufacturer. This approach could limit consumers 

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 efficiency 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 test 
2-12

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 significant 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 in 

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 manufacturers 

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 lamp 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 that 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-ballast 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 would 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 Transcript, 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 because 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 preliminary determined not to use a lamp-ballast system approach (with or without a table of 

lamps), it invites comment on examples of systems that could benefit from this approach. DOE 

also invites comment on the manufacturer impacts and feasibility of a lamp-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 standards 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 compliance 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 reduced 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 approach, 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, within 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 

halide 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 lamp 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 metrics, such as Target Efficacy Rating (TER) and Fitted Target
2-14

Efficacy (FTE), which are not currently being 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. Additionally, 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 increase 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 inherently 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 application, using the 

desired acrylic diffuser, would have a relatively low fixture efficiency. The same fixture in a 

warehouse using a reflector would efficiently direct light downwards.

Another key issue reported by manufacturers during interviews is testing 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 reported 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 between 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 the 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 FTE and TER metrics may not be sufficiently 

developed at this time, in which case DOE should consider specifying design requirements 
2-15

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

NCLC, No. 15.1 at p. 1) The 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 applying 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 

interviewing manufacturers. DOE found that in general, overall fixture energy use depends on 

four areas of importance, as follows: lamp efficacy, ballast efficiency, light absorption 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. 

Although metal halide lamp fixtures’ minimum performance 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®

program, 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 specific to 

each luminaire; it multiplies the lumens delivered to this pool by the percent coverage of the 

rectangular target and divides 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 presents 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 designed 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 evaluating 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 optical 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 designed to light.

Through using uniformity 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 program and therefore has not 

been accepted 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 program 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 TERi

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

metric, Luminaire Efficacy Rating (LER). TER calculates fixture efficacy by multiplying the 

light leaving the luminaire by a value, also known as the Coefficient 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 fixtures. 

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.org
2-17

• 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 for 

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 and 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, all interviewed fixture 

manufacturers were concerned 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 

based on application rather than product.

TER has 22 different types of luminaire classifications, each with a different TER 

calculation method and value. Classifying fixtures by application is difficult. During the 

framework public meeting and in written comments, 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 

allowing 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 fixtures that can fall within 

multiple classifications. This makes it difficult to determine which minimum performance 

standard to follow and possibly allows 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 Brands 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 classifications, such as outdoor floodlights, 

could 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 with compliance and enforcement of standards. Another important concern 

for the use of TER is that it requires the use of manufacturer published data, specifically the 
2-18

lumen output of the lamp used in the fixture, that is not measured using a DOE published test 

procedure. Therefore, DOE would not have a means to verify the manufacturer data, 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 comments 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 preliminarily 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 continues to evaluate amending energy conservation standards for 

metal 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 significant 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 regulations 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 catalogs (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 potential 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 on energy savings that
2-19

would not warrant additional 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 

wattage 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 during 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 replacing 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 considering 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 not to specify the starting method when setting standards for metal 

halide lamp ballasts rated for lamps of 1000 W or greater. However, not 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 and 

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 considering 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 operation 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 therefore 
2-20

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 

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

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

However, to be able to withstand large variations, the ballast is significantly 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 lamp 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 the 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 must meet all 

of the following 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 operate 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 ballasts 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 by 
2-21

recent NEMA documents. (Georgia Power Company, 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. If 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 

Meeting Transcript, No. 8 at pp. 66–67)

DOE is aware that EISA 2007 and California Title 20 defined the exemption of 150-Wonly fixtures rated for wet location use (as specified by the National Electrical Code 2002, 

section 410.4(A)) and containing a ballast 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, if DOE eliminates the exemption at this time, manufacturers could 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. (OSRAM 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 Transcript, 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 the 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 ballast efficiency 
2-22

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 TECHNOLOGY 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 

fixtures. This information serves as a resource throughout the rulemaking.

DOE reviewed existing literature and spoke with manufacturers to gain an understanding 

of the metal halide lamp fixture and ballast industries 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 industries, 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 framework 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. The market assessment also includes information about manufacturers 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.html
2-23

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

(hereafter “Gardco”), Acuity Brands Lighting (hereafter “Acuity”), Cooper Lighting, Hubbell 

Lighting, Juno Lighting Group (hereafter “Juno”), and Venture Lighting. The lighting divisions 

of several of these companies manufacture other products such as HID ballasts and lamps,

fluorescent lamps, and light-emitting diode (LED) lighting in 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 supplied 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 number 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 includes 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 halide 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, OSRAM 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 companies manufacture 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 supplied by large manufacturers 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 provide 
2-24

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 ballasts, 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 conservation 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; the first of which is the subject of the current rulemaking. 

Prior to the enactment of EISA 2007, the California Energy Commission (CEC) adopted 

regulations for metal halide fixtures that took effect on January 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 halide 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. On 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 

chapter 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 shipments 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 final determination concerning the potential for energy conservation standards for HID 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.html
2-25

DOE used this data for three main purposes. First, the shipment data and market trend 

information contributed to the shipments analysis and base-case forecast for fixtures (chapter 9 

of the preliminary TSD). Second, DOE used the data to select the representative equipment

classes and representative units for analysis (chapter 5 of the preliminary TSD). Third, DOE used 

the data to develop the installed stock of fixtures for the national impact analysis (chapter 10 of 

the preliminary TSD). 

The U.S. Census historical shipment 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 commercial 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 lighting. 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 separate 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–

2008

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 technology has improved and its lower cost has attracted 

consumers. Additionally, LED fixture costs have significantly decreased due to competition in 
2-26

the market along with an increase in consumers’ demand for lower 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 historical shipments and additional information on 

such shipments, see chapter 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 seeks 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 ballasts. 

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 circuit designs. 

NEMA and Philips Lighting Electronics discouraged rulemakings specifying technology 

on the basis of frequency. They noted 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 three-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. However, 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 levels 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 

magnetic 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; Philips 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 housing, 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 management 
2-27

issues and low 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 noted 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 electromagnetic ballasts can withstand well in excess 

of 10 kV transients, electronic ballasts are typically rated for 6 kV transients and would likely 

need additional line transient protection. (Philips Lighting Electronics, Public Meeting 

Transcript, No. 8 at p. 64) NEMA and Cooper Lighting also noted that in addition to the thermal 

factors and redesign of products, added costs 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 

transients and high temperatures than magnetic ballasts do. However, these susceptibilities can 

be mitigated with technology such as transient suppressors 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 with 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 sinks 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 comment 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 conservation 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 in 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 optimization 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 efficiency, 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 consideration, but believed that DOE has an obligation to consider 

approaches beyond ballast efficiency and should therefore expand the list of technology options 
2-28

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

of additional options. CA IOUs mentioned that fixture efficiency might be improved with faceted 

metal domes, inner reflectors, glass-lined domes, and clear ribbed and prismatic reflectors. 

(ACEEE, No. 16.1 at p. 2; CA IOUs, No. 17.2 at p. 8)

As discussed in section 2.3.2, DOE is not considering setting energy conservation 

standards for metal halide lamp fixtures based on fixture efficiency or using a metric that 

incorporates fixture optical designs. DOE understands 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 ballasts included in covered metal halide lamp fixtures. DOE researched 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), including 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 Technology 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 diodes with lower losses.

Capacitors Use capacitors with a lower effective 

series resistance and output capacitance.

Transistors Use transistors with lower drain-tosource 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, nor did they account for a 

potentially expanded scope of energy conservation standards. DOE sought comments on 

prospective class-setting factors, specifically rated lamp wattage and input voltage. DOE 

received several comments on its approach to defining equipment classes.

Wattage
2-30

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 light. 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 of 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 increasing 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 be attributed to the proportion of fixed losses to total 

losses. For low wattage electronic ballasts, fixed losses contribute to a larger proportion of total 

losses than in a high wattage ballast. Magnetic ballasts are essentially transformers (sometimes 

with capacitors for power correction and ignitors for pulse-starting), which are understood to 

have proportionally lower losses with increased wattage. Because wattage can affect both 

consumer utility (light output) and efficiency, DOE has preliminarily decided to establish 

separate equipment classes on the basis of wattage.

EISA 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 

including: (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 equipment classes.

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

and 50–150 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 differences

in efficiency depending on the technology (i.e., electronic or magnetic ballast). In terms of 

shipment volume, manufacturers 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 ensure 
2-31

technological feasibility of all products 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 fixtures are equipped with metal halide lamp ballasts that operate at 

several different input voltages. Voltage affects the power the ballast uses, as well as I2

R losses,l

and therefore affects efficiency. Generally, as voltage increases, current decreases, thereby 

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 types 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 ballast 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 suggested simplifying the equipment classes by distinguishing 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 Transcript, 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 decreasing SKUm

 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/multivoltage ballasts allow for the production of stock fixtures, 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 identifier unique to each product that can be purchased.
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During interviews and further research of the market, DOE learned that the majority of 

available metal halide ballasts have the capability to operate at different voltages or have 

multiple voltage “taps” with different voltages for each tap. As noted above by interested parties, 

the multi-taps and multiple voltages benefit consumers and manufacturers by decreasing SKU 

count, allowing the 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. 

To 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 efficiencies. 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 input voltage at which a multiple input voltage ballast should be 

tested, DOE plans to propose an amendment 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. Instead, 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 accurately 

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 per 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 equipment classes by 
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the number of lamps that a ballast operates. DOE seeks 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 starting 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 pulsestart due 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 developed 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 

fixtures 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 ballasts. (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 initial 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 violation 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 standards to a 

more stringent level relative to EISA. DOE is considering whether a design standard 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 copper 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 review of manufacturer catalogs shows that at higher wattages, few electronic 
2-34

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 ballasts, 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 separating 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 capture 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, DOE 

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) ballasts. 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. electronic) 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 these “industrial, scientific, and medical (ISM) equipment” 

standards, which list the general operating conditions for ISM equipment. Ballasts designed to exceed 9 kHz ballast 

frequency have to be designed so that interference with transmitted radio frequencies is eliminated. 47 CFR 18.111. 
2-35

In response to the framework document, some interested parties indicated preference in 

further dividing metal halide lamp fixture equipment 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 product 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 compatibility. (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 ballasts. (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, DOE 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 halide 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. This class-setting factor 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 that DOE considered can be found in chapter 3 of 

this preliminary TSD.
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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 following set 

of screening criteria to determine which design options are unsuitable for further consideration in 

the rulemaking 10 CFR part 430, subpart C, appendix A at 4(a)(4) and 5(b):

• Technological Feasibility: DOE will consider only those technologies incorporated 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 

technology 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 Equipment Availability: DOE will not 

further consider a technology if 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 result 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 if 

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 technology 
2-37

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 agreements 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 Federal government emphasis on domestic materials makes it more challenging to 

meet domestic material, production, and procurement requirements. (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 feasibility; 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 of 

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 available 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 technologies 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 considered 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, reliability, 

health, or safety associated with the design options identified. For a complete discussion of the 

screening analysis, refer to chapter 4 of the preliminary TSD. DOE requests comment on 

whether interested parties agree that amorphous steel and electrical components more efficient

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 efficiency 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 relationship between the MPC and energy efficiency serves as the basis of the cost-benefit 

calculations for individual consumers, manufacturers, and the nation. This section provides an 

overview of the engineering analysis, discusses the representative equipment classes, 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. 
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The primary output of the engineering 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 distribution 

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 wattage 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 within 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 three 

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 efficiency 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) derived 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 product 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 teardowns 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 Classes, Ballasts, and Fixtures: 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 equipment classes primarily because of their high market 

volumes. For the metal halide lamp fixture rulemaking, DOE analyzed all equipment classes. 
2-39

Baseline Models

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

ballasts included in covered metal halide lamp fixtures, and tested them at an accredited testing 

laboratory for ballast efficiency. All test 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 method (pulse- and probe-start), and circuit design to characterize the most common 

ballast contained in covered metal halide fixtures.

: DOE establishes baseline models for 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 level 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 the 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 

values 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 catalogs as ballast 

efficiency.

Candidate Model Designs: 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 distinguishing 

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 considering 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 comments 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 equipment 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 of the 

circuit design.
2-40

class, DOE considered both high reactance autotransformer and CWA magnetic ballasts as 

representative.

Candidate Standard Levels. After identifying the more efficient substitutes for each 

baseline model, DOE develops candidate standard levels (CSLs). DOE based 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 efficiency 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 research fields that 

support the market. DOE believes that within a given equipment class, no working equipment or 

prototypes exist that have 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 Analysis

2.6.2

. After identifying both the baseline model and the 

more efficient substitutes at each CSL, DOE generated a BOM by disassembling multiple 

manufacturers’ ballasts and fixtures that span a range of efficiency levels for each 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 developed a cost model 

that converted the BOMs into MPCs. By applying derived manufacturer 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 halide 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 addition 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 equipment. The full cost of production is broken 

down into two main costs, the full production cost or manufacturing production cost and the nonproduction cost. The non-production cost is equal to the manufacturer markup minus profits. 

DOE totaled the cost of materials, 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 ballasts, direct material costs represent 

the purchase price of steel laminations, 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 circuit 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 metal 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 Table 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 

wattage 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 

preliminary TSD provides more detail on the development of representative empty fixture MSPs.

As mentioned in section 2.6.1, DOE was able to select only unpotted electronic 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, to estimate MPCs for 

representative units that were not directly submitted for teardowns, DOE used several estimating 

techniques. In some cases, DOE marked down a distributor 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 multi-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 appropriate 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 design standards, in addition to performance standards, for metal halide 

lamp fixtures. 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 that 

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 energy 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-start ballasts of reduced wattage. In new construction, 
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 requirement 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 

specific, characteristic differences in lumen maintenance and efficacy across probe- and pulsestart 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 differences 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 

created a separate engineering analysis that established standards for each class. For each 

equipment class, 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 positive 

feedback on its selection of representative wattages during interviews with manufacturers. Table 

2.4 summarizes the equipment classes and their corresponding representative 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, these 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 whether 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 

capable 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 consideration 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 testing, 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 fixtures. Many manufacturers of electronic metal halide lamp ballasts 

also 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 solved 

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 currently on the market. 

Based on DOE’s conclusions that magnetic fixtures can accommodate the space 

constraints and thermal requirements of electronic ballasts, DOE did not apply empty fixture 

incremental costs. The empty fixture MPC for a representative wattage 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 Baseline 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 standards. 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 ballasts’ 

characteristics in choosing the most appropriate baseline for each equipment class. These 

characteristics include the ballast’s input voltage (dedicated, multi-tap, or universalq

 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. 
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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 these ballast efficiency values

and equipment. 

As an example, the following discussion outlines DOE’s choice of baseline models and 

CSLs for the ≥500 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 

interviews 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 probe-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 selected 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 partly 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 premature failure of electrical components and ultimately the ballast itself. DOE 

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 distinguishably 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 DOE 
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determined for this preliminary rulemaking. DOE 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.

CSL1. 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 changed from 

aluminum to copper.

CSL2. Efficiency: 93.3 percent

CSL2 represents the maximum technologically feasible level for the 1000 W representative 

wattage. CSL2 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 classes 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 not 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 input power in its analysis.
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Table 2.6 1000 W Representative Wattage Engineering Summary Candidate Standard Level Ballast Efficiency Normalized Input Power Ballast Manufacturer Production Cost ($) Empty Fixture Manufacturer Production Cost ($) Fixture Manufacturer 

Selling Price ($)

Baseline 91.9% 1088.1 40.02 132.77 254.00

CSL1 92.6% 1079.9 46.26 132.77 263.18

CSL2 93.3% 1071.8 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 Lamp 

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 frequency 

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 CHARACTERIZATION

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 and 
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the NIA. To develop annual energy use estimates, DOE multiplied annual usage (in hours per 

year) by the system input power (in watts). 

Metal 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 sector, 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 Power 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 interior and exterior 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 occupancy-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 reduced 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 

interested 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 occupancybased 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 this 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 Distribution 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 company’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 consistent 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 contracts that, with high-volume purchases, might allow for discounted 

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

that actual end-user 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 SYSTEM
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2.9 LIFE-CYCLE COST AND PAYBACK 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 engineering 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 maintenance 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 purchasing events when 

consumers can be affected by an amended energy 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 their 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 renovation. 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 projections 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 comments 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 Carolinas, 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 preliminary 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 nation. 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 establish 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 from 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 the 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. Consequently, 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 historical 

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 growth rate, replacement rate, and emerging 

technology (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. (Progress 

Energy Carolinas, No. 14.1 at p. 3) NEEP and CA IOUs provided summaries of metal haliderelated 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 magnitude 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.
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2.11 NATIONAL IMPACT ANALYSIS 

The national impact analysis assesses the net present value of total end-user LCC and 

NES. DOE determined both 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, the 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 conduct 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 consumption 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, 

which 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) present 

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 with a discount factor.

DOE calculated increases in total installed costs as the product of the difference in the 

total installed cost between the base case and standards case, and the annual shipments in the 

standards case. Because purchase costs of the higher-efficiency equipment in the standards case 

are generally greater than the purchase costs of equipment in the base case, price increases 

appear as negative values in the NPV. DOE expressed operating cost savings as decreases in 

operating costs associated with the lower energy consumption of equipment in the standards case 
2-53

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 case 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 affected 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 standard 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 incrementally 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 provides 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 standards 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 

following 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 example, 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-andoperated systems be considered as an LCC subgroup. (Georgia 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.
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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 impacts 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 

during 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 manufacturers. DOE also tested equipment from both major and smaller 

manufacturers.

NEMA 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, No. 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 understands that new energy conservation 
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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 incandescent 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 and 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 noted 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 

commented 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, No. 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 companies 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 regulatory burden affecting manufacturers of metal halide lamp fixtures. 

2.13.1 Sources of Information for the Manufacturer Impact Analysis

These analyses provide important information applicable to the MIA. Such information 

includes manufacturing costs and prices 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 role 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 

interviews, 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 chapter 12 of the preliminary TSD for more detail on the methodology used in 

the MIA.
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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 compares the results against base 

case projections that involve no amended energy conservation standards. The financial impact of 

amended energy conservation standards is the difference 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 chapter 12 of the preliminary TSD for more information on the 

industry cash-flow analysis.

2.13.3 Manufacturer 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 models. 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, because 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 environments, 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 fixture 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 chapter 12 of the 

preliminary TSD for more detail on the manufacturer subgroup analysis.

2.13.4 Competitive 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 analysis 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 would 
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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 the 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 Regulatory 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 Federal 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, in response, DOE’s initial analysis of regulations affecting metal 

halide fixtures and ballasts is located in the market and technology assessment (chapter 3 of the 

preliminary TSD). During the NOPR, DOE plans to investigate the regulations that 

manufacturers 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 metrics 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 applications 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 

lamp 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.
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2.13.6.2 Absence of Electronic Ballast ANSI Standards

Some manufacturers worried about setting efficiency standards for electronic ballasts 

when ANSI currently has no standards for such high-frequency 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, expensive 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 are major problems with labeling and enforcement.

Manufacturers 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 

lamp 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 to 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 manufacturers commented that amended energy conservation standards would 

force them to invest in more expensive and energy efficient components, improve existing 

product lines, and design new product lines. The majority of these product conversion costs 

would be attributed to engineering and testing, plant equipment, finer grade materials, production 

personnel and sales force retraining, and consumer education. Those manufacturers that expected 
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significant product conversion costs commented that the large investments would ultimately 

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 comply 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 ANALYSIS

The utility impact analysis includes an analysis of the effect of amended energy 

conservation standards on the electric and gas utility industries. For this analysis, DOE will use a 

variant of the National Energy Modeling System (NEMS), a large multi-sectoral, partialequilibrium model of the U.S. energy sector that the EIA has developed throughout the past 

decade, primarily for preparing 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.

Available in the public domain, NEMS produces a widely-recognized baseline energy 

forecast for the United States through 2030. Typical 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.

Chapter 13 of the preliminary TSD provides additional details on the utility impact 

analysis.

2.15 EMPLOYMENT IMPACT ANALYSIS

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 substitution 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) 
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model. The ImSET model was developed for DOE’s Office of Planning, Budget, and Analysis 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 energy conservation 

investments. Details can be found in chapter 14 of the preliminary TSD.

2.16 ENVIRONMENTAL ASSESSMENT

Pursuant to the National Environmental Policy Act of 1969 and the requirements of 42 

U.S.C. 6295(o)(2)(B)(i)(VI) 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 electricity. 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 (CO2), nitrogen oxides 

(NOx), and mercury (Hg). The environmental assessment also considers impacts on SO2

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 sections

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 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 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 CO2

2.16.2 Sulfur Dioxide

emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects.

SO2 emissions from affected 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 SO2 emissions. Title 

IV of the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in the 48 

contiguous states and the District of Columbia (D.C.). SO2 emissions from 28 eastern states and 

D.C. 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 EGUs 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 tradable permits. Under existing EPA regulations, 
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and under the Transport Rule if it is finalized, any excess SO2 emissions allowances resulting 

from the lower electricity demand caused by the imposition of an efficiency standard could be 

used to permit offsetting increases in SO2 emissions by any regulated EGU. However, if the 

standard resulted in a permanent increase in the quantity of unused emissions allowances, there 

would be an overall reduction in SO2 emissions from the standards. While there remains some 

uncertainty about the ultimate effects of efficiency standards on SO2 emissions covered by the 

existing cap and trade system, the NEMS-BT modeling system that DOE uses to forecast 

emissions reductions currently indicates that no physical reductions in power sector emissions 

would occur for SO2

2.16.3 Nitrogen Oxides

.

NEMS-BT also has an algorithm for estimating NOx emissions from power generation. 

As with SO2 emissions, these emissions will be affected by CAIR and its replacement.

Much like SO2 emissions, a cap on NOx 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 NOx 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 SO2 and NOx, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all states by 2010. However, on February 8, 2008, the D.C. 

Circuit issued a decision in New Jersey v. Environmental Protection Agency, 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 absence 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 

assessment 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 smoke 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 chemical reactions that often 
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involve the gaseous (non-particulate) emissions of power plants, mainly SO2 and NOx. The 

quantity of the secondary sulfates produced is determined by a very complex set of factors 

including the atmospheric quantities of SO2 and NOx, 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 

emissions. 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 SO2

2.17 MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS 

, which are now largely regulated by cap 

and trade systems.

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 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 

CO2, 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, but 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 CO2 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 benefits of 

reducing CO2 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 CO2 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 also intends to estimate the potential monetary benefit of reduced NOX emissions 

resulting from the standard levels it considers. For NOx emissions, available estimates suggest a 

very wide range of monetary values for NOX emissions, ranging from $447 to $4,591 per ton in 
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2009$).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 NOx, 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 ANALYSIS

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 the 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 under 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 might have in the future. 

For more information, refer to the regulatory impact analysis report in the preliminary 

TSD.

 r For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on 

State, Local, and Tribal Entities, Washington, DC. s OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
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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.