2-i 

CHAPTER 2. ANALYTICAL FRAMEWORK 

TABLE OF CONTENTS 

2.1 INTRODUCTION ........................................................................................................... 2-1

2.2 BACKGROUND ............................................................................................................. 2-4

2.2.1 Rulemaking History for High-Intensity Discharge Lamps and Regulatory 

Authority .......................................................................................................................... 2-4

2.2.2 Test Procedures .................................................................................................... 2-5

2.2.3 Standby and Off Mode Energy Consumption ...................................................... 2-5

2.3 SCOPE ............................................................................................................................. 2-6

2.3.1 Definitions............................................................................................................ 2-6

2.3.2 Specific Lamp Categories under Consideration .................................................. 2-7

2.3.2.1 Wattage .................................................................................................... 2-7

2.3.2.2 Correlated Color Temperature ................................................................. 2-8

2.3.2.3 Directional Lamps .................................................................................... 2-9

2.3.2.4 Self-Ballasted Lamps ............................................................................... 2-9

2.3.2.5 Lamps Operated on Electronic Ballasts Only ........................................ 2-10

2.3.2.6 High-CRI Lamps .................................................................................... 2-11

2.3.2.7 Colored MH Lamps ............................................................................... 2-12

2.3.2.8 MV Lamps for Specialty Applications .................................................. 2-12

2.3.2.9 Electrodeless HID Lamps ...................................................................... 2-12

2.3.3 Summary ............................................................................................................ 2-13

2.4 METRIC ........................................................................................................................ 2-14

2.5 MARKET AND TECHNOLOGY ASSESSMENT ...................................................... 2-14

2.5.1 Market Assessment ............................................................................................ 2-15

2.5.1.1 Manufacturers of High-Intensity Discharge Lamps .............................. 2-15

2.5.1.2 Regulatory and Non-Regulatory Programs ............................................ 2-16

2.5.1.3 High-Intensity Discharge Lamp Shipments ........................................... 2-16

2.5.2 Technology Assessment..................................................................................... 2-17

2.5.2.1 Mercury Vapor Lamps ........................................................................... 2-18

2.5.2.2 High-Pressure Sodium Lamps ............................................................... 2-18

2.5.2.3 Metal Halide Lamps ............................................................................... 2-18

2.5.3 Equipment Classes ............................................................................................. 2-19

2.5.3.1 Correlated Color Temperature ............................................................... 2-20

2.5.3.2 Wattage .................................................................................................. 2-20

2.5.3.3 Bulb Finish ............................................................................................. 2-22

2.5.3.4 Luminaire Characteristic ........................................................................ 2-23

2.5.3.5 Summary ................................................................................................ 2-24

2.6 SCREENING ANALYSIS ............................................................................................ 2-25

2.7 ENGINEERING ANALYSIS ........................................................................................ 2-26

2.7.1 Interim Engineering Analysis Approach ........................................................... 2-27

2.7.1.1 Representative Equipment Classes ........................................................ 2-28

2.7.2 Baseline Lamps .................................................................................................. 2-29

2.7.3 More Efficacious Substitutes ............................................................................. 2-30

2.7.4 Candidate Standard Levels ................................................................................ 2-31

2.7.4.1 Reporting Requirements ........................................................................ 2-32
2-ii

2.7.5 HID Lamp System ............................................................................................. 2-33

2.7.6 Scaling Between Equipment Classes ................................................................. 2-33

2.8 EQUIPMENT PRICE DETERMINATION .................................................................. 2-34

2.8.1 HID Lamps......................................................................................................... 2-34

2.8.2 HID Ballasts and Fixtures .................................................................................. 2-35

2.9 MARKUPS ANALYSIS ............................................................................................... 2-35

2.10 ENERGY USE ANALYSIS .......................................................................................... 2-36

2.11 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ................................... 2-36

2.12 SHIPMENTS ANALYSIS ............................................................................................ 2-37

2.13 NATIONAL IMPACT ANALYSIS .............................................................................. 2-37

2.13.1 National Energy Savings Analysis..................................................................... 2-37

2.13.2 Net Present Value Analysis ............................................................................... 2-37

2.14 CUSTOMER SUBGROUP ANALYSIS ....................................................................... 2-38

2.15 MANUFACTURER IMPACT ANALYSIS.................................................................. 2-38

2.15.1 Sources of Information for the Manufacturer Impact Analysis ......................... 2-39

2.15.2 Industry Cash-Flow Analysis ............................................................................. 2-39

2.15.3 Direct Employment Impact Analysis ................................................................. 2-40

2.15.4 Manufacturer Subgroup Analysis ...................................................................... 2-40

2.15.5 Competitive Impacts Assessment ...................................................................... 2-40

2.15.6 Cumulative Regulatory Burden ......................................................................... 2-41

2.15.7 Interim Results for the Manufacturer Impact Analysis...................................... 2-41

2.15.7.1 Energy Savings from Replacement HID Lamps ............................... 2-41

2.15.7.2 Testing Burden .................................................................................. 2-41

2.15.7.3 Technology Shift ............................................................................... 2-41

2.15.7.4 Product Innovation ............................................................................ 2-42

2.16 EMPLOYMENT IMPACT ANALYSIS ....................................................................... 2-42

2.17 UTILITY IMPACT ANALYSIS ................................................................................... 2-42

2.18 EMISSIONS ANALYSIS .............................................................................................. 2-43

2.19 MONETIZATION OF EMISSION REDUCTION BENEFITS ................................... 2-45

2.20 REGULATORY IMPACT ANALYSIS ....................................................................... 2-46

LIST OF FIGURES 

Figure 2.1.1 Flow Diagram of Analyses for the High-Intensity Discharge Lamp Rulemaking 

Process ................................................................................................................. 2-2

LIST OF TABLES 

Table 2.5.1 Historical Shipments of HID Lamps from 1990-2010 ........................................... 2-17

Table 2.5.2 Equipment Classes Based on CCT ......................................................................... 2-20

Table 2.5.3 Equipment Classes Based on Wattage .................................................................... 2-22

Table 2.5.4 Equipment Classes Based on Bulb Finish .............................................................. 2-23

Table 2.5.5 HID Lamps Interim Analysis Equipment Classes .................................................. 2-25

Table 2.7.1 Representative and Scaled Equipment Classes for HID Lamps ............................. 2-29

Table 2.7.2 Representative Lamp Types.................................................................................... 2-30
2-iii

Table 2.7.3 Representative Equipment Class Candidate Standard Levels ................................ 2-32
2-1 

CHAPTER 2. ANALYTICAL FRAMEWORK 

2.1 INTRODUCTION 

This chapter describes the analytical framework that the U.S. Department of Energy 

(DOE) is using to develop energy conservation standards for high-intensity discharge (HID) 

lamps, including a description of the methodology, the analytical tools, and relationships among 

the various analyses that are part of this rulemaking. Chapter 2 provides an overview of the 

preliminary activities DOE conducted and additional detail on key issues identified in the 

executive summary. Finally, chapter 2 provides citations and cross-references to the other 

chapters of the interim technical support document (TSD) that address DOE’s analytical 

approach, inputs, and findings. 

Figure 2.1.1 summarizes the analytical components of the standards-setting process. The 

central parts of this figure are the analyses contained in the boxes. The key inputs to the left and 

key outputs to the right show how the analyses fit into the rulemaking process, and how the 

analyses relate to each other. Key inputs are the types of data and information that the analyses 

require. Key outputs are analytical results that feed directly into the standards-setting process. 

Dotted lines connecting analyses show types of information that feed from one analysis to 

another. Although Figure 2.1.1 summarizes the inputs, outputs, and analyses of a standards 

rulemaking, individual inputs and outputs may vary for this rulemaking. 
2-2 

Figure 2.1.1 Flow Diagram of Analyses for the High-Intensity Discharge Lamp Rulemaking 

Process 

The analyses performed in the interim analysis stage and reported in this TSD include: 
2-3 

 A market and technology assessment to characterize the HID lamp market, identify 

technology options that improve efficacy, and develop equipment classes 

 A screening analysis to review each technology option and determine if it is 

technologically feasible; practicable to manufacture, install, and service; would 

adversely affect lamp utility or availability; or would have adverse impacts on health 

and safety 

 An engineering analysis to study representative lamp and lamp-and-ballast systems 

used as substitutes for baseline lamps, to select candidate standard levels (CSLs), and 

to determine lamp-and-ballast system power ratings 

 An equipment price determination to determine end-user equipment prices for 

representative HID lamps and manufacturer selling prices their associated ballasts and 

fixtures 

 A markup analysis to evaluate distribution channels to develop end-user equipment 

prices of ballasts and fixtures for the life-cycle cost (LCC) analysis and national 

impact analysis (NIA); the markup analysis also relates lamp end-user prices to the 

manufacturer selling prices (MSPs) used in the manufacturer impact analysis (MIA). 

 An energy use analysis to determine the energy usage of the HID lamps considered in 

this rulemaking 

 An LCC analysis that calculates, at the customer level, the discounted savings in 

operating costs throughout the estimated average life of the HID lamps considered in 

this rulemaking, 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 customers to 

recover the higher purchase expense of more efficacious lamps through lower 

operating costs 

 A shipments analysis to estimate yearly shipments of covered HID lamps over the 

analysis period 

 An NIA that assesses the aggregate impacts at the national level of potential energy 

conservation standards as measured by the net present value (NPV) of total customer 

economic impacts and national energy savings (NES) 

 An interim MIA that begins to evaluate the impacts on manufacturers that may result 

from a new efficacy standard 
2-4 

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 those listed below: 

 A customer subgroup analysis that evaluates the economic impacts on identifiable 

groups of customers of HID lamps, including various categories of purchasers or 

owners who may experience disproportionate impacts from a national energy 

conservation standard 

 An MIA that estimates the financial impact of standards on HID lamp manufacturers 

and calculates impacts on competition, employment at the manufacturing plant, and 

manufacturing capacity 

 An employment impact analysis that estimates the impacts of standards on net jobs 

eliminated or created in the general economy due to increased spending on HID 

lamps and reduced customer spending on energy 

 A utility impact analysis that estimates the effects of standard levels on the installed 

capacity and the generating base of electric utilities 

 An emissions analysis to provide estimates of the effects of energy conservation 

standards on emissions of carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides 

(NOX), and mercury (Hg) 

 A monetization of reduction of emission benefits from the proposed standard levels 

 A regulatory impact analysis (RIA) that presents major alternatives to proposed 

standards that may achieve comparable energy savings at a reasonable cost 

In response to comments it receives on this interim analysis and the NOPR that will 

follow, DOE may revise some of its analyses before publishing the final rule. 

2.2 BACKGROUND 

2.2.1 Rulemaking History for High-Intensity Discharge Lamps and Regulatory Authority 

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA), (42 U.S.C. 

6291–6317), as amended, established the Energy Conservation Program for Consumer Products 

Other than Automobiles. Part C established the Energy Conservation Program for Certain 

Industrial Equipment.1 Although HID lamps are defined under Part B, the requirement for DOE 

to consider standards for HID lamps is set forth in Part C. As a result, DOE has determined that 

the provisions of Part C apply to HID lamps. 

 

1

 For editorial reasons, upon codification in the U.S. Code, Parts B and C were re-designated Parts A and A-1, 

respectively. 
2-5 

EPCA requires DOE to prescribe testing requirements for those HID lamps for which 

DOE makes a determination that energy conservation standards would be technologically 

feasible and economically justified, and would result in significant energy savings. (42 U.S.C. 

6317(a)(1)) EPCA further requires DOE, within 18 months of prescribing any testing 

requirements for HID lamps, to prescribe energy conservation standards for those lamps. (42 

U.S.C. 6317(a)(2)) Any standards would apply to lamps manufactured 36 months after the date 

the standards rule is published. (42 U.S.C. 6317(a)(3)) 

DOE published a positive final determination2on July 1, 2010, that standards for certain 

HID lamps are technologically feasible, economically justified, and would result in a significant 

energy savings. 75 FR 37975. As a result of this positive determination, DOE is currently 

conducting a test procedure (TP) rulemaking for HID lamps. In addition, DOE published a 

framework document on February 28, 2012, (77 FR 18963) and held a public meeting to discuss 

the framework document on March 29, 2012. 

2.2.2 Test Procedures 

EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and 

amendment of test procedures. (42 U.S.C. 6314) Manufacturers of covered equipment must use 

these test procedures to certify to the DOE that their equipment complies with EPCA energy 

conservation standards and to quantify the efficiency of their equipment. Also, these test 

procedures must be used whenever testing is required in an enforcement action to determine 

whether covered equipment complies with EPCA standards. 

On December 15, 2011, DOE published a NOPR in which it proposed test procedures for 

HID lamps. 76 FR 77914. DOE addressed the TP NOPR at a public meeting on January 19, 

2012. Comments received in response to the TP NOPR and a transcript of the public meeting are 

available at www.regulations.gov. DOE received comments from interested parties suggesting 

that the DOE HID lamps test procedures should be harmonized with similar, relevant 

international standards and test procedures, and that DOE should pursue using test data already 

collected in accordance with international requirements. DOE also received comments on its 

proposals to measure lamp color characteristics, lumen maintenance, and directional lamp 

characteristics. Other comments received focused on the proposed sampling plan, laboratory 

accreditation requirements, and the instrumentation requirements for test apparatuses. 

Based on comments received on the TP NOPR and subsequent additional research, DOE 

is considering a supplemental notice of proposed rulemaking regarding potential revisions to and 

clarification of the proposed HID lamp test procedures. 

2.2.3 Standby and Off Mode Energy Consumption 

DOE conducted an analysis of the potential for energy savings associated with the 

regulation of standby mode and off mode energy use in HID lamps. Similar to DOE’s conclusion 

in the July 2009 general service fluorescent lamp, general service incandescent lamp, and 

incandescent reflector lamp (GSFL/IRL) final rule (74 FR 34080, 34094 (July 14, 2009)), DOE 

 

2

 The 2010 HID lamp final determination is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23 
2-6 

preliminarily determined that HID lamps that are subject of this rulemaking do not operate in 

standby mode or off mode. 

EPCA defines active mode 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. (42 U.S.C. 6295)(gg)(1)(A)) Off mode is defined as the condition in which an energyusing piece of equipment is connected to a main power source, and is not providing any standby 

or active mode function. Id. 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. Id.

To satisfy the EPCA definitions of standby mode and off mode (42 U.S.C. 6295(gg)(1)), 

the lamp must not be providing any active mode function (i.e., emitting light). However, to reach 

such a state, the lamp must be entirely disconnected from the main power source (i.e., switched 

off), thereby not satisfying the requirements of operating in off mode. In addition, DOE believes 

that all covered equipment that meets the definition of HID lamp are single-function products 

and do not offer any secondary user-oriented or protective functions or continuous standby mode 

functions. Thus, HID lamps do not satisfy the EPCA definition of standby mode. Although 

EPCA allows DOE to amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes 

that the energy use of HID lamps is accounted for entirely in the active mode. Therefore, DOE is 

not considering addressing lamp operation in the standby and off modes in this rulemaking. 

2.3 SCOPE 

This section puts forth the statutory definitions that define the scope of this rulemaking 

and conducts a closer review of specific lamp types to determine the HID lamp types for which 

DOE will consider energy conservation standards in this rulemaking. DOE considered each of 

these specific lamp categories according to the criteria prescribed by EPCAenergy savings 

potential, technological feasibility, and economic justification. (42 U.S.C. 6295(o)(2)(A)) 

DOE assessed a lamp category’s potential for energy savings using lamp catalog data as a 

proxy for market share, which was then reevaluated in light of feedback obtained during 

manufacturer interviews. For HID lamp availability, DOE obtained quantitative information 

from lamp catalogs of 14 different manufacturers. DOE also conducted evaluations of 

technological feasibility and economic justification. 

2.3.1 Definitions 

High-intensity discharge is the generic name for a family of lamps including mercury 

vapor (MV), metal halide (MH), and high-pressure sodium (HPS) lamps. Although low-pressure 

sodium (LPS) lamps are often included in the family, they are not included in the definition set 

forth in EPCA and are therefore not considered in this rulemaking. The definitions of HID lamp, 

MV lamp, and MH lamp (i.e., the covered lamps for which DOE is considering standards in this 

rulemaking) set forth in EPCA are as follows: 
2-7 

High intensity discharge lamp means an electric-discharge lamp in which – 

1. the light-producing arc is stabilized by the arc tube wall temperature; and 

2. the arc tube wall loading is in excess of 3 watts/cm2

High intensity discharge lamps include mercury vapor, metal halide, and high-pressure 

sodium lamps. (42 U.S.C. 6291(46)) 

Mercury vapor lamp means a high-intensity discharge lamp, including clear, phosphorcoated, and self-ballasted screw base lamps, in which the major portion of the light is produced 

by radiation from mercury typically operating at a partial vapor pressure in excess of 100,000 Pa 

(approximately 1 atm). (42 U.S.C. 6291(47)) 

Metal halide lamp is 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)) 

HPS lamps are not defined in EPCA. DOE proposed a definition for these lamps in the 

HID lamps test procedure NOPR issued on December 15, 2011.3 In this interim analysis, DOE is 

considering using the following definition for HPS lamp: 

High-pressure sodium lamp is a high-intensity discharge lamp in which the major portion 

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

6,670 pascals (approximately 0.066 atmospheres or 50 Torr) or greater.4(76 FR 77914, 77317,

Dec. 15, 2011) 

2.3.2 Specific Lamp Categories under Consideration 

HID lamps can differ from each other due to a variety of characteristics that affect 

performance, such as input wattage, directionality, ballast location, ballast type, color of emitted 

light, and others. The following subsections provide a discussion of these features and describe 

the lamps for which DOE is considering energy conservation standards in this rulemaking. 

2.3.2.1 Wattage 

In examining manufacturer catalogs, DOE found that HID lamps span wattages from 15 

watts (W) to 18,000 W, though these wattages varied according to lamp technology. Rated 

wattages range from 15 W to 18,000 W for MH lamps, from 35 W to 1000 W for HPS lamps, 

and from 40 W to 2000 W for MV lamps. DOE is considering standards for a subset of the 

available wattages, as explained in the following paragraphs. 

For MH lamps, DOE is considering standards for lamps with rated wattages ≥50 W and 

≤2000 W. Based on entries in manufacturer catalogs, less than nine percent of MH lamps 

available have rated wattages less than 50 W. Similarly, DOE found less than three percent of 

 

3

 The HID lamp test procedure NOPR is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/21 

4

 Atm, Pa, and Torr are all units of pressure. atm is the abbreviation for atmosphere. Pa is the abbreviation for 

pascal. 760 Torr = 1 atm. 1 Torr = 133 pa. 
2-8 

MH lamps to have rated wattages that exceed 2000 W. The small number of HID lamp offerings 

at low wattages does not suggest significant potential energy savings. Similarly at high wattages, 

the small number of available lamp models combined with their low operating hours, provides

limited energy savings potential. Conversely, between 50 W and 2000 W, as described in section 

2.7.3, DOE has identified a range of efficacies and design options available for MH lamps, 

indicating technological feasibility for standards. DOE also preliminarily determined that 

standards could be economically justified. For these reasons, DOE is considering energy 

conservation standards for MH lamps with rated wattages ≥50 W and ≤2000 W. This is 

consistent with the preliminary approach in the energy conservation standards rulemaking for 

metal halide lamp fixtures (MHLFs).5

For HPS and MV lamps, DOE is considering standards for lamps with rated wattages ≥50 

W and ≤1000 W. In its review of HPS and MV lamp catalogs, DOE found that less than five 

percent of the HPS catalog offerings and less than one percent of the MV catalog offerings had 

rated wattages less than 50 W. Similarly, DOE found only two MV lamps and no HPS lamps 

with rated wattages higher than 1000 W. Given the small number of available products, DOE 

believes these lamps do not reflect significant potential energy savings. Therefore, DOE is 

considering standards for only those HPS and MV lamps with rated wattages ≥50 W and ≤1000 

W. HID lamps in the wattage ranges included in the analysis, named above, have demonstrated 

the potential for significant energy savings. These lamps also have a range of efficacies and 

design options, which suggest technological feasibility, and DOE preliminarily determined that

standards could be economically justified. 

2.3.2.2 Correlated Color Temperature 

Another defining characteristic of an HID lamp is the correlated color temperature 

(CCT). In general terms, the CCT is an approximation of the appearance of the light source 

expressed in kelvins (K) where lower values are considered warm white light and high values are 

considered cool white light. In the test procedure NOPR, DOE proposed to define CCT as the 

absolute temperature of a blackbody whose chromaticity most nearly resembles that of the light 

source. (42 U.S.C. 6291(30)(K)); (76 FR 77914,77930, Dec. 15, 2011).

HID lamps are available with a variety of CCTs, depending on lamp type and design. For 

example, HPS lamps range in CCT from 1900 K to 2700 K, and MV lamps range in CCT from 

3200 K to 6800 K. In reviewing HID lamp catalogs, however, DOE found a much larger range 

for MH lamps, with products ranging in CCT from 2800 K to 50,000 K.6

DOE found that lamps with higher CCTs tend to be advertised for a specific, specialized 

application. For example, DOE found that all MH lamps with a CCT between 10,000 K and 

50,000 K were advertised as aquarium lamps, and MH lamps with a CCT between 7200 K and 

9000 K were advertised as stage and studio lighting. In addition, DOE identified lamps with a 

CCT of 7000 K to be horticulture lamps. 

 

5

 The metal halide lamp fixture preliminary TSD is available at: 

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

6

 Some directional lamps are available with CCT as low as 2500 K. 
2-9 

Overall, lamps with a CCT greater than or equal to 7000 K represent about two percent of 

all available MH lamp models, based on catalog availability. Given the small number of 

available products and their specialized applications, DOE does not believe these lamps 

represent significant potential energy savings. Therefore, DOE is not considering energy 

conservation standards for high-CCT lamps (with a CCT ≥7000 K). 

In summary, DOE is considering standards for the following CCT ranges in this 

rulemaking: HPS lamps ≥1900 K and ≤2700 K, MV lamps ≥3200 K and ≤6800 K, and MH 

lamps ≥2800 K and <7000 K. Lamp catalogs show a large number of lamp offerings in these 

ranges, suggesting the potential for significant energy savings and the technological feasibility of 

such savings, and preliminary results suggest that energy conservation standards for these lamps 

could be economically justified. 

2.3.2.3 Directional Lamps 

Lamp light distribution is typically categorized as omni-directional or directional. Omnidirectional lamps emit light in all directions with approximately equal intensity, whereas 

directional lamps use a secondary optical element (e.g., reflector, lens, refractor, light guide) or a 

combination of elements to shape the light distribution into a particular pattern. In the test 

procedure NOPR, DOE proposed “directional lamp” be defined as a lamp emitting at least 80 

percent of its light output within a solid angle of π (pi) steradians (corresponding to a cone with 

an angle of 120 degrees) (76 FR 77914, 77917, Dec. 15, 2011). 

DOE found that manufacturers offer both directional and omni-directional lamps for each 

of the three HID lamp types. By analyzing manufacturer catalogs, DOE found that less than 10 

percent of available HID lamps are directional. Lamp manufacturers noted during interviews, 

however, that the actual market share of directional HID lamps is much smaller than their catalog 

representation indicates. Because each directional lamp provides a specific beam pattern, a larger 

number of directional lamp offerings are needed to meet all customer needs. Manufacturers 

indicated that this fact belies their low shipment volume relative to their representation in 

catalogs. Given their small market share, DOE does not believe directional lamps represent 

significant energy savings potential. Furthermore, the pattern of light distribution of these lamps 

makes them unacceptable replacements for omni-directional lamps. Therefore, DOE is not 

considering energy conservation standards for directional lamps. 

2.3.2.4 Self-Ballasted Lamps 

HID lamps can be also categorized by their ballast location (i.e., externally ballasted or 

self-ballasted lamps). The vast majority of HID lamps are operated with an external ballast, 

meaning that the ballast is not located within the lamp body (socket and envelope). An external 

ballast can be located within the fixture or installed separately from the fixture (e.g., at the base 

of a pole-mounted fixture). DOE refers to a ballast that is integrated into the lamp, however, as a 

self-ballasted HID lamp. In the test procedure NOPR, DOE proposed to define “self-ballasted 

lamp” as a lamp unit that incorporates all elements that are necessary for the starting and stable 

operation of the lamp in a permanent enclosure, and that does not include any replaceable or 

interchangeable parts (76 FR 77914, 77918, Dec. 15, 2011). 
2-10

A survey of the market revealed that MH and MV lamp types are available in selfballasted models, but HPS lamps are not. In reviewing catalogs, DOE found that less than one 

percent of MH lamps are self-ballasted, whereas about 17 percent of MV lamps are selfballasted. Of these self-ballasted lamps, most are also directional and would thereby be excluded 

from the scope of coverage. Many of the remaining omni-directional, self-ballasted lamps, which 

span a range from 100 W to 750 W, are marketed as replacements for incandescent technology. 

MV lamps have increased efficacy and longer lifetimes relative to incandescent lamps. However, 

DOE does not believe that regulating self-ballasted HID lamps would result in significant energy 

savings. Instead, adoption of energy conservation standards could increase the price of these 

lamps or eliminate them altogether, thereby shifting the market towards less efficient, 

incandescent lamps. Given the small number of available self-ballasted HID lamps and the 

expectation that customers would likely choose incandescent technology if self-ballasted HID 

lamps were regulated, DOE does not believe there is significant potential for energy savings by 

regulating these lamps. Therefore, DOE is not considering standards for self-ballasted lamps in

this rulemaking. 

2.3.2.5 Lamps Operated on Electronic Ballasts Only 

In its market research, DOE found that catalogs indicated that some HID lamps could be 

operated only by an electronic ballast. DOE conducted additional research on these lamps and

found that they tend to be newer models with uncommon rated wattages. Furthermore, DOE 

discovered that the reason that such lamps are reported for use with an electronic-ballast only 

stems from American National Standards Institute (ANSI) lamp datasheets. ANSI provides 

specifications for operating HID lamps with magnetic ballasts only, regardless of whether a lamp 

can operate on an electronic ballast as well. When a manufacturer develops a new lamp with a 

rated wattage that is already included in ANSI C78.43-20077

or ANSI C78.44-20088standards, 

the lamp will be compatible with the magnetic ballast specifications reported on the ANSI 

datasheets. For a lamp with a new rated wattage to be added to the ANSI datasheets, however, 

ANSI requires that (1) at least two manufacturers independently produce a lamp model at the 

new wattage and (2) they, along with an ANSI committee, agree on the standardized operating 

specifications. In a situation where a manufacturer is the sole producer of a lamp with an unlisted 

wattage, the manufacturer often conducts research and development only for electronic operation 

of that lamp, leading to the designation of electronic-ballast only. 

In the framework document, DOE did not consider standards for these lamp types, 

primarily because of the absence of industry consensus test methods. These lamps also represent 

a small market share (less than one percent) based on feedback during manufacturer interviews. 

Therefore, for the interim analysis, DOE is not considering energy conservation standards for 

HID lamps marketed for exclusive use with electronic ballasts . 

 

7

 ANSI C78.43-2007 American National Standard for Electric Lamps—Single-Ended Metal Halide Lamps is a 

standard published by ANSI that sets forth the physical and electrical requirements for single-ended metal halide 

lamps operated on 60 Hz ballasts to ensure interchangeability and safety and is available for download at: 

http://webstore.ansi.org/RecordDetail.aspx?sku=NEMA+ANSI+ANSLG+C78.43:2007

8

 ANSI C78.44-2008 American National Standard for Electric Lamps—Double-Ended Metal Halide Lamps is a 

standard published by ANSI that sets forth the physical and electrical requirements for double-ended metal halide 

lamps operated on 60 Hz ballasts to ensure interchangeability and safety and is available for download at: 

http://webstore.ansi.org/RecordDetail.aspx?sku=NEMA+ANSI+ANSLG+C78.44:2008
2-11

2.3.2.6 High-CRI Lamps 

CRI is the measure of the degree of color shift objects undergo when illuminated by a 

light source as compared with the color of those same objects when illuminated by a reference 

source of comparable color temperature. (42 U.S.C. 6291(30)(J)) CRI ranges from zero for 

monochromatic light sources to 100 for a light source that closely mimics the color rendering 

properties of the reference source. HID lamps are available over a range of CRIs depending on 

the type, application, and environment in which the lamp is intended to operate. 

During manufacturer interviews, DOE learned that some manufacturers offer an HPS 

lamp with a higher CRI (60 or greater) than typical HPS lamps (a typical CRI value for HPS 

lamps is about 20). These high-CRI HPS lamps are generally marketed as an inexpensive way to 

achieve whiter, higher-CRI light than traditional HPS lamps, though increased color rendering is 

achieved at the expense of lamp efficacy. Instead of purchasing a new lamp, ballast, and fixture, 

the customer can use the high-CRI HPS lamp with their existing HPS ballast and fixture. 

According to HID lamp manufacturers, the market share of such lamps is extremely small—less 

than one percent of total industry HPS lamp shipments. For these reasons, DOE believes that 

high-CRI lamps do not have potential for significant energy savings. 

However, if DOE did not establish standards for these lamps but established a minimum 

efficacy standard for HPS lamps that would exceed the efficacy of high-CRI HPS lamps, there is 

the possibility that the market could shift to the unregulated, high-CRI HPS lamps. While highCRI HPS lamps would provide reduced light output for a given wattage, customers may prefer 

the high-CRI HPS lamps due to the possibility of the unregulated lamp being offered at a lower 

cost (relative to a standard-compliant, traditional HPS lamp) and their compatibility with existing 

HPS ballasts and fixtures. Because alternative high-CRI lamp technologies exist in the wattage 

and CCT ranges under consideration, and to ensure the realization of energy savings associated 

with adopted standards, DOE is considering standards for these high-CRI HPS lamps in this 

interim analysis. 

DOE observed a similar, but different trend regarding high-CRI MH lamps. MH lamps 

are available with CRI values up to 100, though a typical value for a pulse-start quartz MH lamp 

is about 65. The highest CRI MH lamps, those with CRI values greater than or equal to 95, 

utilize pulse-start (quartz and ceramic) technology. These high-CRI pulse-start MH lamps are 

predominantly offered by one company (over 80 percent of product offerings for pulse-start MH 

lamps with CRI values ≥95), indicating that these products are intended for a low volume, niche 

market. For this reason, DOE believes that high-CRI pulse-start MH lamps do not have potential 

for significant energy savings. 

DOE notes that pulse-start MH lamps with CRI values ≥95 often exhibit lower efficacy 

than other pulse-start MH lamps. If DOE did not establish standards for these lamps but 

established a minimum efficacy standard for MH lamps that exceeded the efficacy of high-CRI 

pulse-start MH lamps, it is unlikely that the market would shift to the unregulated, high-CRI 

pulse-start MH lamps. High-CRI pulse-start MH lamps are not likely to be a low cost substitute 

for standards-compliant lamps, because a high-CRI MH lamp is not currently a cost-saving 

option. Furthermore, for certain standard levels, transitioning to a high-CRI pulse-start lamp 

could require a purchase of a new pulse-start ballast and fixture. Because of their small market 
2-12

share and limited potential for energy savings, DOE is not considering standards for pulse-start 

MH lamps with CRI values ≥95 in this interim analysis. 

DOE requests comment on its determination to not consider standards for high-CRI (≥95) 

pulse-start MH lamps. 

2.3.2.7 Colored MH Lamps 

DOE found a small number of HID lamps within the covered CCT ranges that were 

advertised as colored lamps (e.g., blue, green, orange, and magenta). DOE found these lamps 

only in the MH market, and they represented less than two percent of MH lamp catalog 

offerings. This small market share indicates a lack of potential for significant energy savings. 

DOE is considering identifying and defining these colored lamps by CRI based on the 

observation that these lamps have very low CRI such that they emit light that appears colored. 

Because of their unique colored light output, such lamps are used for specialized applications 

and are unsuitable substitutions for other white-light emitting HID lamps. By examination of 

HID lamp offerings currently on the market, DOE preliminarily concluded that advertised 

colored MH lamps generally have a CRI less than 40. As such, DOE is not considering standards 

for those MH lamps that fall below a CRI of 40 due to their use in specialty applications and 

minimal energy savings potential. 

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

which sets chromaticity requirements based on coordinates of the CIE 1931 chromaticity 

diagram.9 DOE preliminarily determined that a colored MH lamp could be effectively defined 

using the simpler CRI criteria specified in the previous paragraph. DOE requests comments on 

this conclusion and whether consistency with the EU definition would be beneficial. 

2.3.2.8 MV Lamps for Specialty Applications 

The Energy Policy Act of 2005 banned the sale of MV lamp ballasts, but exempted 

ballasts for certain specialty applications, such as quality inspection, industrial processing, or 

scientific use, including fluorescent microscopy and ultraviolet curing. These applications cannot 

be served by other HID or solid-state lighting technologies due their unique need for the 

ultraviolet light emitted by MV sources. To preserve the market presence of the lamps that are 

intended for use with these exempted specialty application MV ballasts, DOE is considering 

excluding from energy conservation standards MV lamps that are individually labeled for 

specialty application, including the intended application. DOE welcomes comment on excluding 

such specialty application MV lamps from standards. 

2.3.2.9 Electrodeless HID Lamps 

DOE has determined preliminarily that “electrodeless HID lamps” meet the definition of 

an HID lamp as defined in section 2.3.1. Electrodeless HID lamps generate light through a 

similar process, but couple power to the arc tube through means other than electrodes. Based on 

 

9

 For the complete EU definition of “white light source”, please see the Official Journal of the European Union, 

Commission Regulation (EC) No. 245/2009 of 18 March 2009 at: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:076:0017:0044:EN:PDF. 
2-13

comments received in response to the framework document, the lighting industry generally 

considers electrodeless HID lamps to be a separate lamp technology, and not a subset of HID 

lamps. However, DOE determined that the definition of HID lamp as defined in section 2.3.1

does not make a distinction between lamps that do or do not have electrodes. 

The definition of HID lamp has four main specifications: (1) the arc tube wall loading is 

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

temperature; (3) the lamp is either a MV, HPS, or MH lamp; and (4) the lamp is an “electricdischarge lamp.” Electrodeless HID lamps meet both the first and second criteria based on the 

high power density contained in the gaseous chamber. Regarding the third criteria, electrodeless 

HID lamps have a similar gas mixture to and produce light in the same manner as MH lamps, 

and meet the EPCA definition of a MH lamp. For the fourth criteria, the term electric discharge 

lamp is not defined in DOE’s regulations. DOE found that industry also does not have a 

definition of this term, so DOE reviewed industry’s usage of ‘electric-discharge lamp’ in 

available technical literature to understand its meaning.10 Based on this review, DOE considers 

an electric discharge lamp to be any device that that uses a flow of electric charge in a gas to 

generate visible light through collision of charged particles and possibly other processes. 

Electrodeless HID lamps use this mechanism for generating light, and therefore meet the fourth 

specification of an HID lamp. Thus, DOE has determined preliminarily that “electrodeless HID 

lamps” meet the definition of an HID lamp. 

Although DOE considers electrodeless HID lamps to be a type of HID lamp, 

electrodeless HID lamps have very small market share (less than one percent) and do not have an 

industry consensus test method. DOE has evaluated this information and is not considering 

standards for electrodeless HID lamps in the interim analysis. DOE welcomes comments 

regarding this determination and whether additional information is necessary to define this 

exclusion. 

2.3.3 Summary 

In summary, DOE is considering energy conservation standards for MH lamps with a 

rated wattage of ≥50 W and ≤2000 W, and MV and HPS lamps with a rated wattage of ≥50 W 

and ≤1000 W in the scope of coverage. Within those wattage ranges, DOE is considering 

standards for MH lamps with CCTs ≥2800 K and <7000 K, MV lamps with CCTs ≥3200 K and 

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

DOE is considering excluding directional HID lamps, self-ballasted HID lamps, HID 

lamps designed and labeled for use with electronic ballasts only, pulse-start MH lamps with CRI 

≥95, colored MH lamps (CRI less than 40), MV lamps intended for specialty applications, and 

electrodeless lamps from standards in this interim analysis. 

As discussed in more detail in sections 2.5.2.2, 2.6, and 2.7, DOE also continues to 

consider whether sapphire arc tube technology for HPS lamps meets DOE’s screening criteria 

and, as a related matter, whether to develop a CSL 1 for HPS lamps based on modeled lamps that 

 

10 Electric Discharge Lamps. John F. Waymouth. The Massachusetts Institute of Technology, 1971. 

The Lighting Handbook, Ninth Edition. The Illuminating Engineering Society, 2000. 

The Lighting Handbook, Tenth Edition. The Illuminating Engineering Society, 2011. 
2-14

use this technology. Based on the results of its continued analysis, DOE will consider whether to 

pursue potential regulation of HPS lamps. 

DOE welcomes comment from interested parties regarding the proposed scope of 

coverage and exclusions. 

2.4 METRIC 

To develop energy conservation standards related to HID lamps, DOE must select a 

metric for rating the performance of the lamps. Because directional lamps are under 

consideration for exclusion from standards, DOE analyzed metrics for omni-directional lamps. 

Therefore, for the interim analysis, DOE considered initial lamp efficacy, mean lamp efficacy, 

and input wattage as potential metrics. 

Initial lamp efficacy is the ratio of light output divided by lamp input power at the 

beginning of lamp life. DOE is considering using this metric to establish minimum initial lamp 

efficacy requirements for certain categories of HID lamps. 

Mean lamp efficacy is the ratio of light output divided by lamp input power at a 

percentage of rated life. Mean lamp efficacy is often used by lighting designers to ensure that 

sufficient light output is available over the life of the lamp. DOE found, however, that most 

lamps with higher mean lamp efficacy also had higher initial lamp efficacy, minimizing the 

differential impact of standards defined by mean versus initial lamp efficacy. Mean lamp 

efficacy data would take longer for manufacturers to collect than initial lamp efficacy, which 

could increase the test burden on manufacturers without adequate benefit in the measurement of 

efficacy. For these reasons, DOE does not plan to use mean lamp efficacy as the metric for 

defining energy conservation standards. 

Wattage is a measure of the power used by the lamp. Light output and wattage are highly 

correlated, with a higher wattage associated with a higher light output. DOE considered setting 

standards in terms of a maximum allowable wattage for a given lamp light output (measured in 

lumens). Although this approach directly addresses energy consumption, a disadvantage is that it 

requires equipment classes (groups of lamps subject to the same energy conservation standard) to 

be defined by light output. The use of light output as a class-setting factor has several drawbacks, 

discussed in section 2.5.3. In light of these drawbacks, DOE has preliminarily determined not to 

use maximum input wattage as a metric for HID lamp energy conservation standards. 

2.5 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 include the major manufacturers, 

equipment classes, market trends, shipments of the covered lamps, regulatory and non-regulatory 

programs, and technologies that could be used to improve the efficacy of HID lamps. 
2-15

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

of the HID lamp industry in the United States. Industry publications (e.g., manufacturer catalogs, 

trade journals), government agencies (Environmental Protection Agency, California Energy 

Commission [CEC], etc.), and trade organizations provided the bulk of the information. Using 

this information, DOE assessed the overall state of the industry, lamp manufacturing and market 

shares, shipments by lamp type, general technical information on HID lamps, and industry 

trends. 

The following discussion summarizes DOE’s analytical approach. A more detailed 

discussion on DOE’s approach can be found in the market and technology assessment (chapter 3 

of the interim TSD). 

2.5.1 Market Assessment 

2.5.1.1 Manufacturers of High-Intensity Discharge Lamps 

The majority of the domestic market share of HID lamps is held by four major 

manufacturers: GE Consumer and Industrial of General Electric, Inc. (hereafter “GE”); OSRAM 

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

“Philips”); and Venture Lighting International (hereafter “Venture”). The lighting divisions of 

several of these companies manufacture other products such as fluorescent lamps, halogen 

lamps, light-emitting diode (LED) lamps, and compact fluorescent lamps (CFLs). 

Of all the manufacturers that sell domestically, the majority belong to the National 

Electrical Manufacturers Association (NEMA), a trade association that represents electrical 

product manufacturers, including HID lamp manufacturers. NEMA provides an organizational 

framework for manufacturers of lighting products to work together on projects that affect their 

industry and business. 

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

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

rulemaking analysis. The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation 

of a 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 HID lamps under the North American Industry Classification System (NAICS) 

product code 335110, Electric Lamp Bulb and Part Manufacturing, which has a size standard of 

1,000 employees or fewer.11 This includes the total number of employees in the parent company, 

not only those in the division that produces HID lamps. DOE invites interested parties to provide 

information for any small businesses that manufacture HID lamps and should be consulted 

before DOE publishes a NOPR. 

 

11 U.S. Small Business Administration. Table of Small Business Size Standards Matched to North American Industry 

Classification System Codes. 2012. (Last accessed March 5, 2012.) 

<www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf>.
2-16

2.5.1.2 Regulatory and Non-Regulatory Programs 

Several Federal and international regulatory and non-regulatory programs affect the 

market for HID lamps. U.S., Canadian, and European regulatory initiatives relevant to HID 

lamps covered by this rulemaking and the HID ballasts that operate these lamps are currently in 

place or under development. While the following summary is not exhaustive in describing all 

regulatory action related to HID lamps, it indicates notable initiatives that characterize recent 

developments in the lighting market. Chapter 3 of the interim TSD discusses these regulatory 

programs and initiatives in additional detail and presents a summary of non-regulatory programs 

that affect the HID market. 

The HID lamps rulemaking requirements in the U.S. are described in section 2.2.1. In 

addition to U.S. federal requirements, several other organizations have standards that apply to 

HID lamps or HID ballasts. CEC has adopted,12 and Natural Resources Canada (NRCan) has 

proposed,13 minimum efficiency standards for certain metal halide (MH) ballasts sold with new 

fixtures. In Europe, Commission Regulation No 245/2009 (March 18, 2009) and its revision No 

347/2010 (April 21, 2010) establish lamp efficacy and ballast efficiency requirements for certain 

HID lamps and ballasts. Chapter 3 of the interim TSD further details these lamp efficacy and 

ballast efficiency requirements. 

2.5.1.3 High-Intensity Discharge Lamp Shipments 

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

lamps, DOE estimates shipment volumes disaggregated by lamp type. In chapter 3 of the interim 

TSD, DOE uses two sets of HID lamp shipments that NEMA provided for the periods 1990 to 

2002 and 2003 to 2008, and NEMA HID lamp indices data for 2010.14 The HID lamps in the 

shipment values include colored lamps and directional lamps, both of which DOE is considering 

excluding from this rulemaking. 

DOE uses this data for two main purposes. First, the shipment data and market trend 

information contributes to the shipments analysis and base-case forecast for HID lamp shipments 

(see Chapter 10 of the interim TSD for additional detail). By using historical shipment data and 

expert opinion on market trends and calibrating forecast assumptions with recent data, DOE 

believes it has based the shipments model and base-case forecasts on a sound dataset. Second, 

DOE uses the data to develop the installed stock of HID lamps for the NIA (see Chapter 11 of 

the interim TSD for additional detail). 

Table 2.5.1 shows the estimated historical shipments of HID lamps from 1990 to 2010. 

Discussions with lighting experts and lamp manufacturers indicate an expectation for some 

migration of the HID lamp market to LED lamp systems in outdoor applications and fluorescent 

lamp systems in indoor applications. 

 

12 www.energy.ca.gov/2010publications/CEC-400-2010-012/CEC-400-2010-012.PDF 

13 http://oee.nrcan.gc.ca/regulations/bulletins/4817 

14 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial Reports, Electric 

Lighting Fixtures, MA335L. 2001. (Last accessed March 2, 2012). <www.census.gov/mcd/> 
2-17

Table 2.5.1 Historical Shipments of HID Lamps from 1990-2010 

Year

Unit Shipments (millions) by Year

HPS MV Pulse

MH & CMH

Probe 

MH Total*

1990 7.4 6.2 — 5.7 19.3

1991 8.2 4.5 — 5.5 18.2

1992 8.8 4.7 — 6.4 19.9

1993 9.7 4.6 — 7.3 21.6

1994 10.6 4.8 — 8.7 24.1

1995 10.8 4.5 — 10.5 25.8

1996 11.9 4.4 0.05 11.5 27.9

1997 11.9 3.5 0.1 13.1 28.6

1998 12.2 2.8 0.4 15.0 30.4

1999 12.6 3.0 0.9 17.2 33.4

2000 11.5 1.8 1.2 16.8 31.4

2001 11.5 2.6 2.7 15.6 32.4

2002 11.7 2.4 3.7 15.0 32.9

2003 11.5 2.3 4.7 14.5 32.9

2004 11.3 2.5 7.2 12.7 33.7

2005 13.9 2.6 7.9 13.6 37.8

2006 11.8 2.7 7.9 14.0 36.4

2007 11.2 2.3 7.9 14.1 35.5

2008 10.9 1.8 7.3 13.0 33.1

2009 10.2 1.5 8.6 9.2 29.6

2010 10.2 1.5 9.8 8.8 30.3

* Because of rounding, values may not sum to the total. 

2.5.2 Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to improve 

HID lamp efficacy. This assessment provides the technical background and structure on which 

DOE bases its screening and engineering analyses. The following discussion provides a list of 

technologies for consideration that could improve the efficacy of the covered lamps. To develop 

this list, DOE reviewed manufacturer catalogs, recent trade publications, and technical journals; 

and consulted with technical experts. Chapter 3 of the interim TSD provides more detailed 

descriptions of the basic construction and operation of HID lamps, followed by a discussion of 

technology options to improve the efficacy of HID lamps. 

The technology assessment centers on understanding how the covered equipment uses 

energy and on identifying measures that would improve the efficacy of HID lamps. Measures 

that improve equipment efficacy are called technology options, and they are based on existing 

commercially available technologies as well as working prototypes. In consultation with 

interested parties, DOE created a list of technology options for consideration in this rulemaking. 

Following research into this list of technology options, DOE considered each option in light of 

four screening criteria: (1) technological feasibility; (2) practicability to manufacture, install, and 

service on the scale necessary to serve the relevant market at the time of the effective date of the 
2-18

standard; (3) adverse impacts on equipment utility or availability; and (4) adverse impacts on 

health or safety (see section 2.6). (10 CFR Part 430, subpart C, appendix A at 4(a)(4) and 5(b)) 

Those technology options that meet the four screening criteria are called design options. These 

options will be considered appropriate ways to improve the efficacy of the equipment in the 

engineering analysis, and will assist DOE in determining the maximum technologically feasible 

design. 

The following sections provide DOE’s initial assessment of technologies that improve the 

efficacy of HID lamps. 

2.5.2.1 Mercury Vapor Lamps 

MV ballasts, other than specialty application MV ballasts, have been banned from import 

or production in the United States since January 1, 2008. (42 U.S.C. 6295(ee)) This ban 

effectively limits the installation of new MV fixtures and ballasts, meaning the only MV lamps 

currently being sold are replacement lamps. DOE understands that there is limited industry 

design emphasis on MV lamps, that there are limited methods to improving the efficacy of MV 

lamps, and that the common pathway to increase efficacy is a change of technology to MH or 

HPS lamps. 

2.5.2.2 High-Pressure Sodium Lamps 

HPS lamps are very efficacious (up to 150 lumens per watt [lm/W]), but have 

intrinsically poor color quality. DOE is aware of only one current option that could achieve 

higher efficacy in HPS lamps: 

 Sapphire Arc Tubes. The arc tube assembly contains the gases that are excited to 

generate light. The arc tubes in current commercially available HPS lamps are 

constructed of a ceramic material known as polycrystalline alumina (PCA). Through 

its own research, DOE found academic papers that indicated potential increases in 

efficacy by constructing the arc tubes out of a sapphire material, or single crystal 

aluminum oxide. Sapphire has improved light transmission characteristics that would 

allow for a moderate improvement in efficacy. Through research and manufacturer 

feedback, DOE estimates that HPS lamp efficacy could increase by five percent when 

changing from PCA to sapphire arc tubes. 

Several manufacturers produced an HPS lamp with a sapphire arc tube, the first 

appearing in the late 1970s. Manufacturers have since discontinued production of these lamps, 

though DOE does not have information on the causes of the discontinuance. At this time, lamps 

using sapphire arc tube technology are not available commercially or in a working prototype. 

DOE welcomes comment and additional information on this technology. 

2.5.2.3 Metal Halide Lamps 

DOE is aware of several technology options that can improve MH lamp efficacy. DOE 

intends to evaluate the following technology options: 
2-19

 Arc Tube Design. Potential improvement options include changing the material of the 

arc tube from quartz to ceramic and changing the size and shape of the arc tube. Some 

of these options, however, may not be compatible with all MH systems. For example, 

ceramic arc tubes are used only with low-frequency pulse-start MH systems. 

o Ceramic Arc Tubes. Manufacturers have introduced commercial pulse-start 

ceramic metal halide (CMH) lamps with higher efficacy and better color 

characteristics than quartz pulse-start MH lamps. 

o Arc Tube Shape. The shape of the HID lamp arc tube relates to the efficacy of the 

lamp. For example, certain arc tube shapes (like formed or offset electrode) can 

be more efficacious than others for horizontal operating orientations. These arc 

tube shapes help position the lamp arc in a way that increases MH vapor pressure, 

leading to increased light output. 

 Starting Method. Pulse-start lamps are often more efficacious than probe-start lamps. 

While the pulse-starting method itself consumes more energy, the removal of the 

probe electrode needed in probe-start lamps can allow for more efficacious arc tube 

designs by providing more flexibility for shaping the ends of the arc tube. Some arc 

tube shapes can lead to a slightly higher initial efficacy than others. 

DOE invites comment on the technology options considered for this rulemaking and any 

additional technology options that should be considered. 

2.5.3 Equipment Classes 

In general, when evaluating and establishing energy conservation standards, DOE divides 

covered equipment into classes by: (a) the type of energy used; and (b) capacity of the 

equipment; or (c) any other performance-related feature that justifies different standard levels. In 

establishing product classes, DOE considers the consumer utility of the feature and other factors 

DOE determines appropriate. (42 U.S.C. 6295(q)) DOE then conducts its analysis and considers 

standards for each equipment class. 

DOE identified the following characteristics or features of HID lamps that warrant 

separation of covered equipment into different equipment classes: 

 correlated color temperature; 

 wattage; 

 bulb finish; and 

 luminaire characteristic. 

DOE also considered several other characteristics or features of HID lamps, but 

preliminarily determined that these features did not warrant further delineation of equipment 

classes. See chapter 3 for a discussion of all potential class-setting factors. 
2-20

2.5.3.1 Correlated Color Temperature 

In general terms, CCT represents the color appearance of a light source and is expressed 

in Kelvins. The higher the CCT, the cooler or more blue the light appears, and the lower the 

CCT, the warmer or more red the light appears. HID lamps are available with a wide range of 

CCT values depending on lamp type and design. DOE’s analysis of commercially available lamp 

catalog data concluded that CCT is correlated with lamp efficacy. DOE determined that higherCCT lamps were less efficacious than lower CCT lamps of the same wattage. 

DOE identified distinct differences in efficacies for lamps with CCT values 1900 K and 

2800 K; 2800 K and 4500 K; and 4500 K and 7000 K. For example, a 250 W lamp with a 

CCT 1900 K and 2800 K has a maximum efficacy of about 116 lm/W, a 250 W lamp with a 

CCT 2800 K and 4500 K has a maximum efficacy of about 100 lm/W, and a 250 W lamp with 

a CCT >4500 K and <7000 K has a maximum efficacy of about 76 lm/W. 

Because CCT is an approximation of the color appearance of the color of a lamp, 

customers typically specify different CCTs for different applications. For example, in indoor 

applications, customers typically specify a CCT of 3000 K to 4500 K, based on the preferences 

of their occupants. Because of these preferences and behavior, DOE believes that CCT offers 

customers unique utility. 

Because CCT affects HID lamp efficacy and impacts utility, DOE has preliminarily 

decided to establish separate equipment classes based on CCT. These equipment class divisions 

are summarized below in Table 2.5.2. 

Table 2.5.2 Equipment Classes Based on CCT 

CCT Range

1900 K and ≤2800 K

2800 K and ≤4500 K

4500 K and <7000 K

2.5.3.2 Wattage 

HID lamps are available with a variety of light outputs, or lumen outputs, and input 

powers, or wattages. Light output and input power are highly correlated (increased input power 

typically leads to increased light output). DOE’s initial review of manufacturer catalogs for the 

framework document determined that HID lamps with increased light output (and therefore 

increased input powers) were generally more efficacious than lamps with lower light outputs 

(and therefore lower input powers). Because customers typically require specific light output 

from a lamp depending on the intended use for the lamp, in the framework document DOE 

considered establishing separate equipment classes based on light output. 

DOE notes that the use of light output as a class-setting factor could result in HID lamps 

of the same wattage being placed in separate equipment classes and therefore subject to different 

standards. DOE received feedback that customers typically choose lamps based on the wattage 

rather than the lumen output. Manufacturers also categorize their lamps in terms of wattage, in 

part because it serves the dual role of identifying which ballasts can be paired with the lamp. As 
2-21

a result, and for the additional reasons discussed below, DOE considered establishing separate 

equipment classes based on wattage. 

HID lamps are commercially available with rated wattages as low as 15 W and as high as 

18,000 W. As previously discussed in section 2.3, in this rulemaking, DOE is considering 

coverage of HID lamps with rated wattages 50 W and 1000 W for HPS and MV lamps, and 

50 W and 2000 W for MH lamps. Because of the typical CCT characteristics of the HID lamp 

types, DOE determined that these wattage delineations correlated with a maximum wattage of 

1000 W for lamps in the lower CCT range, and a maximum wattage of 2000 W for lamps in the 

middle and highest CCT ranges. 

When examining manufacturer catalog data, all other features remaining constant, DOE 

observed that HID lamp efficacy generally increases with increasing lamp wattage. This 

correlation is because there are certain fixed losses within a lamp associated with current passing 

through the electrodes (known as end losses) and with thermal losses from the arc to the arc tube 

wall. When the wattage increases, the fixed losses are a smaller portion of the overall losses, thus 

making the lamp more efficacious. In addition to impacting efficacy, DOE believes that lamp 

wattage impacts consumer utility. Typically, a lamp with a higher wattage will provide more 

light. Because customers require varying light levels depending on the application and location 

of the lamp, lamp wattage provides utility to the customer. Further, ballasts are typically 

designed to operate specific lamp wattages, indicating that a change in lamp wattage often 

requires a change in ballast. For these reasons, DOE concludes that lamp wattage impacts 

consumer utility as well as efficacy. In the interim analysis, therefore, DOE has decided to 

consider wattage as a potential class-setting factor rather than lumen output. However, DOE 

continues to use lumen output as a factor when selecting higher-efficacy lamp replacements. 

Because DOE decided to use equations to relate efficacy and wattage, the efficacy levels 

considered in this interim analysis account for the observed trend of increasing efficacy with 

increasing lamp wattage. The reasoning and methodology for this decision is further explained in 

section 2.7.4. 

However, even when using an equation to relate efficacy and wattage, DOE observed that 

the same alternative designs were not available at all wattages. For example, CMH lamps were 

available at only 400 W and below, pulse-start quartz MH lamps were available at only 1000 W 

and below, and only probe-start quartz lamps (no MV lamps) were available through 2000 W. 

Therefore, DOE subdivided the higher two CCT ranges based on lamp wattage. In these two 

CCT ranges, DOE created separate equipment classes for the following wattage ranges: (1) 50 

W and 400 W; (2) 400 W and 1000 W; and (3) 1000 W and 2000 W. For the lowest CCT 

range, wattage divisions were not necessary because the same number of energy saving 

alternatives were available at all of the wattages. These equipment class divisions are 

summarized in Table 2.5.3.
2-22

Table 2.5.3 Equipment Classes Based on Wattage 

CCT Range Wattage

1900 K and ≤2800 K 50 W and ≤1000 W

2800 K and ≤4500 K

50 W and ≤400 W

400 W and ≤1000 W

1000 W and ≤2000 W

4500 K and <7000 K

50 W and ≤400 W

400 W and ≤1000 W

1000 W and ≤2000 W

2.5.3.3 Bulb Finish 

In reviewing catalogs, DOE observed that HID lamps are offered with several different 

bulb finishes, such as clear, coated, diffuse, frosted, white, or deluxe white. Some of these labels 

apply to only certain types of HID lamps. For example, in addition to being classified as coated, 

DOE has found HPS lamps labeled as diffuse lamps, MH lamps labeled as frosted, and MV 

lamps labeled as white and deluxe white lamps. DOE determined that the difference among all of 

these terms was generally based on marketing techniques. However, across all manufacturers, 

DOE notes that most coated lamps have phosphor coatings applied to the inner wall of the outer 

bulb, whereas clear lamps do not have this coating. For this rulemaking, DOE defines “coated 

lamps” as all lamps that are not clear, because the terms coated, diffuse, frosted, white, or deluxe 

white usually represent the same or nearly the same bulb finish within a lamp type. DOE invites 

comment on a definition for coated lamps and for clear lamps. 

The coating on a lamp blocks a portion of the light produced by the arc tube from leaving 

the lamp. Thus, coated lamps should have lower efficacy than their clear counterparts. By 

comparing pairs of coated and clear lamps, all other features remaining the same or similar, DOE 

found that a coating on MH and HPS lamps reduced overall lamp efficacy. However, for MV 

lamps, DOE determined that coated lamps were more efficacious than their clear counterparts. 

Based on manufacturer feedback during interviews, this relationship exists because MV lamps 

generate a large amount of ultraviolet (UV) light and the coating on MV lamps converts the UV 

light into visible light, thereby increasing the efficacy of the lamp. 

DOE believes that for all three types of HID lamps, a coated lamp offers unique utility. 

For MH and HPS lamps, a coating is often applied to reduce the perception of glare perceived by 

the customer. For MV lamps, a coating often impacts the CCT of the lamp. As discussed above, 

DOE believes that CCT offers unique consumer utility. 

Given the impact on efficacy and utility, DOE established separate equipment classes for 

clear and coated MH and HPS lamps in their respective wattage and CCT ranges. For MV lamps, 

DOE determined that an equipment class division was not necessary because the CCT equipment 

class divisions already separate coated MV lamps from clear MV lamps. DOE found all clear 

MV lamps in the scope of this rulemaking have a CCT 4500 K and 7000 K, while all coated 

MV lamps in the scope are 2800 K and 4500 K. Because clear MH lamps are the most likely 

replacements for coated MV lamps in the applicable CCT ranges, DOE has preliminarily 

determined that MV lamps should be categorized in the clear bulb finish equipment classes 
2-23

(regardless of the bulb finish of the MV lamp itself). These equipment class divisions are 

summarized in Table 2.5.4.

Table 2.5.4 Equipment Classes Based on Bulb Finish 

CCT Range Wattage Bulb Finish*

1900 K and ≤2800 K 50 W and ≤ 1000 W

Clear

Coated

2800 K and ≤4500 K

50 W and ≤ 400 W

Clear

Coated

400 W and ≤ 1000 W

Clear

Coated

1000 W and ≤ 2000 W

Clear

Coated

4500 K and <7000 K

50 W and ≤ 400 W

Clear

Coated

400 W and ≤ 1000 W

Clear

Coated

1000 W and ≤ 2000 W

Clear

Coated

* MV lamps regardless of bulb finish are placed in the clear equipment class for their 

respective CCT and wattage.

2.5.3.4 Luminaire Characteristic 

MH lamps are frequently listed with a luminaire characteristic, typically open-rated or 

enclosed-rated, to indicate in which type of fixture the lamps should be used. An open fixture 

does not have a physical barrier that separates the lamp from the space that is to be illuminated. 

Open-rated lamps have a glass shroud that surrounds the arc tube to protect the environment and 

any occupants around the lamp in the event of arc tube rupture.15 An enclosed fixture does have a 

physical barrier that separates the lamp from the space that is to be illuminated. Enclosed-rated 

lamps do not have the glass shroud surrounding the arc tube, and must be used in enclosed 

fixtures to satisfy safety requirements.16 DOE also found commercially available lamps that were 

labeled as S-rated.17 S-rated lamps do not have a glass shroud around the arc tube, but can be 

used in open-rated fixtures under certain defined conditions. Because S-rated lamps do not 

feature a shroud, DOE determined their efficacy potential would be comparable to traditional 

enclosed-rated lamps. 

 

15 DOE is considering adopting the ANSI C78.380-2007 definition of open-rated: “Lamp may be used in an open 

luminaire. The effective antic UV output of the lamp shall not exceed 2 mW/klm for a non-reflector lamp or 2 

mW/(m2∙klx) [klx refers to kilo-lux] for a reflector lamp. Metal halide Type O lamps must meet specified 

containment test requirements.” 

16 DOE is considering adopting the ANSI C78.380-2007 definition of enclosed-rated: “Lamp may be used in an 

enclosed luminaire that meets industry standards for containment in the event of lamp rupture. The effective antic 

UV output of the lamp shall not exceed 2 mW/klm for a non-reflector lamp or 2 mW/(m2∙klx) for a reflector lamp.” 

17 ANSI C78.380-2007 defines S-rated lamps as: “Lamp may be used in an open luminaire if position restrictions are 

followed. Otherwise, the lamp requires an enclosed luminaire that meets industry standards for containment in the 

event of lamp rupture. Specific containment test requirements do not apply to this type of lamp. The effective actinic 

[wavelengths potentially harmful to humans] UV output of the lamp shall not exceed 2 mW/klm for a non-reflector 

lamp or 2 mW/(m2∙klx) for a reflector lamp. This letter is not to be used for luminaire designation on lamps other 

than metal halide.” 
2-24

DOE notes that luminaire characteristic applies to only MH lamps. This is because MH 

lamps typically operate at temperatures and pressures significantly higher than those of HPS or 

MV lamps (see the technology assessment in chapter 3 of the interim TSD). DOE also found 

definitions for F-rated lamps, but did not identify any of these lamps in its review of 

manufacturer catalog data. DOE requests comment on the separation of equipment classes by 

luminaire characteristic, as well as the applications of F-rated lamps and how they should be 

categorized within DOE’s equipment class structure. 

By comparing pairs of open-rated and enclosed-rated MH lamps, with all other features 

remaining the same or similar, DOE determined that enclosed-rated MH lamps are more 

efficacious than their open-rated counterparts. DOE attributes the efficacy gain to the removal of 

the shroud that covers the entire arc tube and blocks a small percentage of light from leaving the 

lamp. Because the shroud is a safety feature that is required for open fixtures, DOE believes 

open-rated lamps offer unique utility. 

Given the impact on both consumer utility and lamp efficacy, DOE established separate 

equipment classes for enclosed-rated versus open-rated lamps. For this interim analysis, DOE 

placed HPS and MV lamps in the enclosed-rated equipment classes, because they do not have a 

protective glass covering. HPS and MV lamps would be subject to the same energy conservation 

standards as enclosed-rated lamps, even though DOE recognizes these lamps could be used in 

open fixtures in practice. 

2.5.3.5 Summary 

The equipment class divisions are summarized in Table 2.5.5. DOE seeks comment on 

the appropriateness of the class-setting factors (i.e., CCT, wattage, bulb finish, and luminaire 

characteristic) considered and selected, as well as the equipment classes defined for this 

rulemaking. 

DOE also welcomes additional comments pertaining to the market and technology 

assessment. 
2-25

Table 2.5.5 HID Lamps Interim Analysis Equipment Classes 

CCT Range Wattage Bulb 

Finish*

Luminaire 

Characteristic**

1900 K and ≤2800 K 50 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

2800 K and ≤4500 K

50 W and ≤400 W

Clear Enclosed

Open

Coated Enclosed

Open

400 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

1000 W and ≤2000 W

Clear Enclosed

Open

Coated Enclosed

Open

4500 K and <7000 K

50 W and ≤400 W

Clear Enclosed

Open

Coated Enclosed

Open

400 W and ≤1000 W

Clear Enclosed

Open

Coated Enclosed

Open

1000 W and ≤2000 W

Clear Enclosed

Open

Coated

Enclosed

Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their 

respective CCT and wattage.

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

wattage and CCT.

2.6 SCREENING ANALYSIS 

After DOE identified the technologies that might improve the efficacy of HID lamps, 

DOE conducted the screening analysis. The purpose of the screening analysis is to determine 

which options to consider further in the engineering analysis 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 from 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. 
2-26

 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. 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. 

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. After 

examining all of the options presented in the technology assessment except sapphire arc tube 

technology, DOE determined that none of these technology options should be screened out. 

Therefore, all of these options will be considered in the engineering analysis as design options. 

DOE continues to examine sapphire arc tube technology and seeks comment on whether 

sapphire arc tube technology meets the criteria of the screening analysis. For a complete 

discussion of the screening analysis, refer to chapter 4 of the interim TSD.

2.7 ENGINEERING ANALYSIS 

In the engineering analysis, DOE selects representative equipment classes to analyze. It 

then selects representative lamp types within those representative equipment classes, and 

identifies lamps that represent more efficacious versions of the baseline lamps. DOE uses these 

more efficacious lamps to develop CSLs. While DOE establishes CSLs based on lamp designs, it 

also develops lamp-and-ballast designs for use in the LCC analysis and NIA. DOE is considering 

lamp-and-ballast designs in the LCC and NIA because lamps and ballasts operate together in 

practice. 

In energy conservation standard rulemakings for other equipment, DOE often develops 

cost-efficiency relationships in the engineering analysis. However, for this HID lamp 

rulemaking, DOE derives efficacy levels in the engineering analysis and end-user prices in the 

equipment price determination. By combining the results of the engineering analysis and the 

equipment price determination, DOE derives typical inputs for use in the LCC and NIA. Section 

2.8 discusses the equipment price determination (see chapter 6 of the interim TSD for further 

detail). 
2-27

2.7.1 Interim Engineering Analysis Approach 

The following is a summary of the steps taken in the engineering analysis: 

 Step 1: Select Representative Equipment Classes 

 Step 2: Select Baseline Lamps 

 Step 3: Identify More Efficacious Substitutes 

 Step 4: Develop CSLs 

A more detailed discussion of the methodology DOE followed to perform the engineering 

analysis can be found in the engineering analysis chapter of the interim TSD (chapter 5). The 

following discussion summarizes the general steps of the engineering analysis:

Representative equipment classes: DOE first reviews covered lamps and the associated 

equipment classes. When a product has multiple equipment classes, DOE selects certain classes 

as “representative” and concentrates its analytical effort on these classes. DOE selects 

representative equipment classes primarily because of their high market volumes. For those 

equipment classes that are not analyzed, DOE extrapolates the CSLs from representative 

equipment classes to other equipment classes. 

Baseline lamps: DOE selects representative lamp types within each representative 

equipment class. For each representative lamp type, DOE selects a baseline model as a reference 

point against which to measure changes resulting from energy conservation standards. Typically, 

a baseline model is the most common, least efficacious lamp sold in a given equipment class. For 

this interim analysis, DOE uses performance data presented in manufacturer catalogs to 

determine lamp efficacy. DOE considers other lamp characteristics in choosing the most 

appropriate baseline for each equipment class. These characteristics include the lamp’s starting 

method, wattage, and lamp type (i.e., HPS, MH, MV). For some of the representative lamp types, 

DOE selects multiple baseline models to ensure consideration of different high-volume lamps 

and their associated customer economics. For example, although metal halide lamps are not the 

least efficacious products available, consumers of metal halide lamp-and-ballast systems incur 

different costs than consumers of mercury vapor lamp-and-ballast systems. 

More efficacious substitutes: DOE selects higher-efficacy lamps as replacements for each 

of the baseline models considered for each representative lamp type. DOE considers only design 

options that meet the criteria outlined in the screening analysis (see section 2.6, or for further 

detail, chapter 4 of the interim TSD). DOE generally selects commercially available lamps as 

substitutes. For this rulemaking, DOE may also consider model lamps developed for the 1900 

K and 2800 K, 50 W and 1000 W, clear equipment class that use sapphire arc tube 

technology, if it is determined that this technology meets the screening criteria described in 

section 2.6. 

Because customers typically are unable or unwilling to change fixture spacing within 

their facilities and spaces, DOE is analyzing more efficacious substitutes that maintain mean 

lumens within 10 percent of the baseline when possible. Changing fixture spacing would require 

the light output of a lamp to increase because fewer fixtures would be used in order to maintain 
2-28

overall light output. Mean lumens are a measure of light output midway18 through the rated life 

of a lamp, and a 10 percent change is a common parameter used by lighting designers to specify 

acceptable substitute products on the basis of light output. 

Candidate standard levels: After identifying the more efficacious substitutes for each 

baseline lamp, DOE develops CSLs. DOE is basing its analysis on three factors: (1) the design 

options associated with the specific lamps studied; (2) the ability of lamps across wattages to 

comply with the standard level of a given equipment class;

19 and (3) the maximum 

technologically feasible efficacy level. 

2.7.1.1 Representative Equipment Classes 

As discussed in the market and technology assessment (section 2.5 and chapter 3 of the 

interim TSD), DOE created equipment classes based on CCT, wattage, bulb finish, and luminaire 

characteristic, shown in Table 2.7.1. 

Of these equipment classes, DOE chose to analyze four as representative. For CCT, DOE 

considered the ≥1900 K to ≤2800 K and >2800 K to ≤4500 K ranges to be representative. The 

≥1900 K and ≤2800 K range includes all HPS lamps, a significant market segment (about onethird of HID lamp shipments in 2008).14 Based on lamp catalogs and manufacturer interviews, 

MH and MV lamps are available in both the >2800 K to ≤4500 K and >4500 K and <7000 K 

ranges, but the former of the two ranges includes the more commonly shipped MH and MV 

lamps. For bulb finish, DOE determined that clear lamps were more commonly shipped than 

coated lamps for both representative CCT ranges.20 Finally, for luminaire characteristic in the 

≥1900 K to ≤2800 K21 and >2800 K to ≤4500 K CCT ranges, DOE determined that enclosedrated lamps are more commonly shipped than open-rated lamps. Table 2.7.1 lists the 

representative equipment classes and those classes not analyzed directly (scaled equipment 

classes). DOE seeks comment on its selection of the representative equipment classes. 

 

18 For MH lamps, mean lumens listed in catalogs are typically measured at 40 percent of rated life. For HPS and MV 

lamps, mean lumens listed in catalogs are typically measured at 50 percent of rated life. 

19 CSLs span multiple lamps of different wattages. In selecting CSLs, DOE considered whether these multiple lamps 

can meet the standard levels. 

20 Clear lamps are more commonly shipped within these two representative CCT ranges for both HPS and MH 

lamps. The MV lamps that are in the >2800 K and ≤4500 K equipment classes are all coated. Because these 

equipment classes are made up predominantly of MH lamps and there is only one option for MV lamps in these 

classes, DOE will refer to these classes as being “clear,” although all the MV lamps within them will be coated. 

21 HPS lamps are the most common in this CCT range. While HPS lamps do not have open-rated vs. enclosed-rated 

luminaire characteristic, DOE determined in section 2.5.3 that HPS lamps would be placed in the enclosed-rated 

equipment classes for their respective CCT and wattage. 
2-29

Table 2.7.1 Representative and Scaled Equipment Classes for HID Lamps

CCT Range Wattage Bulb 

Finish*

Luminaire 

Characteristic**

Representative or Scaled Equipment 

Class

1900 K and 2800 

K

50 W and 

1000 W

Clear

Enclosed Representative Equipment Class

Open Scaled

Coated

Enclosed Scaled

Open Scaled

2800 K and 4500 

K

50 W and 

400 W

Clear

Enclosed Representative Equipment Class

Open Scaled

Coated

Enclosed Scaled

Open Scaled

400 W and 

1000 W

Clear

Enclosed Representative Equipment Class

Open Scaled

Coated

Enclosed Scaled

Open Scaled

1000 W and 

2000 W

Clear

Enclosed Representative Equipment Class

Open Scaled

Coated

Enclosed Scaled

Open Scaled

4500 K and 7000

K

50 W and 

400 W

Clear

Enclosed Scaled

Open Scaled

Coated

Enclosed Scaled

Open Scaled

400 W and 

1000 W

Clear

Enclosed Scaled

Open Scaled

Coated

Enclosed Scaled

Open Scaled

1000 W and 

2000 W

Clear

Enclosed Scaled

Open Scaled

Coated

Enclosed Scaled

Open Scaled

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

wattage.

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

2.7.2 Baseline Lamps 

Once DOE identified the representative equipment classes for analysis, it selected 

baseline lamps to analyze in each class. Because no federal energy conservation standards exist 

for HID lamps, the baseline lamps represent the most common, least efficacious lamps sold 

within the equipment class. For each baseline lamp, DOE selected more efficacious replacement 

lamps to measure potential energy-saving improvements. DOE refers to the baseline lamp and its 

more efficacious replacements collectively herein as a “representative lamp type.” The 
2-30

representative lamp type is named by its least efficacious baseline. For example, the 400 W MV 

representative lamp type refers to the 400 W MV baseline lamp and its more efficacious 

replacements. 

In certain cases in which two lamp technologies (e.g., MV and MH) are included in the 

same representative lamp type, DOE chose multiple baseline lamps. For example, MV lamps are 

the least efficacious lamp option for some equipment classes; however, MV lamps represent a 

very small portion of the market because many customers have already transitioned to MH 

technology. For this reason, DOE selects both an MV lamp and an MH lamp as baselines for 

certain representative lamp types in the >2800 K and ≤4500 K equipment classes. DOE 

welcomes comment on the baseline lamps selected. 

Table 2.7.2 Representative Lamp Types 

CCT Range Wattage Bulb Finish Luminaire 

Characteristic

Baseline 

Lamp Type

Baseline 

Wattage

1900 K and 

2800 K

50 W and 

1000 W

Clear Enclosed

HPS 70

HPS 100

HPS 250

HPS 400

HPS 1000

2800 K and 

4500 K

50 W and 

400 W Clear Enclosed

MV 100

Pulse MH 70

MV 175

Pulse MH 100

MV 250

Probe MH 175

MV 400

Probe MH 250

Probe MH 400

400 W and 

1000 W Clear

Enclosed MV 1000

Enclosed Probe MH 1000

1000 W and 

2000 W Clear Enclosed Probe MH 2000

2.7.3 More Efficacious Substitutes 

After choosing a baseline lamp for each representative lamp type, DOE searched for 

commercially available HID lamps that would serve as more efficacious substitutes on the basis 

of initial efficacy. When identifying lamps that could replace baselines, DOE considered a 

number of criteria. Most importantly, more efficacious substitutes were selected to save energy 

and have mean lumens within 10 percent of the mean lumens of the baseline lamp when 

possible. DOE also sought to keep other characteristics as similar as possible, such as initial 

lumen output, operating orientation, rated life, CRI, bulb shape, and base type. 
2-31

Manufacturers suggested that lamps with universal operating orientation22 provide value 

for the customer. DOE analyzed whether the specified operating orientation of lamp had a 

significant impact on efficacy by comparing horizontal position-only, vertical (base-up) positiononly, and universal-position (when tested in a vertical, base-up position)23 lamps. DOE found the 

data reported in catalogs did not provide conclusive evidence of a difference in efficacy. When 

possible, however, DOE chose representative units that were designed for universal operating 

orientation to ensure this parameter remained available to the customer. DOE requests comment 

on the criteria used in selecting more efficacious substitute lamps, as well as the units selected. 

Because there are no commercially available higher efficacy replacements for the HPS 

baseline lamps, DOE is considering the use of modeled replacements for these lamps. DOE 

looked into several different methods for modeling these more efficacious replacements, 

explained in more detail in chapter 5 of the interim TSD. The method DOE chose involved 

modeling the changes in efficacy and cost associated with replacing the standard ceramic arc 

tube found in HPS lamps with sapphire arc tubes. As discussed in section 2.6, DOE continues to 

consider whether this technology meets the screening criteria and should be considered further in 

DOE’s analysis. 

2.7.4 Candidate Standard Levels 

In its analysis of available data, DOE found that initial lamp efficacy tends to increase 

with increased wattage. DOE considered two options to capture this trend when establishing 

CSLs: (1) a constant-value approach, in which the same standard is established for all lamps 

within an equipment class, and (2) an equation-based approach, in which a relationship between 

lamp input power and initial lamp efficacy is determined for each equipment class. To consider a 

constant-value approach, in which all lamp wattages within an equipment class are required to 

meet a single standard, DOE would have to create several additional equipment classes to 

accommodate the range of wattages encompassed by a representative lamp type. For example, in 

the >2800 K to ≤4500 K CCT range, DOE could create an equipment class for lamps with 

wattages between 100 W and 250 W (the 250 W MV representative lamp type) that would 

encompass the 250 W MV baseline and the more efficacious, lower-wattage probe-start, pulsestart, and CMH replacements. However, when analyzing potential equipment class divisions 

based on wattage, DOE noticed that the wattage of the highest-efficacy replacements for certain 

baselines overlapped with a neighboring equipment class. For example, the 100 W CMH 

replacement for the 250 W MV baseline lamp in the above equipment class has the same wattage 

as: (1) a 100 W pulse-start MH replacement for a 175 W MV baseline lamp and (2) a 100 W MV 

baseline lamp. Furthermore, a constant-value approach could encourage a market shift to the 

higher-wattage end of any equipment class, as those lamps are naturally able to achieve higher 

efficacy than lower wattage lamps. For these reasons, DOE decided to pursue an equation-based 

approach in this rulemaking. DOE requests comment on the decision to pursue an equation-based 

approach for the engineering analysis in this rulemaking. 

 

22 Lamps with universal operating orientation designed to operate when mounted in any direction, as opposed to 

other lamps that are designed to operate at a single orientation (e.g., horizontal, base up). 

23 For purposes of certification, compliance, and enforcement, DOE proposes requiring testing of universal 

orientation lamps in the vertical, base-up position as required in the applicable industry standard (ANSI C78.389, 

section 3.6) because data indicate that the vertical, base-up position is the most commonly used. 
2-32

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

design option. For example, DOE developed a CSL for each more efficacious replacement for a 

MV baseline, such as a probe-start, pulse-start, and CMH lamp. After analyzing available 

products, DOE noticed that the same design options were not available across all lamp wattages. 

For example, CMH lamps were available between only 50 and 400 W. Similarly, pulse-start 

quartz MH lamps are not available above 1000 W. Because more efficacious lamp design 

options are available at only certain lamp wattages, and DOE had already established that lamp 

wattage offers unique utility, DOE established separate equipment classes based on lamp 

wattage. DOE established separate equipment classes for lamps in the >2800 K and ≤4500 K 

CCT range with wattages ≥50 W and ≤400 W, >400 W and ≤1000 W, and >1000 W and ≤2000 

W.

DOE analyzed each equipment class to determine the appropriate CSLs. To develop 

equations, DOE used power function regression curves to best fit the representative units in each 

equipment class, according to an equation of the form: 

Initial lamp efficacy (lm/W) = Coefficient * (Lamp input power [W])^Exponent 

Using the available data, DOE calculated the coefficient and exponent for each CSL 

equation. For the equipment classes in which fewer technologies were available to improve 

efficacy (i.e., lamps with CCT >2800 K and ≤4500 K and input wattage >400 W and ≤2000 W), 

DOE utilized linear equation forms instead of the power function equation form. Table 2.7.3

summarizes the CSLs identified for each representative equipment class. See chapter 5 of the 

interim TSD for additional detail on the development of CSLs. DOE invites comment on the 

CSL equations set forth in the interim analysis. 

Table 2.7.3 Representative Equipment Class Candidate Standard Levels 

CCT Range Wattage Range CSL Lamp Type Equation

>2800 K and ≤4500 K

≥50 W and ≤400 W

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

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

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

>400 W and ≤1000 W CSL 1 Probe MH lm/W = 0.021 * W + 74.3

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

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

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

and ≤1000 W wattage range. The lamp type would be an HPS lamp that uses sapphire arc tube 

technology. As noted in section 2.6, DOE seeks comment on whether this technology passes the 

screening analysis and should be considered in the development of a CSL 1 for these lamps. For 

more information on the standard level for this potential CSL 1, see chapter 5 of the interim 

TSD.

2.7.4.1 Reporting Requirements 

As stated previously in section 2.7, DOE has based the engineering analysis on average 

performance data presented in manufacturer catalogs. For most covered equipment, however, 

DOE does not require manufacturers to report the average value (mean) to demonstrate 

compliance with standards. Instead, for metrics in which the customer prefers a larger value, 
2-33

DOE requires manufacturers to report the smaller of either the sample mean itself or the result of 

a compliance equation that accounts for variation within the sample set. While reporting 

requirements for HID lamps are not yet established, DOE is considering such requirements in the 

ongoing HID lamp test procedure rulemaking. DOE intends to consider these reporting 

requirements by setting standards that take into account the output of such a compliance 

equation. DOE invites comment on whether an adjustment to the CSLs is needed to account for 

the reporting requirements and other sources of variation. 

2.7.5 HID Lamp System 

In this rulemaking, DOE is considering standards for only HID lamps. HID lamps, 

however, are just one component of an HID lighting system. HID lamps require a ballast to 

regulate the current and power supplied to the lamp. The lamp-and-ballast system is then housed 

in an HID lamp fixture to protect the components, enable the system to be mounted in the desired 

location, and direct the light to the target area. When considering changes to HID lamps, DOE 

recognizes the importance of also analyzing the impact on both the ballast and the fixture. 

Because HID lamps require a ballast to operate, DOE pairs each representative HID lamp 

with a representative ballast to develop representative lamp-and-ballast systems. Through catalog 

review and manufacturer interviews, DOE learned that a new ballast is generally required when 

an HID lamp is replaced with a more efficacious substitute. Generally, this is because the more 

efficacious substitute lamp will have a lower wattage or different technology or starting method. 

DOE has found that the performance characteristics of a ballast, most importantly ballast 

efficiency, change with wattage and lamp technology to be driven. Therefore, to properly 

identify an energy conservation standard’s impact on system performance, the correct ballast 

needs to be paired with each representative lamp. For this rulemaking, DOE assumes that any 

change in lamp wattage or technology necessitates a change in ballast. 

After seeking input from both HID lamp and HID lamp fixture manufacturers, DOE 

determined that changes (wattage and technology) to the lamp-and-ballast system also 

necessitate a change in fixture. This fixture replacement is needed because replacement lampand-ballast systems will likely be a different size than the existing, preventing the new system 

from fitting in the existing fixture. Even if the new system could physically fit in the fixture, the 

changes in lamp and ballast may reduce the optical efficiency. Although a change in fixture does 

not impact lamp efficacy or system energy use, the cost of a new fixture impacts the total 

installation cost of a more efficacious system, which is considered in the LCC and NIA analyses. 

See section 2.8 for information on how DOE calculated fixture prices. See chapter 5 of the 

interim TSD for additional detail on the HID lamp system. 

DOE requests comment on the ballast types and ballast efficiencies chosen for each lamp 

type to calculate lamp-and-ballast system energy use.

2.7.6 Scaling Between Equipment Classes 

As discussed earlier, DOE focused its analysis on certain representative equipment 

classes. DOE then extrapolated the findings from those representative classes to other equipment 

classes that were not directly analyzed. To determine efficacy levels for other equipment classes, 
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DOE calculated scaling factors based on relationships observed in catalog data. To develop 

relationships between clear and coated bulb finish, enclosed and open luminaire characteristic, 

and >2800 K to ≤4500 K and >4500 K to <7000 K CCT, DOE identified pairs of lamps where 

the only difference between the lamps was the parameter under consideration for scaling. For 

example, to identify the scaling factor between clear lamps and coated lamps, DOE identified 

pairs of lamps within two equipment classes that were manufactured by the same manufacturer, 

within the same family, and differed only by bulb finish. DOE calculated the percentage 

difference in initial efficacy for each of these pairs. When analyzing bulb finish and luminaire 

characteristic, DOE determined that the difference in efficacy did not depend on wattage or any 

other lamp characteristic. Therefore, DOE calculated the average efficacy difference of all 

available pairs to determine the appropriate scaling factor. When analyzing the relationship 

between >2800 K to ≤4500 K and >4500 K to <7000 K, the data exhibited more variation across 

lamp wattage but the overall trend was inconclusive. Therefore, like the other scaling factors, 

DOE calculated the average efficacy difference of all available pairs to determine the appropriate 

scaling factor. DOE requests comment on the methodology and results of this scaling analysis 

and, in particular, whether the scaling factor between these CCT ranges should be a function of 

wattage. DOE also requests a technical description of why such a trend between wattage and 

efficacy difference might exist between CCT ranges. 

More details about the scaling methodology, as well as the results of the analysis, can be 

found in chapter 5 of this interim TSD. In addition, DOE requests any comments pertaining to 

the methodology and results of the engineering analysis. 

2.8 EQUIPMENT PRICE DETERMINATION 

As mentioned in the discussion of the engineering analysis in section 2.7, DOE 

developed equipment prices for HID lamps, ballasts, and fixtures. DOE estimated end-user 

prices for HID lamps by establishing discounts off manufacturer suggested price lists (hereafter 

“blue book prices”). For ballasts and fixtures, DOE developed an MSP by estimating the material 

and labor cost of production and applying a manufacturer markup to account for non-production 

costs and profit. Sections 2.8.1 and 2.8.2 describe these methods in more detail. 

2.8.1 HID Lamps 

Typically, DOE develops MSPs for covered equipment and uses the prices as an input to 

the LCC analysis and NIA. Because HID lamps are difficult to reverse-engineer (i.e., not easily 

disassembled; arc tube salts and fill gas are hard to assess), DOE derived end-user prices for the 

lamps covered in this rulemaking. In its review of publicly-available prices, DOE observed a 

range of end-user prices paid for a lamp, depending on the distribution channel through which it 

is purchased. In line with its observation of public pricing, DOE developed three sets of 

discounts from the blue-book prices, representing low (State procurement), medium (electrical 

distributors), and high (Internet retailers) lamp prices for HID lamps. Starting with a consistent 

set of aggregated blue-book prices, DOE calculated an average discount ratio for each end-user. 

DOE found the discount did not vary with wattage or lamp technology, and therefore applied a 

single discount for all lamps to estimate end-user prices. For the representative lamps for which 

blue-book prices were unavailable, DOE extrapolated pricing from lamps whose blue-book 

prices were available. This was done by using the blue-book prices of similar lamps from an 
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alternative manufacturer or by interpolating between blue-book prices of lamps with different 

wattages within the same lamp family. DOE invites comment on its methodology and results for 

estimating end-user prices for HID lamps. 

2.8.2 HID Ballasts and Fixtures 

DOE understands that an energy conservation standard that requires higher-efficacy, 

reduced-wattage lamps may require customers to purchase a new ballast and fixture. Therefore, 

DOE also developed prices for the HID ballasts and fixtures used with the representative HID 

lamps. Developing the MSPs for different ballasts and fixtures involved two main inputs, a 

teardown analysis to develop the manufacturer production costs (MPCs) and a markup analysis 

to arrive at the MSPs. 

DOE performed teardown analyses of MH ballasts and fixtures to estimate the MPCs. 

DOE also was able to use teardown data from the metal halide lamp fixtures energy conservation 

standard preliminary analysis because of the similarity in manufacturers and covered equipment. 

76 FR 18127 (April 1, 2011). To estimate the MPCs for HPS and MV ballasts, DOE applied the 

average discount between the MH ballast MPCs and MH ballast blue-book values to the HPS 

and MV ballast blue-book values. 

DOE did not perform direct teardowns of HPS and MV fixtures. Instead, in light of 

feedback from interviews of HID fixture manufacturers and fixture data sheets,24 DOE assumed 

that the MPCs of HPS and MV fixtures were equivalent to comparable MHLFs. Because MV 

fixtures are generally used in similar applications as MHLFs, DOE used the same MPCs for MV 

fixtures and MHLFs of the same wattage. Similarly, because HPS fixtures are typically used in 

outdoor applications, DOE used only the MPCs of MH fixtures used in outdoor applications. 

To markup the ballast and fixture MPCs to MSPs, DOE estimated a manufacturer markup 

multiplier. This markup accounts for the non-production costs and profit. For the interim 

analysis, DOE assumed the same manufacturer markup for MV, HPS, and MH ballasts and a 

separate manufacturer markup for MV, HPS, and MH fixtures. These three technologies are 

typically manufactured by the same companies and often in the same facilities. DOE 

preliminarily determined that the manufacturer markups derived as part of the MHLF rulemaking 

process were applicable to all ballasts and fixtures considered in the HID lamp rulemaking. 

DOE invites comment on its methodology and results for estimating MSPs for HID 

ballasts and fixtures, as well as any other comments pertaining to the equipment price 

determination. For more information on DOE’s equipment price determination for HID lamps, 

ballasts, and fixtures, see chapter 6 of the interim TSD. 

2.9 MARKUPS ANALYSIS 

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

relate MSPs to end-user prices for lamps.25 For the interim analysis, DOE estimated price 

 

24 Fixture datasheets frequently cross list a single fixture for multiple lamp technologies. 

25 Lamp MSPs will be required for the MIA to be performed in the NOPR stage of this rulemaking, DOE will 

estimate a price markup to relate the low end-user prices for HID lamps to the MSPs used as MIA inputs. 
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markups to calculate end-user prices from MSPs for HID ballasts and fixtures in the LCC and 

PBP analysis. Although HID lamps are the covered equipment in this rulemaking, DOE 

considered the prices of HID ballasts and fixtures because almost all higher-efficacy HID lamps 

are assumed to require a new ballast or a new fixture (with a new ballast). 

Consistent with the approach in the MHLF energy conservation standards rulemaking, 

DOE estimated a weighted average baseline markup for HID ballasts and fixtures, reflecting 

estimated proportions of equipment sold through different distribution channels, involving 

electrical wholesalers (distributors), contractors, and/or direct sales. For the interim analysis, 

DOE used economic data for publicly traded electrical wholesalers and national sales tax data to 

estimate overall markups for HID ballasts and fixtures. DOE applied only baseline markups to 

the ballast and fixture MSPs, because DOE does not expect the cost structure for this ancillary 

equipment to vary with efficacy levels for HID lamps. Therefore, incremental markups were not 

used to develop end-user prices for HID ballasts and fixtures. For more detail on the markups 

analysis, see chapter 7 of this TSD. 

2.10 ENERGY USE ANALYSIS 

The purpose of the energy use analysis is to estimate the energy usage in the baseline and 

higher-efficacy lamps considered in this rulemaking. This analysis, which is meant to represent 

typical energy usage in the field, is an input to both the LCC and PBP analysis and the NIA. For 

HID lamps, energy use is derived by multiplying the system input power value (ballast input 

power) by the annual operating hours. DOE used data from manufacturer catalogs for ballast 

input power values (as described in the engineering analysis) and data from the 2010 U.S. 

Lighting Market Characterization26 to estimate distributions of operating hours in the 

commercial, industrial, and outdoor stationary sectors. 

For more detail on the energy use analysis, see chapter 8 of this TSD. 

2.11 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

The effects of new energy conservation standards on customers include a change in 

operating expense (usually decreased electricity expenses) and a change in purchase price 

(usually increased). The LCC of equipment is the cost it incurs over its lifetime, taking into 

account both purchase price and operating expenses. The PBP represents the time it takes to 

recover the additional installed cost of the more efficacious equipment through annual operatingcost savings. DOE analyzes the net effect on customers by calculating the LCC and PBP using 

the engineering performance data, the energy use analysis data, and the markups analysis. Inputs 

to the LCC calculation include the installed cost to the customer (purchase price plus installation 

cost), operating expenses, the lifetime of the equipment or another defined period of analysis, 

and a discount rate. Inputs to the PBP calculation include the installed cost to the customer and 

annual operating costs. 

 

26 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Final Report: 2010 U.S. 

Lighting Market Characterization. 2012. Washington, D.C. 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 
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For the interim analysis, DOE conducted the LCC and PBP analysis using typical values 

to reflect conditions in the field for equipment retail price and life, energy costs, energy usage, 

and discount rates. For the NOPR stage of this rulemaking, DOE plans to conduct the LCC and 

PBP analysis by modeling both the uncertainty and the variability in selected inputs using Monte 

Carlo simulation and probability distributions. For more detail on the LCC and PBP analysis, see 

chapter 9 of this TSD. 

2.12 SHIPMENTS ANALYSIS 

Projections of equipment shipments are needed to calculate the national effects of 

standards on energy use, NPV, and future manufacturer cash flows. DOE developed shipment 

projections based on an analysis of key market drivers for each considered HID lamp type. In 

DOE’s shipments model, shipments of equipment are driven by new construction, stock 

replacements, and other types of purchases. 

The shipments model takes an accounting approach, tracking market shares of each 

equipment class and the vintage of units in the existing stock. Stock accounting uses equipment 

shipments as inputs to estimate the age distribution of in-service equipment stocks for all years. 

The age distribution of in-service equipment stocks is a key input to calculations of both the NES 

and the NPV, because operating costs for any year depend on the age distribution of the stock. 

For more detail on the shipments analysis, see chapter 10 of this TSD. 

2.13 NATIONAL IMPACT ANALYSIS 

The NIA assesses cumulative NES and the cumulative national economic impacts of 

efficacy levels considered for the equipment classes analyzed. The analysis measures economic 

impacts using the NPV metric, which presents total customer costs and savings expected to result 

from new standards at specific efficacy levels, discounted to their present value. For a given 

efficacy level, DOE calculates the NPV, as well as the NES, as the difference between a baseline 

projection and the standards-case projections. Chapter 11 of this TSD describes DOE’s 

assessment of the aggregate economic impacts at the national level. 

2.13.1 National Energy Savings Analysis 

The five inputs for determining NES are (1) annual energy consumption per unit; 

(2) shipments; (3) stock; (4) national energy consumption (calculated from consumption per unit 

and equipment stock); and (5) site-to-source conversion factors. DOE calculated the national 

energy consumption by multiplying the number of units, or stock, of HID lamps by the unit 

energy consumption. Then, DOE calculated national annual energy savings from the difference 

between national energy consumption in the base case (without efficacy standards) and in each 

higher-efficacy standards case. Cumulative energy savings are the sum of the annual NES, which 

DOE determined over the analysis period. 

2.13.2 Net Present Value Analysis 

DOE calculates the national NPV of the customer savings resulting from energy 

conservation standards in conjunction with the NES. DOE calculates annual energy expenditures 
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from annual energy use by incorporating projected energy prices, using the shipments from the 

shipments analysis. DOE calculates annual equipment expenditures by multiplying the installed 

costs per HID fixture by the projected shipments. The difference between a base-case and a 

standards-case scenario gives the national energy bill savings and increased equipment 

expenditure in dollars. The difference each year between projected energy bill savings and 

increased equipment expenditures is the net savings (if positive) or net costs (if negative). DOE 

discounted these annual values to the present time and summed them to provide NPVs at 3 

percent and 7 percent discount rates. Because the national cost of capital may differ from the 

customer cost of capital, the discount rate used in the NIA is different from the rate used in the 

LCC. The national average aggregates the different costs of capital, while the customer cost of 

capital is more applicable to subsets of customers. In accordance with U.S. Office of 

Management and Budget (OMB) guidance, 27 DOE conducted two NPV calculations, one using a 

real discount rate of 3 percent and another using a real discount rate of 7 percent. 

2.14 CUSTOMER SUBGROUP ANALYSIS 

The customer subgroup analysis evaluates economic impacts on selected groups of 

customers. At the NOPR stage of this rulemaking, DOE will conduct the customer subgroup 

analysis and divide customers into subgroups accounting for variations in key inputs to the LCC 

analysis. A customer subgroup comprises a subset of the population more likely to be affected 

disproportionately by energy conservation standards (e.g., small businesses or firms that use HID 

lamps in particular applications where energy savings are likely to be small). The purpose of a 

subgroup analysis is to determine the extent of any such disproportionate effect. DOE will work 

with industry and other interested parties early in the rulemaking process to identify any 

subgroups for consideration. 

In comparing potential effects on the different customer subgroups, DOE will evaluate 

variations in regional electricity prices, usage profiles, and installation costs that might affect 

LCC and PBP for certain customer subgroups under potential energy conservation standards. To 

the extent possible, DOE will obtain estimates of the variability in each input and consider this 

variability when calculating effects on customers. DOE will discuss this variability with 

interested parties and likely sources of information. 

For more detail on the approach to the customer subgroup analysis, see chapter 12 of this 

TSD.

2.15 MANUFACTURER IMPACT ANALYSIS 

The purpose of the MIA is to identify the likely impacts of higher energy conservation 

standards on manufacturers. DOE will conduct this analysis with input from manufacturers and 

other interested parties. DOE will apply this methodology to its evaluation of standards for HID 

lamps. DOE will consider 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 HID lamps. DOE will identify and 

 

27 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 
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discuss these impacts in interviews with manufacturers and other interested parties during the 

NOPR stage of the analysis. 

DOE intends to 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.

In this interim analysis, DOE evaluates and reports preliminary MIA information at this 

interim analytical phase. DOE gathered the information for the analysis during the manufacturer 

interviews conducted after the engineering analysis. See chapter 13 of the interim TSD for more 

detail on the MIA. 

2.15.1 Sources of Information for the Manufacturer Impact Analysis 

The MIA uses outputs from other upstream analyses (such as the engineering analysis, 

the NIA, and the markup analysis) and develops its own inputs based on publically available 

information, such as 10-Ks, and refines these inputs based on manufacturer interviews. These 

analyses provide important inputs into the MIA, including the number of shipments, the 

manufacturer production costs, and the markups for each product. DOE will supplement this 

information with company financial data and other information gathered and/or refined during 

interviews with manufacturers to estimate the industry financial parameters, such as the tax rate, 

research and development (R&D) and capital expenditures, depreciation, and industry discount 

rate. 

DOE aggregates information across manufacturers, creating a combined industry opinion 

or estimate. The interview process plays a key role in the MIA. 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 efficacy 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. 

2.15.2 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 industry. 

The GRIM analysis uses several inputs to determine industry annual cash flows with and 

without new energy conservation standards. These inputs include shipments, production costs, 

product markups, conversion costs for higher efficacy standards, and industry financial 

parameters. DOE then compares the results if more efficient standards are mandated against the 
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base case projections that involve no new energy conservation standards. The financial impact of 

new energy conservation standards is the difference between the two sets of discounted industry 

annual cash flows. Other performance metrics, such as return on invested capital, are also 

available from the GRIM. See chapter 13 of the interim TSD for more information on the 

industry cash flow analysis. 

2.15.3 Direct Employment Impact Analysis 

The impact of new energy conservation standards on employment is an important 

consideration in the rulemaking process. Manufacturer interviews play a significant role in 

assessing how domestic employment patterns might be impacted by new conservation standards. 

DOE explores current employment trends in the HID lamp industry and solicits feedback from 

manufacturers on changes in employment patterns that may result from increased standard 

levels. See chapter 13 of this TSD for more information on the direct employment impact 

analysis. 

2.15.4 Manufacturer Subgroup Analysis 

Average industry impacts may not adequately show differential impacts among 

subgroups of manufacturers that have different cost structures or operate with different 

regulatory frameworks. 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. One common subgroup identified is small 

business manufacturers. Should DOE determine this rulemaking may have a significant impact 

on a substantial number of small business manufacturers, DOE will conduct a regulatory 

flexibility analysis pursuant to the Regulatory Flexibility Act. (5 U.S.C. 601 et seq.) 

During the interview process, DOE discusses 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 13 of the 

interim TSD for more detail on the manufacturer subgroup analysis. 

2.15.5 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, possible impacts of any lessening of competition. (42 U.S.C. 

6295(o)(2)(B)(ii)) 

The manufacturer interviews focus on gathering information that would help in assessing 

asymmetrical cost increases to some manufacturers, increased proportion of fixed costs 

potentially escalating business risks, and potential barriers to market entry (e.g., proprietary 

technologies, limited access to resources). 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 
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competition. DOE will publish the Attorney General’s letter and address any related comments 

in the final rule. 

2.15.6 Cumulative Regulatory Burden 

Other regulations may apply to the HID lamps covered under this rulemaking, and to 

other equipment produced by HID lamp manufacturers. DOE recognizes that multiple 

regulations could result in a significant, cumulative regulatory burden on manufacturers. DOE’s 

initial analysis of regulations affecting HID lamps is located in the market and technology 

assessment (chapter 3 of the interim TSD). During the NOPR, DOE plans to investigate the 

regulations manufacturers mentioned in interviews and the public meeting, and will further 

analyze and consider the impact of multiple, equipment-specific regulatory actions on HID lamp 

manufacturers. 

2.15.7 Interim Results for the Manufacturer Impact Analysis 

One important aspect of the interim MIA is the opportunity it creates for DOE to identify 

key manufacturer issues early in the evaluation of new energy conservation standards. During 

preliminary interviews, manufacturers identified four major areas of concern: (1) energy savings 

from replacement HID lamps, (2) testing burden, (3) technology shift, and (4) product 

innovation. 

2.15.7.1 Energy Savings from Replacement HID Lamps 

Some manufacturers expressed doubt that new energy conservation standards for HID 

lamps would realize significant energy savings in the replacement HID lamp market. Because 

HID ballasts and fixtures typically work with only one lamp type and lamp wattage, customers 

cannot simply replace a failed lamp with a reduced wattage lamp or different kind of HID lamp. 

Instead, some manufacturers argued, customers would install wattage-equivalent lamps and 

accept high lumen output (given more efficacious lamps) to avoid the high costs of replacing the 

ballast and/or fixture. 

2.15.7.2 Testing Burden 

Several manufacturers expressed concern over the testing burden associated with a new 

efficacy standard for HID lamps. Manufacturers stated that there are already numerous testing 

requirements for compliance and certification and a new HID lamps standard would add another 

standard to test for and meet. This could force manufacturers to increase the size of their current 

test laboratories and the number of man-hours associated with compliance testing. Additionally, 

the increase in the number of hours of testing would increase manufacturers’ electricity bill. 

2.15.7.3 Technology Shift 

Apart from this rulemaking or other standards related to HID lamps, manufacturers 

reported that a technological shift is already occurring away from HID lighting in general. 

According to manufacturers, LED and fluorescent technologies are capturing significant market 

share of new construction in both indoor and outdoor applications. Manufacturers are concerned 
2-42

that standards will accelerate this migration to alternative technologies due to potential price 

increases resulting from new energy conservation standards for HID lamps. 

2.15.7.4 Product Innovation 

Manufacturers expressed concern that this HID lamps rulemaking could force resources 

away from the R&D of more efficient lighting products, such as LEDs, in order to spend time 

and money on a product with diminishing market share. Manufacturers would then be forced to 

reallocate resources away from LEDs to make potentially more expensive changes to HID lamps 

that could end up driving customers into the LED market. 

2.16 EMPLOYMENT IMPACT ANALYSIS 

DOE considers employment impacts in the domestic economy as one factor in selecting a 

standard. Employment impacts consist of direct and indirect impacts. Direct employment 

impacts—which are considered in the manufacturer impact analysis—are any changes in the 

number of employees working for manufacturers of the equipment that are the subject of this 

rulemaking, their suppliers, and related service firms. Indirect employment impacts—the subject 

of the employment impact analysis—are changes in employment within the larger economy that 

occur from the shift in expenditures and capital investment caused by the purchase and operation 

of more efficient equipment. 

At the NOPR stage of this rulemaking, DOE will estimate indirect national employment 

impacts using an input-output (I–O) model of the U.S. economy called Impact of Sector Energy 

Technologies (ImSET), version 3.1.1. The ImSET model characterizes economic flows among 

187 sectors most relevant to industrial, commercial, and residential building energy use. DOE 

will estimate changes in expenditures using the NIA spreadsheet. Using ImSET, DOE will 

estimate the net national, indirect employment impacts by sector of potential new efficiency 

standards for HID lamps. The MIA will address the direct employment impacts that concern HID 

lamp manufacturers, as described in section 2.15.

For more detail on the employment impact analysis, see chapter 14 of this TSD. 

2.17 UTILITY IMPACT ANALYSIS 

The utility impact analysis includes an analysis of the impact of higher energy 

conservation standards on the electric utility industry, and will be conducted at the NOPR stage 

of this rulemaking. DOE adapted the U.S. Energy Information Administration’s (EIA’s) National 

Energy Modeling System (NEMS) for this analysis. NEMS is a large, multi-sector, generalequilibrium model of the U.S. energy sector that has been developed over the past decade by 

EIA, primarily for preparing DOE’s Annual Energy Outlook (AEO). In prior rulemakings, a 

variant of NEMS (currently titled NEMS-BT, BT referring to the DOE’s Building Technologies 

Program) was developed to better address the specific impacts of an equipment efficiency 

standard. 

NEMS produces a widely recognized baseline energy projection for the United States 

through the year 2035, and is available in the public domain. The typical NEMS outputs include 

projections of electricity sales, prices, and avoided electric generating capacity. 
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DOE will conduct the utility impact analysis as a scenario departing from the latest 

reference case, generated by NEMS-BT. In the standards case, energy use is reduced by the 

amount of energy saved (by fuel type) from each considered standard level. The inputs of 

national energy savings come from the NIA spreadsheet model, while the output is the electricity 

generation and generating capacity. The utility impact analysis is discussed in more detail in 

chapter 15 of this TSD. 

2.18 EMISSIONS ANALYSIS 

At the NOPR stage of this rulemaking, DOE will estimate the reduction in power sector 

emissions of carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2) and mercury 

(Hg) from potential energy conservation standards for the considered products. In addition, DOE 

will estimate emissions impacts in production activities (extracting, processing, and transporting 

fuels) that provide the energy inputs to power plants. These are referred to as “upstream” 

emissions. Together, these emissions account for the full-fuel-cycle (FFC). In accordance with 

DOE’s FFC Statement of Policy (76 FR 51282 (Aug. 18, 2011)), the FFC analysis includes 

impacts on emissions of methane and nitrous oxide, both of which are recognized as greenhouse 

gases. 

DOE will conduct the emissions analysis using emissions factors derived from data in the 

latest version of EIA’s Annual Energy Outlook, supplemented by data from other sources. EIA 

prepares the Annual Energy Outlook using NEMS. Each annual version of NEMS incorporates 

the projected impacts of existing air quality regulations on emissions. The text below refers to 

AEO2012. 

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs. 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. were also limited under the Clean Air 

Interstate Rule (CAIR), which created an allowance-based trading program that operates along 

with the Title IV program in those States and D.C. 70 FR 25162 (May 12, 2005). CAIR was 

remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit), but it remains in effect. See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); 

North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2011 EPA issued a 

replacement for CAIR, the Cross-State Air Pollution Rule (CSAPR; also known as the Transport 

Rule). 76 FR 48208 (August 8, 2011). The AEO2012 NEMS assumes the implementation of the 

CSAPR.28

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, 

 

28 On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told EPA 

to continue administering CAIR (see EME Homer City Generation v. EPA, No. 11-1302, Slip Op. at *2 (D.C. Cir. 

Dec. 30, 2011)). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court again ordered 

EPA to continue administering CAIR. AEO2012 had been finalized prior to this decision, however. DOE 

understands that CAIR and CSAPR are similar with respect to their effect on emissions impacts of energy efficiency 

standards. 
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any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about 

the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that no reductions in power sector emissions would occur for SO2 as a 

result of standards. 

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a standard for HCl 

as a surrogate for acid gas hazardous air pollutants (HAP), and also established a standard for 

SO2 (a non-HAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The 

same controls are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will be 

reduced as a result of the control technologies installed on coal-fired power plants to comply 

with the MATS requirements for acid gas. AEO2012 assumes that, in order to continue 

operating, coal plants must have either flue gas desulfurization or dry sorbent injection systems 

installed by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when electricity 

demand decreases (e.g., as a result of energy efficiency standards). Emissions will be far below 

the cap that would be established by CSAPR, so it is unlikely that excess SO2 emissions 

allowances resulting from the lower electricity demand would be needed or used to permit 

offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE believes that 

efficiency standards will reduce SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX emissions in eastern States and the District of 

Columbia. Energy conservation standards are expected to have little or no physical effect on 

these emissions in those States covered by CSAPR because excess NOx emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases in NOx

emissions. However, standards would be expected to reduce NOx emissions in the States not 

affected by CSAPR. Therefore, DOE estimates NOX emissions reductions from potential 

standards in the States where emissions are not capped. 

The MATS limit mercury emissions from power plants, but they do not include emissions 

caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. 

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for 

reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM. 

For more detail on the emissions analysis, see chapter 16 of this TSD. 
2-45

2.19 MONETIZATION OF EMISSION REDUCTION BENEFITS 

At the NOPR stage of this rulemaking, DOE plans to consider the estimated monetary 

benefits likely to result from the reduced emissions of CO2 and NOx 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 interim analysis, the most recent interagency estimates of the potential 

global benefits resulting from reduced CO2 emissions in 2015, expressed in 2012$, were $6.2, 

$25.9, $41.7, and $79.1 per metric ton avoided. For emissions reductions that occur in later 

years, these values grow in real terms over time. Additionally, the interagency group determined 

that a range of values from 7 percent to 23 percent should be used to adjust the global SCC to 

calculate domestic effects, 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 GHGs 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, from $468 to $4,809 per ton in 2012$).29 In accordance 

with 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.30

DOE is investigating appropriate valuations of Hg emissions. Whether monetization of 

reduced Hg emissions will occur in this rulemaking is not yet certain. 

See chapter 17 of this TSD for more detail on the monetization of emission reductions 

benefits. 

 

29 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. 

30 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
2-46

2.20 REGULATORY IMPACT ANALYSIS 

As part of the NOPR stage of this rulemaking, DOE will prepare an RIA under Executive 

Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993), which will be 

subject to review under the Executive Order by the OMB Office of Information and Regulatory 

Affairs. The RIA will evaluate non-regulatory alternatives to standards, in terms of their ability 

to achieve significant energy savings in the considered equipment at a reasonable cost, and 

compare the effectiveness of each regulatory alternative to the effectiveness of the adopted 

standards. 

DOE recognizes that voluntary or 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 will consider the likely effects of non-regulatory 

initiatives on equipment energy use, customer utility, and LCC. DOE will base its assessment on 

the actual impacts of any such initiatives to date, but will also consider information presented 

regarding the impacts that any existing initiative might have in the future. 

See chapter 18 of this TSD for more detail on the regulatory impact analysis.