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 SCO PE ............................................................................................................................. 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 -322- 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 -302- iii

Table 2.7.3 Representative Equipment Class Candidate Standard Levels ................................ 2-322-1 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

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

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

a nalyses 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.

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

a nother. Although F igure 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

a dversely 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 dete rmine lamp-and-ballast system power ratings

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

re presentative HID lamps and manufacturer selling prices their associated ballasts and

fix tures

 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

im pact 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

ope rating 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 lowe r

ope rating costs

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

a nalysis 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

fr om a new efficacy standard2-4

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

g roups 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

a nd 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

c apacity and the generating base of electric utilities

 An emissions analysis to provide estimates of the effects of energy conservation
standa rds on emissions of carbon dioxide (CO 2 ), sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), 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
Othe r 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 pr ovisions 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

re quirements 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 determination 2 on 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 NO PR 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/232-6

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

EPC A 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

p otential, 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
manuf acturer interviews. For HID lamp availability, DOE obtained quantitative information from lamp catalogs of 14 different manufacturers. DOE also conducted evaluations of

tec hnological 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
sodi um (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, a nd 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/cm 2

High intensity discharge lamps include mercury vapor, metal halide, and high-pressure
sodi um lamps. (42 U.S.C. 6291(46))

M ercury 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
b y 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

c ombination 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 6,6 7 0 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

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

li ght, 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

a vailable 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

a vailable 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

a t low wattages does not suggest significant potential energy savings. Similarly at high wattages,
the sma ll number of available lamp models combined with their low operating hours, provid es 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

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

c onsistent with the preliminary approach in the energy conservation standards rulemaking for

meta l halide lamp fixtures (MHLFs). 5

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

W and ≤1 000 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 ≤1 000

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 ar e 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

a pplication. 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

re present significant potential energy savings. Therefore, DOE is not considering energy conservation standards for high-CCT lamps (with a CCT ≥7000 K).

I n 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 ≥2 800 K and <7000 K. Lamp catalogs show a large number of lamp offerings in these

ra nges, 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) (7 6 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

pe rcent 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
make s 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

ope ration 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 selfba llasted models, but HPS lamps are not. In reviewing catalogs, DOE found that less than one

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

fr om 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 customer s 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
thi s 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

ope rated 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

c an operate on an electronic ballast as well. When a manufacturer develops a new lamp with a rated wattage that is already included in ANSI C78.43-2007 7 or ANSI C78.44-2008 8 standards, the lamp will be compatible with the magnetic ballast specifications reported on the ANSI
da tasheets. 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 th e 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

w attage, 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+C78.44:20082- 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

a chieve 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 establish ed a minimum efficacy standard for HPS lamps that would exceed the efficacy of high-CRI HPS lamps, there is the possibi lity that the market could shift to the unregulated, high-CRI HPS lamps. While highC RI HPS lamps would provide reduced light output for a given wattage, customers may prefer the hig h-CRI HPS lamps due to the possibility of the unregulated lamp being offered at a lower

c ost (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

a nd 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
int erim analysis.

DO E 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 wit h 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

e stablished a minimum efficacy standard for MH lamps that exceed ed 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 substitut e 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

c ould require a purchase of a new pulse-start ballast and fixture. Because of their small market2- 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

a dvertised 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
of ferings. This small market share indicates a lack of potential for significant energy savings. DOE is considering identifying and def in in g 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

a nd 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

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

f or 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

spec ialty 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

a n 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/cm 2 ; (2) the light-producing arc is stabilized by the arc tube walltemperature; (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 en ergy conservation standards for MH lamps with a

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

a nd ≤1 000 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.

DO E is considering excluding directional HID lamps, self-ballasted HID lamps, HID lamps designed and labeled for use with electronic ballasts only, pul se -start MH lamps with CRI ≥95, colored MH lamps (CRI less than 40), MV lamps intended for specialty applications, and

e lectrodeless lamps from standards in this interim analysis.

As discusse d in more detail in section s 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.

DO E 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,

a nd input wattage as potential metrics.

I nitial 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 wit h 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

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

e fficacy. For these reasons, DOE does not plan to use mean lamp efficacy as the metric for
de fining energy conservation standards.

W attage 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

re quires 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

pr ograms, 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

C ommission [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
manuf acturers: 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
Elec trical Manufacturers Association (NEMA), a trade association that represents electrical

pr oduct manufacturers, including HID lamp manufacturers. NEMA provides an organizational framework for manufacturers of lighting products to work together on projects that affect their
indus try 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
rule making 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 the se lamps are currently in plac e 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
de velopments in the lighting market. Chapter 3 of the interim TSD discusses these regulatory

pr ograms and initiatives in additional detail and presents a summary of non-regulatory programs
that a ffect 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

pr oposed, 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

H ID 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

ex cluding 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 (se e 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
be lieves 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 inter im 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

Ye ar 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
thi s 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
int erested 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 the2- 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

e fficacy of HID lamps.

2.5.2.1 Mercury Vapor Lamps

MV ba llasts, 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

e ffectively 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 hig her 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

c hanging 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 technolo gy

.

2.5.2.3 Metal Halide Lamps

DO E 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,

c eramic 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
la mp. 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 en ergy, 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

a dditional 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

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

DO E 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

se paration 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

pr eliminarily 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 lampcatalog 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

C CT  2800 K and  4500 K has a maximum efficacy of about 100 lm/W , a nd a 250 W lamp with a CCT >4500 K and <7000 K has a maximum efficacy of about 76 lm/W.

B ecause 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

c ustomers 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 R ange

 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
incr eased 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
standa rds. 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

pa rt because it serves the dual role of identifying which ballasts can be paired with the lamp. A s2- 21

a result, and for the additional reasons discussed below, DOE considered establishing separate equipment classes based on wattage.

H ID 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 throug h 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

a nd 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 R ange 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

a pply 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,

DO E 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

c omment 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

c omparing 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.

DO E 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 classes2- 23

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

summ arized in Table 2.5 .4

.

Table 2.5. 4 Equipment Classes Based on Bulb Finish

CCT R ange 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

e nclosed-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

a ny 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
labe led 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 C7 8.380 -2007 definition of open-rated: “Lamp may be used in an open
lu minaire. The effective antic UV output of the lamp shall not exceed 2 mW/klm for a non-reflector lamp or 2 mW/(m 2

∙ 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 C7 8. 3 80 -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/(m 2

∙ 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/(m 2

∙ 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 th ose 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
remai ning the same or similar, DOE determined that enclosed-rated MH lamps are more

e fficacious 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

ope n 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 ≤4 00 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, subpa rt 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 th e 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

sa pphire arc tube technology meets the criteria of the screening analysis. For a complete
discussi on of the screening analysis, refer to c hapter 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

e quipment price determination. By combining the results of the engineering analysis and the

e quipment 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 analysi s:

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

e quipment 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

a nd 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.

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

tec hnology, if it is determined that this technology meets the screening criteria described in
section 2.6.

B ecause customers typically are unable or unwilling to change fixture spacing within their facilities and spaces, DOE is analyzing more efficacious substitutes that maintain mean
lu mens 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 maintain2- 28

overall light output. Mean lumens are a measure of light output midway 18 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

c omply 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
int erim TSD), DOE created equipment classes based on CCT, wattage, bulb finish, and luminaire

c haracteristic, 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 K 21 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  2 8 00

K  50 W and

 1000 W Clear Enclosed Representative Equipment Class

Open Scaled

Coated Enclosed Scaled

Open Scaled

 2 8 0 0 K and  4500

K  50 W and

 4 00 W Clear Enclosed Representative Equipment Class

Open Scaled

Coated Enclosed Scaled

Open Scaled

 4 0 0 W and

 1000 W Clear Enclosed Representative Equipment Class

Open Scaled

Coated Enclosed Scaled

Open Scaled

 100 0 W and

 2000 W Clear Enclosed Representative Equipment Class

Open Scaled

Coated Enclosed Scaled

Open Scaled

 450 0 K and  7000

K  50 W and

 4 00 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

 4 0 0 W and

 1000 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

 100 0 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 .” The2- 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 le ast 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

tec hnology. For this reason, DOE selects both an MV lamp and an MH lamp as baselines for

c ertain representative lamp types in the >2800 K and ≤4500 K equipment classes. DOE welcomes comment on the baseline lamps selected.

T able 2.7. 2 Representative Lamp Types

CCT Range Wattage Bulb Finish Luminaire

Characteristic Baseline

Lamp Type Baseline

Wattage

 1900 K and

 2 8 00 K  50 W and

 1000 W Clear Enclosed HPS 70

HPS 100

HPS 250

HPS 400

HPS 1000

 2 8 0 0 K and

 4500 K  50 W and

 4 00 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

 4 0 0 W and

 1000 W Clear Enclosed MV 1000

Enclosed Probe MH 1000

 100 0 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
lum en output, operating orientation, rated life, CRI, bulb shape, and base type.2- 31

Manufacturers suggested that lamps with universal operating orientation 22 provide value
for the customer. DOE analyzed whether the specified operating orientation of lamp had asignificant impact on efficacy by comparing horizontal position-only, vertical (base-up) positiononl y, and universal-position (when tested in a vertical, base-up position) 23 lamps. DOE found the
da ta reported in catalogs did not provide conclusive evidence of a difference in efficacy. When possi ble, 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 c riteria 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 s everal 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

e ncompass 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
ba selines 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

wa ttage 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) = C oefficient * (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 few er 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

C SL equations set forth in the interim analysis.

Table 2.7. 3 Representative Equipment Class Candidate Standard Levels
CCT Range Wattage Range C SL 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 r eporting 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

re view and manufacturer interviews, DOE learned that a new ballast is generally required when

a n 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
identif y 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

c hange 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

ne cessitate 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,2- 34

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

pa irs 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

c haracteristic, 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

a vailable 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,

DO E 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

a nd, in particular, whether the scaling factor between these CCT ranges should be a function of

wa ttage. DOE also requests a technical description of why such a trend between wattage and

e fficacy 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 , DO E 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 an2- 35

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

tea rdown 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.

DO E 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

a verage 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
mul tiplier. 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.2- 36

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

e stimate 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 Characterization 26 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 torecover 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- 201 2.pdf

.2- 37

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

a nd 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 expenditures2- 38

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

a nalysis 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 subg roups 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
int erested 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 HI D lamps. DOE will identify and

27 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).2- 39

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 base d 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 th en assesses impacts on competition, manufacturing capacity, employment, and regulatory burden based on manufacturer
interview feedback and discussions.

In this interim analysis, DOE evaluat es 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
de tail 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
manuf acturer 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,

re search 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
int erviews 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

c ompetitiveness. 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

a nalyze 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,

pr oduct markups, conversion costs for higher efficacy standards, and industry financial parameters. DOE then compares the results if more efficient standards are mandated against the2- 40

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

ne w 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

a vailable from the GRIM. See chapter 13 of the interim TSD for more information on the
indus try cash flow analysis.

2.15.3 Direct Employment Impact Analysis

The impact of new energy conservation standards on employment is an important

c onsideration in the rulemaking process. Manufacturer interviews play a significant role in

as sessing 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 subg roups of manufacturers that have d ifferent 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
busi ness manufacturers. Should DOE determine this rulemaking may have a significant impact on a substantial number of small business manufacturers, DOE will conduct a regulatory
fle xibility analysis pursuant to the Regulatory Flexibility Act. (5 U.S.C. 601 et seq.)

Dur ing the interview process, DOE discuss es 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 of2- 41

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

re gulations could result in a significant, cumulative regulatory burden on manufacturers. DOE’s

ini tial analysis of regulations affecting HID lamps is located in the market and technology

a ssessment (chapter 3 of the interim TSD). During the NOPR, DOE plans to investigate the

re gulations 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
ke y manufacturer issues early in the evaluation of new energy conservation standards. During

pr eliminary 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
la mps 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

re quirements 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 labor atories 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.

Ac cording to manufacturers, LED and fluorescent technologies are capturing significant market share of new construction in both indoor and outdoor applications. Manufacturers are concerned2- 42

that standards will accelerate this migration to alternative technologies due to potential price
incr eases 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

a way 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

re allocate 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

oc cur 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

Te chnologies (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) NationalEnergy 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.2- 43

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 (CO 2 ), nitrogen oxides (NO X ), sulfur dioxide (SO 2 ) 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

DO E’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

pr epares 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

AEO 2012

.

SO 2 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 SO 2 for affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). SO 2 emissions from 28 eastern states and D.C. 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 N orth 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 AEO 2012 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.2- 44

any excess SO 2 emissions allowances resulting from the lower electricity demand caused by the adoption of an efficiency standard could be used to permit offsetting increases in SO 2 emissions by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about the effects of efficiency standards on SO 2 emissions covered by the existing cap-and-trade system, but it concluded that no reductions in power sector emissions would occur for SO 2 as a result of standards.

Beginning in 2015, however, SO 2 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 F R 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

SO 2 (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, SO 2 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

SO 2 emissions. Under the MATS, NEMS shows a reduction in SO 2 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 SO 2 emissions allowances resulting from the lower electricity demand would be needed or used to permit offsetting increases in SO 2 emissions by any regulated EGU. Therefore, DOE believes that efficiency standards will reduce SO 2 emissions in 2015 and beyond.

CSAPR established a cap on NO X 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 NO

x emissions allowances resulting from the lower electricity demand could be used to permit offsetting increases in NO

x

e missions. However, standards would be expected to reduce NO

x emissions in the States not affected by CSAPR. Therefore, DOE estimates NO X 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 SO 2 and NO

x . The monetary benefits that DOE estimates for
reductions in SO 2 and NO

x 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 CO 2 and NO

x that are expected to result
from each of the standard levels considered.

In order to estimate the monetary value of benefits resulting from reduced emissions of

CO 2 , DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed to by an interagency process. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, 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 CO 2 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 CO 2 emissions. To calculate a present value of the stream of monetary

va lues, DOE will discount the values in each of the four cases using the discount rates that had
been used to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to
the contribution of CO 2 and other 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 NO

x emissions resulting from the standard levels it considers. For NO

x 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 NO

x , 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

Or der 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.