Vol. 78 Tuesday, 

No. 161 August 20, 2013 

Part V 

Department of Energy 

10 CFR Part 431 

Energy Conservation Program: Energy Conservation Standards for Metal 

Halide Lamp Fixtures; Proposed Rule 


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51464 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket Number EERE–2009–BT–STD– 

0018] 

RIN 1904–AC00 

Energy Conservation Program: Energy 

Conservation Standards for Metal 

Halide Lamp Fixtures 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Notice of proposed rulemaking 

(NOPR) and public meeting. 

SUMMARY: The Energy Policy and 

Conservation Act of 1975 (EPCA), as 

amended, prescribes energy 

conservation standards for various 

consumer products and certain 

commercial and industrial equipment, 

including metal halide lamp fixtures. 

EPCA also requires the U.S. Department 

of Energy (DOE) to determine whether 

more-stringent, amended standards 

would be technologically feasible and 

economically justified, and would save 

a significant amount of energy. In this 

notice, DOE proposes amended energy 

conservation standards for metal halide 

lamp fixtures. The notice also 

announces a public meeting to receive 

comments on these proposed standards 

and associated analyses and results. 

DATES: DOE will hold a public meeting 

on Friday, September 27, 2013, from 9 

a.m. to 4 p.m., in Washington, DC. The 

meeting will also be broadcast as a 

webinar. See section VIII, ‘‘Public 

Participation,’’ for webinar registration 

information, participant instructions, 

and information about the capabilities 

available to webinar participants. 

DOE will accept comments, data, and 

information regarding this notice of 

proposed rulemaking (NOPR) before and 

after the public meeting, but no later 

than October 21, 2013. See section, ‘‘VIII 

Public Participation,’’ for details. 

ADDRESSES: The public meeting will be 

held at the U.S. Department of Energy, 

Forrestal Building, Room 8E–089 1000 

Independence Avenue SW., 

Washington, DC 20585. To attend, 

please notify Ms. Brenda Edwards at 

(202) 586–2945. Please note that foreign 

nationals visiting DOE Headquarters are 

subject to advance security screening 

procedures. Any foreign national 

wishing to participate in the meeting 

should advise DOE as soon as possible 

by contacting Ms. Edwards to initiate 

the necessary procedures. Please also 

note that those wishing to bring laptops 

into the Forrestal Building will be 

required to obtain a property pass. 

Visitors should avoid bringing laptops, 

or allow an extra 45 minutes. Persons 

can attend the public meeting via 

webinar. For more information, refer to 

the Public Participation section near the 

end of this notice. 

Any comments submitted must 

identify the NOPR for Energy 

Conservation Standards for metal halide 

lamp fixtures, and provide docket 

number EE–2009–BT–STD–0018 and/or 

regulatory information number (RIN) 

1904–AC00. Comments may be 

submitted using any of the following 

methods: 

1. Federal eRulemaking Portal: 

www.regulations.gov. Follow the 

instructions for submitting comments. 

2. Email: MHLF-2009-STD-0018@

ee.doe.gov. Include the docket number 

and/or RIN in the subject line of the 

message. 

3. Mail: Ms. Brenda Edwards, U.S. 

Department of Energy, Building 

Technologies Program, Mailstop EE–2J, 

1000 Independence Avenue SW., 

Washington, DC 20585–0121. If 

possible, please submit all items on a 

CD. It is not necessary to include 

printed copies. 

4. Hand Delivery/Courier: Ms. Brenda 

Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 

L’Enfant Plaza SW., Suite 600, 

Washington, DC 20024. Telephone: 

(202) 586–2945. If possible, please 

submit all items on a CD, in which case 

it is not necessary to include printed 

copies. 

Written comments regarding the 

burden-hour estimates or other aspects 

of the collection-of-information 

requirements contained in this proposed 

rule may be submitted to Office of 

Energy Efficiency and Renewable 

Energy through the methods listed 

above and by email to Chad_S_

Whiteman@omb.eop.gov. 

For detailed instructions on 

submitting comments and additional 

information on the rulemaking process, 

see section VIII of this document 

(‘‘Public Participation’’). 

Docket: The docket is available for 

review at www.regulations.gov, 

including Federal Register notices, 

framework documents, public meeting 

attendee lists and transcripts, 

comments, and other supporting 

documents/materials. All documents in 

the docket are listed in the 

www.regulations.gov index. However, 

not all documents listed in the index 

may be publicly available, such as 

information that is exempt from public 

disclosure. 

A link to the docket Web page can be 

found at: www1.eere.energy.gov/

buildings/appliance_standards/

product.aspx/productid/49. This Web 

page will contain a link to the docket for 

this notice on the regulations.gov site. 

The regulations.gov Web page will 

contain simple instructions on how to 

access all documents, including public 

comments, in the docket. See section 

VIII for further information on how to 

submit comments through 

www.regulations.gov. 

For further information on how to 

submit a comment, review other public 

comments and the docket, or participate 

in the public meeting, contact Ms. 

Brenda Edwards at (202) 586–2945 or by 

email: brenda.edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: 

Ms. Lucy deButts, U.S. Department of 

Energy, Office of Energy Efficiency 

and Renewable Energy, Building 

Technologies Program, EE–2J, 1000 

Independence Avenue SW., 

Washington, DC 20585–0121. 

Telephone: (202) 287–1604. Email: 

metal_halide_lamp_fixtures@

ee.doe.gov. 

Mr. Ari Altman, U.S. Department of 

Energy, Office of the General Counsel, 

GC–71, 1000 Independence Avenue 

SW., Washington, DC 20585–0121. 

Telephone: (202) 287–6307. Email: 

ari.altman@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Summary of the Proposed Rule 

A. Benefits and Costs to Customers 

B. Impact on Manufacturers 

C. National Benefits 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. History of Standards Rulemaking for 

Metal Halide Lamp Fixtures 

3. Compliance Date 

III. Issues Affecting the Scope of This 

Rulemaking 

A. Additional Metal Halide Lamp Fixtures 

for Which DOE Is Proposing Standards 

1. EISA 2007 Exempted Metal Halide Lamp 

Fixtures 

a. Fixtures With Regulated-Lag Ballasts 

b. Fixtures With 480 V Electronic Ballasts 

c. Exempted 150 W Fixtures 

2. Additional Rated Lamp Wattages 

3. General Lighting 

4. Summary 

B. Alternative Approaches to Energy 

Conservation Standards: System 

Approaches 

1. Lamp-Ballast System 

2. Fixtures Systems—Lamp, Ballast, 

Optics, and Enclosure 

3. California Title 20 Approach 

C. Combined Rulemakings 

D. Standby Mode and Off Mode Energy 

Consumption Standards 

IV. General Discussion 

A. Test Procedures 

1. Current Test Procedures 

2. Test Input Voltage 


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1For editorial reasons, upon codification in the 

U.S. Code, Part B was redesignated Part A. 

a. Average of Tested Efficiency at all 

Possible Voltages 

b. Posting the Highest and Lowest 

Efficiencies 

c. Test at Single Manufacturer-Declared 

Voltage 

d. Test at Highest-Rated Voltage 

e. Test on Input Voltage Based on Wattage 

and Available Voltages 

3. Testing Electronic Ballasts 

4. Rounding Requirements 

B. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible 

Levels 

C. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

D. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Manufacturers and 

Customers 

b. Life-Cycle Costs 

c. Energy Savings 

d. Lessening of Utility or Performance of 

Products 

e. Impact of Any Lessening of Competition 

f. Need for National Energy Conservation 

g. Other Factors 

2. Rebuttable Presumption 

V. Methodology and Discussion 

A. Market and Technology Assessment 

1. General 

2. Equipment Classes 

a. Input Voltage 

b. Fixture Application 

c. Electronic Configuration and Circuit 

Type 

d. Lamp Wattage 

e. Number of Lamps 

f. Starting Method 

g. Conclusions 

B. Screening Analysis 

C. Engineering Analysis 

1. Approach 

2. Representative Equipment Classes 

3. Representative Wattages 

4. Representative Fixture Types 

5. Ballast Efficiency Testing 

6. Input Power Representations 

7. Baseline Ballast Models 

a. 70 W Baseline Ballast 

b. 150 W Baseline Ballast 

c. 1000 W Baseline Ballast 

8. Selection of More Efficient Units 

a. Higher-Efficiency Magnetic Ballasts 

b. Electronic Ballasts 

9. Efficiency Levels 

10. Design Standard 

11. Scaling to Equipment Classes Not 

Analyzed 

12. Manufacturer Selling Prices 

a. Manufacturer Production Costs 

b. Incremental Costs for Electronically 

Ballasted Fixtures 

c. Manufacturer Markups 

D. Markups to Determine Equipment Price 

1. Distribution Channels 

2. Estimation of Markups 

3. Summary of Markups 

E. Energy Use Analysis 

F. Life-Cycle Cost and Payback Period 

Analysis 

1. Equipment Cost 

2. Installation Cost 

3. Annual Energy Use 

4. Energy Prices 

5. Energy Price Projections 

6. Replacement Costs 

7. Equipment Lifetime 

8. Discount Rates 

9. Analysis Period 

10. Fixture Purchasing Events 

G. National Impact Analysis—National 

Energy Savings and Net Present Value 

Analysis 

1. Shipments 

a. Historical Shipments 

b. Fixture Stock Projections 

c. Base Case Shipment Scenarios 

d. Standards Case Efficiency Scenarios 

2. Site-to-Source Energy Conversion 

H. Customer Subgroup Analysis 

I. Manufacturer Impact Analysis 

1. Overview 

2. GRIM Analysis and Key Inputs 

a. Manufacturer Production Costs 

b. Base Case Shipment Projections 

c. Standards Case Shipment Projections 

d. Markup Scenarios 

e. Product and Capital Conversion Costs 

3. Discussion of Comments 

a. Compliance Period 

b. Opportunity Cost of Investments 

c. Impact on Competition 

4. Manufacturer Interviews 

a. Ability To Recoup Investments 

b. Efficiency Metric Used 

c. Maintenance of 150 W Exemption 

J. Employment Impact Analysis 

K. Utility Impact Analysis 

L. Emissions Analysis 

M. Monetizing Carbon Dioxide and Other 

Emissions Impacts 

1. Social Cost of Carbon 

a. Monetizing Carbon Dioxide Emissions 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

c. Current Approach and Key Assumptions 

2. Valuation of Other Emissions 

Reductions 

VI. Analytical Results 

A. Trial Standard Levels 

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Individual 

Customers 

a. Life-Cycle Cost and Payback Period 

b. Customer Subgroup Analysis 

c. Rebuttable Presumption Payback 

2. Economic Impacts on Manufacturers 

a. Industry Cash-Flow Analysis Results 

b. Impacts on Employment 

c. Impacts on Manufacturing Capacity 

d. Impacts on Subgroups of Manufacturers 

e. Cumulative Regulatory Burden 

3. National Impact Analysis 

a. Significance of Energy Savings 

b. Net Present Value of Customer Costs and 

Benefits 

c. Impacts on Employment 

4. Impact on Utility or Performance of 

Equipment 

5. Impact of Any Lessening of Competition 

6. Need of the Nation To Conserve Energy 

C. Proposed Standards 

1. Trial Standard Level 5 

2. Trial Standard Level 4 

3. Trial Standard Level 3 

D. Backsliding 

VII. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866 

and 13563 

B. Review Under the Regulatory Flexibility 

Act 

1. Description and Estimated Number of 

Small Entities Regulated 

a. Methodology for Estimating the Number 

of Small Entities 

b. Manufacturer Participation 

c. Metal Halide Ballast and Fixture 

Industry Structure 

d. Comparison Between Large and Small 

Entities 

2. Description and Estimate of Compliance 

Requirements 

3. Duplication, Overlap, and Conflict with 

Other Rules and Regulations 

4. Significant Alternatives to the Proposed 

Rule 

C. Review Under the Paperwork Reduction 

Act 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality 

Bulletin for Peer Review 

VIII. Public Participation 

A. Attendance at the Public Meeting 

B. Procedure for Submitting Prepared 

General Statements For Distribution 

C. Conduct of the Public Meeting 

D. Submission of Comments 

E. Issues on Which DOE Seeks Comment 

IX. Approval of the Office of the Secretary 

I. Summary of the Proposed Rule 

Title III, Part B1 of the Energy Policy 

and Conservation Act of 1975 (EPCA or 

the Act), Public Law 94–163 (42 U.S.C. 

6291–6309, as codified), established the 

Energy Conservation Program for 

Consumer Products Other Than 

Automobiles. Pursuant to EPCA, any 

new or amended energy conservation 

standard that the U.S. Department of 

Energy (DOE) prescribes for certain 

products, such as metal halide lamp 

fixtures (MHLFs or ‘‘fixtures’’), shall be 

designed to achieve the maximum 

improvement in energy efficiency that is 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, the new or 

amended standard must result in a 

significant conservation of energy. (42 

U.S.C. 6295(o)(3)(B)) In accordance with 

these and other statutory provisions 

discussed in this notice, DOE proposes 

amended energy conservation standards 

for metal halide lamp fixtures. The 

proposed standards, which are the 


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2 DOE is proposing to continue using a ballast 

efficiency metric for regulation of metal halide lamp 

fixtures, rather than a system or other approach. See 

section III.B for further discussion. 

minimum allowable ballast efficiencies 2

based on fixture location, ballast type, 

and rated lamp wattage, are shown in 

Table I.1. 

TABLE I.1—PROPOSED ENERGY CONSERVATION STANDARDS FOR METAL HALIDE LAMP FIXTURES

Equipment 

classes Rated lamp wattage Indoor/outdoor *** Test input voltage † Minimum standard equation % 

1 ................. ≥50 W and ≤100 W ................................ Indoor .............................. 480 V ............................... 99.4/(1 + 2.5 * P∧(¥0.55)) ‡. 

2 ................. ≥50 W and ≤100 W ................................ Indoor .............................. All others ......................... 100/(1 + 2.5 * P∧(¥0.55)). 

3 ................. ≥50 W and ≤100 W ................................ Outdoor ........................... 480 V ............................... 99.4/(1 + 2.5 * P∧(¥0.55)). 

4 ................. ≥50 W and ≤100 W ................................ Outdoor ........................... All others ......................... 100/(1 + 2.5 * P∧(¥0.55)). 

5 ................. >100 W and <150 W * ............................ Indoor .............................. 480 V ............................... 99.4/(1 + 0.36 * P∧(¥0.30)). 

6 ................. >100 W and <150 W * ............................ Indoor .............................. All others ......................... 100/(1 + 0.36 * P∧(¥0.30)). 

7 ................. >100 W and <150 W * ............................ Outdoor ........................... 480 V ............................... 99.4/(1 + 0.36 * P∧(¥0.30)). 

8 ................. >100 W and <150 W * ............................ Outdoor ........................... All others ......................... 100/(1 + 0.36 * P∧(¥0.30)). 

9 ................. ≥150 W ** and ≤250 W .......................... Indoor .............................. 480 V ............................... For ≥150 W and ≤200 W: 

88.0. 

For >200 W and ≤250 W: 6.0 

* 10∧(¥2) * P + 76.0. 

10 ............... ≥150 W ** and ≤250 W .......................... Indoor .............................. All others ......................... For ≥150 W and ≤200 W: 

88.0. 

For >200 W and ≤250 W: 7.0 

* 10∧(¥2) * P + 74.0. 

11 ............... ≥150 W ** and ≤250 W .......................... Outdoor ........................... 480 V ............................... For ≥150 W and ≤200 W: 

88.0. 

For >200 W and ≤250 W: 6.0 

* 10∧(¥2) * P + 76.0. 

12 ............... ≥150 W ** and ≤250 W .......................... Outdoor ........................... All others ......................... For ≥150 W and ≤200 W: 

88.0. 

For >200 W and ≤250 W: 7.0 

* 10∧(¥2) * P + 74.0. 

13 ............... >250 W and ≤500 W .............................. Indoor .............................. 480 V ............................... 91.0. 

14 ............... >250 W and ≤500 W .............................. Indoor .............................. All others ......................... 91.5. 

15 ............... >250 W and ≤500 W .............................. Outdoor ........................... 480 V ............................... 91.0. 

16 ............... >250 W and ≤500 W .............................. Outdoor ........................... All others ......................... 91.5. 

17 ............... >500 W and ≤2000 W ............................ Indoor .............................. 480 V ............................... For >500 W to <1000 W: 

0.994 * (3.2 * 10∧(¥3) * P 

+ 89.9). 

For ≥1000 W to ≤2000 W: 

92.5 and may not utilize a 

probe-start ballast. 

18 ............... >500 W and ≤2000 W ............................ Indoor .............................. All others ......................... For >500 W to <1000 W: 3.2 * 

10∧(¥3) * P + 89.9. 

For ≥1000 W to ≤2000 W: 

93.1 and may not utilize a 

probe-start ballast. 

19 ............... >500 W and ≤2000 W ............................ Outdoor ........................... 480 V ............................... For >500 W to <1000 W: 

0.994 * (3.2 * 10∧(¥3) * P 

+ 89.9). 

For ≥1000 W to ≤2000 W: 

92.5 and may not utilize a 

probe-start ballast. 

20 ............... >500 W and ≤2000 W ............................ Outdoor ........................... All others ......................... For >500 W to <1000 W: 3.2 * 

10∧(¥3) * P + 89.9. 

For ≥1000 W to ≤2000 W: 

93.1 and may not utilize a 

probe-start ballast. 

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified 

by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, 

as specified by Underwriters Laboratories (UL) 1029–2001. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 

50 °C, as specified by UL 1029–2001. 

*** DOE’s proposed definitions for ‘‘indoor’’ and ‘‘outdoor’’ metal halide lamp fixtures are described in section V.A.2. 

† Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 120 

V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these voltages would be 

tested at the highest voltage for which the ballast is designed to operate. ‡P is defined as the rated wattage of the lamp that the fixture is designed to operate. 


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3A metric ton is equivalent to 1.1 short tons. 

Results for CH4, SO2, NOX and Hg are presented in 

short tons. 

4 DOE calculates emissions reductions relative to 

the Annual Energy Outlook (AEO) 2013 Reference 

case, which generally represents current legislation 

and environmental regulations for which 

implementing regulations were available as of 

December 31, 2012. 

5 DOE also estimated CO2 and CO2 equivalent 

(CO2eq) emissions that occur by 2030 (CO2eq 

includes greenhouse gases such as CH4 and N2O). 

The estimated emissions reductions by 2030 are 15– 

17 million metric tons CO2, 1,471–1,627 thousand 

tons CO2eq for CH4, and 63–70 thousand tons 

CO2eq for N2O. 

6 DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg 

emissions before it monetizes Hg in its rulemakings. 

A. Benefits and Costs to Customers 

Table I.2 presents DOE’s evaluation of 

the economic effects of the proposed 

standards on customers of metal halide 

lamp fixtures, as measured by the 

average life-cycle cost (LCC) savings and 

the median payback period (PBP). The 

average LCC savings are positive for a 

majority of users for all equipment 

classes. For example, the estimated 

average LCC savings are approximately 

$30 for fixtures operating a 400 W metal 

halide (MH) lamp in indoor and outdoor 

applications. 

TABLE I.2—IMPACTS OF PROPOSED STANDARDS ON METAL HALIDE LAMP FIXTURE CUSTOMERS

Equipment class 

Average LCC 

savings 

2012$ 

Median payback 

period 

years 

70 W (indoor, magnetic baseline) ................................................................................................................... 38.41 4.2 

70 W (outdoor, magnetic baseline) ................................................................................................................. 46.44 4.4 

150 W (indoor) ................................................................................................................................................. 10.14 4.7 

150 W (outdoor) ............................................................................................................................................... 112.51 10.5 

250 W (indoor) ................................................................................................................................................. 13.12 11.8 

250 W (outdoor) ............................................................................................................................................... 13.75 14.0 

400 W (indoor) ................................................................................................................................................. 28.23 10.5 

400 W (outdoor) ............................................................................................................................................... 30.47 12.3 

1000 W (indoor) ............................................................................................................................................... 502.21 2.0 

1000 W (outdoor) ............................................................................................................................................. 409.02 3.0 

B. Impact on Manufacturers 

The industry net present value (INPV) 

is the sum of the discounted cash flows 

to the industry from the base year 

through the end of the analysis period 

(2013 to 2045). Using a real discount 

rate of 8.9 percent, DOE estimates that 

the INPV for manufacturers of metal 

halide ballasts ranges from $77 million 

in the low shipment-preservation of 

operating profit markup scenario to 

$127 million in the high shipment-flat 

markup scenario in 2012$. Under the 

proposed standards, DOE expects ballast 

manufacturers to lose up to 25.0 percent 

of their INPV, which is approximately 

$25.9 million, in the low shipment,- 

preservation of operating profit markup 

scenario. In the high shipment-flat 

markup scenario, DOE expects 

manufacturers to increase their INPV up 

to 3.7 percent, which is approximately 

$4.5 million. Using a real discount rate 

of 9.5 percent, DOE estimates that the 

INPV for manufacturers of metal halide 

lamp fixtures ranges from $523 million 

in the low shipment-preservation of 

operating profit markup scenario to 

$695 million in the high shipment-flat 

markup scenario in 2012$. Under the 

proposed standards, DOE expects 

fixture manufacturers to lose up to 3.2 

percent of their INPV, which is 

approximately $17.3 million, in the low 

shipment-preservation of operating 

profit markup scenario. In the high 

shipment-flat markup scenario, DOE 

expects manufacturers to increase their 

INPV up to 10.3 percent, which is 

approximately $64.8 million. 

Additionally, based on DOE’s 

interviews with the manufacturers of 

metal halide lamp fixtures, DOE does 

not expect any plant closings or 

significant loss of employment. 

C. National Benefits 

DOE’s analyses indicate that the 

proposed standards would save a 

significant amount of energy. The 

lifetime savings for metal halide lamp 

fixtures purchased in a 30-year period 

(2016–2045) amount to 0.80–1.1 quads. 

The cumulative national net present 

value (NPV) of total customer costs and 

savings of the proposed standards in 

2012$ ranges from $0.95 billion (at a 7- 

percent discount rate) to $3.2 billion (at 

a 3-percent discount rate) for metal 

halide lamp fixtures. This NPV 

expresses the estimated total value of 

future operating-cost savings minus the 

estimated increased equipment costs for 

equipment purchased in 2016–2045, 

discounted to 2013. 

In addition, the proposed standards 

would have significant environmental 

benefits. The energy savings would 

result in cumulative emission 

reductions of 49–65 million metric tons 

(Mt) 3 of carbon dioxide (CO2), 214–289 

thousand tons of methane (CH4), 0.89– 

3.0 thousand tons of nitrous oxide 

(N2O), 65–87 thousand tons of sulfur 

dioxide (SO2), 66–90 thousand tons of 

nitrogen oxides (NOX), and 0.11–0.15 

tons of mercury (Hg).4 5

The value of the CO2 emissions 

reductions is calculated using a range of 

values per metric ton of CO2 (otherwise 

known as the Social Cost of Carbon, or 

SCC) developed by a recent interagency 

process. The derivation of the SCC 

values is discussed in section V.M.1. 

DOE estimates the net present monetary 

value of the CO2 emissions reduction is 

between $0.33 and $4.7 billion, 

expressed in 2012$ and discounted to 

2013. DOE also estimates the net present 

monetary value of the NOX emissions 

reduction, expressed in 2012$ and 

discounted to 2013, is $45 million at a 

7-percent discount rate, and $91 million 

at a 3-percent discount rate.6

Table I.3 summarizes the national 

economic costs and benefits expected to 

result from today’s proposed standards 

for metal halide lamp fixtures. 


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7 DOE used a two-step calculation process to 

convert the time-series of costs and benefits into 

annualized values. First, DOE calculated a present 

value in 2013, the year used for discounting the 

NPV of total customer costs and savings, for the 

time-series of costs and benefits using discount 

rates of 3 and 7 percent for all costs and benefits 

except for the value of CO2 emissions reductions. 

For the latter, DOE used a range of discount rates, 

as shown in Table I.4. From the present value, DOE 

then calculated the fixed annual payment over a 30- 

year period (2016 through 2045) that yields the 

same present value. The fixed annual payment is 

the annualized value. Although DOE calculated 

annualized values, this does not imply that the 

time-series of costs and benefits from which the 

annualized values were determined is a steady 

stream of payments. 

TABLE I.3—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF METAL HALIDE LAMP FIXTURE ENERGY

CONSERVATION STANDARDS (PRIMARY (LOW SHIPMENTS) ESTIMATE) 

Category Present value 

million 2012$ 

Discount rate 

(percent) 

Benefits 

Operating Cost Savings ................................................................................................................................... 1,848 7 

3,748 3 

CO2 Reduction Monetized Value ($12.9/t case) * ........................................................................................... 333 5 

CO2 Reduction Monetized Value ($40.8/t case) * ........................................................................................... 1,532 3 

CO2 Reduction Monetized Value ($62.2/t case) * ........................................................................................... 2,436 2.5 

CO2 Reduction Monetized Value (at $117/t case) * ........................................................................................ 4,689 3 

NOX Reduction Monetized Value (at $2,639/ton) ** ........................................................................................ 45 7 

91 3 

Total Benefits† .......................................................................................................................................... 3,424 7 

5,371 3 

Costs 

Incremental Installed Costs ............................................................................................................................. 897 7 

1,294 3 

Net Benefits 

Including CO2 and NOX Reduction Monetized Value ..................................................................................... 2,528 7 

4,076 3 

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series used by DOE incorporate an escalation factor. 

** The value represents the average of the low and high NOX values used in DOE’s analysis. †Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC value with 3-percent discount rate. 

The benefits and costs of today’s 

proposed standards, for equipment sold 

between 2016 and 2045, can also be 

expressed in terms of annualized values. 

The annualized monetary values are the 

sum of (1) the annualized national 

economic value of the benefits from 

customer operation of equipment that 

meets the proposed standards 

(consisting primarily of operating cost 

savings from using less energy, minus 

increases in equipment purchase and 

installation costs, which is another way 

of representing customer NPV), and (2) 

the annualized monetary value of the 

benefits of emissions reductions, 

including CO2 emissions reductions.7

Although combining the values of 

operating savings and CO2 emissions 

reductions provides a useful 

perspective, two issues should be 

considered. First, the national operating 

savings are domestic U.S. customer 

monetary savings that occur as a result 

of market transactions, while the value 

of CO2 emissions reductions is a global 

value. Second, the assessments of 

operating cost savings and CO2

emissions savings are performed with 

different methods that use different time 

frames for analysis. The national 

operating cost savings is measured for 

the lifetime of metal halide lamp 

fixtures shipped between 2016 and 

2045. The SCC values, on the other 

hand, reflect the present value of some 

future climate-related impacts resulting 

from the emission of 1 ton of CO2 in 

each year. These impacts will continue 

well beyond 2045. 

Estimates of annualized benefits and 

costs of the proposed standards are 

shown in Table I.4. The results under 

the primary estimate are as follows. (All 

monetary values below are expressed in 

2012$.) Using a 7-percent discount rate 

for benefits and costs other than CO2

emissions reductions, for which DOE 

used a 3-percent discount rate along 

with the SCC series corresponding to a 

value of $40.8/ton in 2012$, the cost of 

the standards proposed in today’s rule 

is $68.0 million per year in increased 

equipment costs, while the annualized 

benefits are $139 million per year in 

reduced equipment operating costs, $76 

million in CO2 emissions reductions, 

and $3.4 million in reduced NOX

emissions. In this case, the net benefit 

amounts to $151 million per year. Using 

a 3-percent discount rate for all benefits 

and costs and the SCC series 

corresponding to a value of $40.8/ton in 

2012$, the cost of the standards 

proposed in today’s rule is $64 million 

per year in increased equipment costs, 

while the benefits are $186 million per 

year in reduced operating costs, $76 

million in CO2 emissions reductions, 

and $4.5 million in reduced NOX

emissions. In this case, the net benefit 

amounts to $202 million per year. 


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8For editorial reasons, upon codification in the 

U.S. Code, Part B was redesignated Part A. 

TABLE I.4—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR METAL HALIDE LAMP FIXTURES

Discount rate 

Monetized Values 

[million 2012$/year] 

Primary (low shipments) estimate * High 

estimate * 

Benefits 

Operating Cost Savings ....................................................................... 7% .................................................... 139 ......................... 169 

3% .................................................... 186 ......................... 240 

CO2 Reduction Monetized Value ($12.9/t case) ** ............................... 5% .................................................... 21 ........................... 26 

CO2 Reduction Monetized Value ($40.8/t case) ** ............................... 3% .................................................... 76 ........................... 99 

CO2 Reduction Monetized Value ($62.2/t case) ** ............................... 2.5% ................................................. 114 ......................... 149 

CO2 Reduction Monetized Value $117/t case) ** ................................. 3% .................................................... 232 ......................... 303 

NOX Reduction Monetized Value (at $2,639/ton) ** ............................. 7% .................................................... 3.36 ........................ 4.06 

3% .................................................... 4.49 ........................ 5.76 

Total Benefits† .............................................................................. 7% plus CO2 range ......................... 163 to 375 .............. 200 to 476 

7% .................................................... 218 ......................... 272 

3% .................................................... 266 ......................... 344 

3% plus CO2 range ......................... 211 to 422 .............. 272 to 548 

Costs 

Incremental Equipment Costs .............................................................. 7% .................................................... 68 ........................... 81 

3% .................................................... 64 ........................... 80 

Net Benefits/Costs 

Total † .................................................................................................... 7% plus CO2 range ......................... 96 to 307 ................ 119 to 396 

7% .................................................... 151 ......................... 192 

3% .................................................... 202 ......................... 264 

3% plus CO2 range ......................... 147 to 358 .............. 192 to 468 

* This table presents the annualized costs and benefits associated with fixtures shipped in 2016 and 2045. These results include benefits to 

customers which accrue after 2045 from the fixtures purchased in 2016 to 2045. Costs incurred by manufacturers, some of which may be incurred prior to 2016 in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The 

Low (Primary) and High Estimates utilize forecasts of energy prices from the Energy Information Administration’s 2012 Annual Energy Outlook 

(AEO2013) from the AEO2013 Reference case, with the Low and High Estimates based on projected fixture shipments in the Low Shipments, 

Roll-up and High Shipments, Roll-up scenarios, respectively. In addition, all estimates use incremental equipment costs that reflect a declining 

trend for equipment prices, using AEO price trends (deflators). The derivation and application of price trends for equipment prices is explained in 

section V.F. 

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile 

SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate 

an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount 

rate. In the rows labeled as ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full range of CO2 values. 

DOE has tentatively concluded that 

the proposed standards represent the 

maximum improvement in energy 

efficiency that is technologically 

feasible and economically justified, and 

would result in the significant 

conservation of energy. DOE further 

notes that equipment achieving these 

standard levels are already 

commercially available for at least some, 

if not most, equipment classes covered 

by today’s proposal. Based on the 

analyses described above, DOE has 

tentatively concluded that the benefits 

of the proposed standards to the nation 

(energy savings, positive NPV of 

customer benefits, customer LCC 

savings, and emissions reductions) 

would outweigh the burdens (loss of 

INPV for manufacturers and LCC 

increases for some customers). 

DOE also considered more-stringent 

fixture energy-use levels as trial 

standard levels (TSLs), and is still 

considering them in this rulemaking. 

DOE has tentatively concluded, 

however, that the potential burdens of 

the more-stringent energy-use levels 

would outweigh the projected benefits. 

Based on its consideration of the public 

comments DOE receives in response to 

this notice and related information 

collected and analyzed during the 

course of this rulemaking effort, DOE 

may adopt energy-use levels that are 

either higher or lower than the proposed 

standards, or some combination of 

level(s) that incorporate the proposed 

standards in part. 

II. Introduction 

The following section discusses the 

statutory authority underlying today’s 

proposal, as well as some of the 

historical background related to the 

establishment of standards for metal 

halide lamp fixtures. 

A. Authority 

Title III, Part B of EPCA established 

the Energy Conservation Program for 

Consumer Products Other Than 

Automobiles,8 a program covering most 

major household appliances 

(collectively referred to as ‘‘covered 

products’’). Amendments to EPCA have 

given DOE the authority to regulate the 

energy efficiency of several additional 

kinds of equipment, including certain 

metal halide lamp fixtures, which are 

the subject of this rulemaking. (42 

U.S.C. 6292(a)(19)) EPCA, as amended 

by the Energy Independence and 

Security Act of 2007 (EISA 2007) 

prescribes energy conservation 


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standards for these products (42 U.S.C. 

6295(hh)(1)), and directs DOE to 

conduct a rulemaking to determine 

whether to amend these standards. (42 

U.S.C. 6295(hh)(2)(A)) (DOE notes that 

under 42 U.S.C. 6295(hh)(3)(A), the 

agency must review its already 

established energy conservation 

standards for metal halide lamp fixtures. 

Under this requirement, the next review 

that DOE would need to conduct must 

occur no later than January 1, 2019.) 

Pursuant to EPCA, DOE’s energy 

conservation program for covered 

products consists of four parts: (1) 

Testing; (2) labeling; (3) the 

establishment of Federal energy 

conservation standards; and (4) 

certification and enforcement 

procedures. The Federal Trade 

Commission (FTC) is primarily 

responsible for labeling, and DOE 

implements the remainder of the 

program. Subject to certain criteria and 

conditions, DOE is required to develop 

test procedures to measure the energy 

efficiency, energy use, or estimated 

annual operating cost of each covered 

product. (42 U.S.C. 6293) Manufacturers 

of covered products must use the 

prescribed DOE test procedures as the 

basis for certifying to DOE that their 

products comply with the applicable 

energy conservation standards adopted 

under EPCA and when making 

representations to the public regarding 

the energy use or efficiency of those 

products. (42 U.S.C. 6293(c) and 

6295(s)) Similarly, DOE must use these 

test procedures to determine whether 

the products comply with standards 

adopted pursuant to EPCA. The DOE 

test procedures for metal halide lamp 

fixtures currently appear at title 10 of 

the Code of Federal Regulations (CFR) 

§§ 431.323 and 431.324. 

DOE must follow specific statutory 

criteria for prescribing amended 

standards for covered products. As 

indicated above, any amended standard 

for a covered product must be designed 

to achieve the maximum improvement 

in energy efficiency that is 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, DOE may 

not adopt any standard that would not 

result in the significant conservation of 

energy. (42 U.S.C. 6295(o)(3)) Moreover, 

DOE may not prescribe a standard: (1) 

For certain products, including metal 

halide lamp fixtures, if no test 

procedures have been established for 

the product, or (2) if DOE determines by 

rule that the proposed standard is not 

technologically feasible or economically 

justified. (42 U.S.C. 6295(o)(3)(A)–(B)) 

In deciding whether a proposed 

standard is economically justified, DOE 

must determine whether the benefits of 

the standard exceed its burdens. (42 

U.S.C. 6295(o)(2)(B)(i)) DOE must make 

this determination after receiving 

comments on the proposed standard, 

and by considering, to the greatest 

extent practicable, the following seven 

factors: 

1. The economic impact of the standard on 

manufacturers and consumers of the 

products subject to the standard; 

2. The savings in operating costs 

throughout the estimated average life of the 

covered products in the type (or class) 

compared to any increase in the price, initial 

charges, or maintenance expenses for the 

covered products that are likely to result 

from the imposition of the standard; 

3. The total projected amount of energy, or 

as applicable, water, savings likely to result 

directly from the imposition of the standard; 

4. Any lessening of the utility or the 

performance of the covered products likely to 

result from the imposition of the standard; 

5. The impact of any lessening of 

competition, as determined in writing by the 

Attorney General, that is likely to result from 

the imposition of the standard; 

6. The need for national energy and water 

conservation; and 

7. Other factors the Secretary of Energy 

(Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(I)–(VII)) 

EPCA, as codified, also contains what 

is known as an ‘‘anti-backsliding’’ 

provision, which prevents the Secretary 

from prescribing any amended standard 

that either increases the maximum 

allowable energy use or decreases the 

minimum required energy efficiency of 

a covered product. (42 U.S.C. 

6295(o)(1)) Also, the Secretary may not 

prescribe an amended or new standard 

if interested persons have established by 

a preponderance of evidence that the 

standard is likely to result in the 

unavailability in the United States of 

any covered product type (or class) of 

performance characteristics (including 

reliability), features, sizes, capacities, 

and volumes that are substantially the 

same as those generally available in the 

United States. (42 U.S.C. 6295(o)(4)) 

Further, EPCA, as codified, 

establishes a rebuttable presumption 

that a standard is economically justified 

if the Secretary finds that the additional 

cost to the consumer of purchasing a 

product complying with an energy 

conservation standard level will be less 

than three times the value of the energy 

savings during the first year that the 

consumer will receive as a result of the 

standard, as calculated under the 

applicable test procedures. See 42 

U.S.C. 6295(o)(2)(B)(iii). 

Additionally, 42 U.S.C. 6295(q)(1) 

specifies requirements when 

promulgating a standard for a type or 

class of covered product that has two or 

more subcategories. DOE must specify a 

different standard level than that which 

applies generally to such type or class 

of products for any group of covered 

products that have the same function or 

intended use if DOE determines that 

products within such group (A) 

consume a different kind of energy from 

that consumed by other covered 

products within such type (or class); or 

(B) have a capacity or other 

performance-related feature which other 

products within such type (or class) do 

not have and such feature justifies a 

higher or lower standard. In 

determining whether a performancerelated feature justifies a different 

standard for a group of products, DOE 

must consider such factors as the utility 

to the consumer of the feature and other 

factors DOE deems appropriate. (42 

U.S.C. 6294(q)(1)) Any rule prescribing 

such a standard must include an 

explanation of the basis on which such 

a higher or lower level was established. 

(42 U.S.C. 6295(q)(2)) 

Federal energy conservation 

requirements generally supersede state 

laws or regulations concerning energy 

conservation testing, labeling, 

standards, and enforcement. (42 U.S.C. 

6297(a)–(c)) DOE may, however, grant 

waivers of Federal preemption for 

particular state laws or regulations, in 

accordance with the procedures and 

other provisions set forth under 42 

U.S.C. 6297(d)). 

Finally, pursuant to the amendments 

contained in section 310(3) of EISA 

2007, any final rule for new or amended 

energy conservation standards 

promulgated after July 1, 2010, is 

required to address standby mode and 

off mode energy use. (42 U.S.C. 

6295(gg)(3)) When DOE adopts a 

standard for a covered product after that 

date, it must, if justified by the criteria 

for adoption of standards under EPCA 

(42 U.S.C. 6295(o)), incorporate standby 

mode and off mode energy use into the 

standard, or, if that is not feasible, adopt 

a separate standard for such energy use 

for that product. (42 U.S.C. 

6295(gg)(3)(A)–(B)) DOE’s current test 

procedures and standards for metal 

halide lamp fixtures address standby 

mode and off mode energy use. 

However, in this rulemaking, DOE only 

addresses active mode energy 

consumption as standby and off mode 

energy use are not applicable to the 

proposed scope of coverage. 

DOE has also reviewed this regulation 

pursuant to Executive Order (E.O.) 

13563, issued on January 18, 2011. 76 

FR 3281, (Jan. 21, 2011). E.O. 13563 is 

supplemental to and explicitly reaffirms 

the principles, structures, and 

definitions governing regulatory review 


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Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51471 

established in E.O. 12866. To the extent 

permitted by law, agencies are required 

by E.O. 13563 to: (1) Propose or adopt 

a regulation only upon a reasoned 

determination that its benefits justify its 

costs (recognizing that some benefits 

and costs are difficult to quantify); (2) 

tailor regulations to impose the least 

burden on society, consistent with 

obtaining regulatory objectives, taking 

into account, among other things, and to 

the extent practicable, the costs of 

cumulative regulations; (3) select, in 

choosing among alternative regulatory 

approaches, those approaches that 

maximize net benefits (including 

potential economic, environmental, 

public health and safety, and other 

advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify 

performance objectives, rather than 

specifying the behavior or manner of 

compliance that regulated entities must 

adopt; and (5) identify and assess 

available alternatives to direct 

regulation, including providing 

economic incentives to encourage the 

desired behavior, such as user fees or 

marketable permits, or providing 

information upon which choices can be 

made by the public. 

DOE emphasizes as well that E.O. 

13563 requires agencies ‘‘to use the best 

available techniques to quantify 

anticipated present and future benefits 

and costs as accurately as possible.’’ In 

its guidance, the Office of Information 

and Regulatory Affairs has emphasized 

that such techniques may include 

‘‘identifying changing future 

compliance costs that might result from 

technological innovation or anticipated 

behavioral changes.’’ For the reasons 

stated in the preamble, DOE believes 

that today’s NOPR is consistent with 

these principles, including the 

requirement that, to the extent 

permitted by law, benefits justify costs 

and that net benefits are maximized. 

Consistent with EO 13563, and the 

range of impacts analyzed in this 

rulemaking, the energy efficiency 

standard proposed herein by DOE 

achieves maximum net benefits. 

B. Background 

1. Current Standards 

EISA 2007 prescribed the current 

energy conservation standards for metal 

halide lamp fixtures manufactured on or 

after January 1, 2009. (42 U.S.C. 

6295(hh)(1)) The current standards are 

set forth in Table II.1. EISA 2007 

excludes from the standards: fixtures 

with regulated-lag ballasts, fixtures with 

electronic ballasts that operate at 480 

volts (V); and fixtures that (1) are rated 

only for 150 W lamps; (2) are rated for 

use in wet locations; and (3) contain a 

ballast that is rated to operate at ambient 

air temperatures higher than 50 °C. 

TABLE II.1—FEDERAL ENERGY EFFICIENCY STANDARDS FOR METAL HALIDE LAMP FIXTURES * 

Ballast type Operated lamp rated wattage range 

Minimum 

ballast 

efficiency 

(percent) 

Pulse-start ............................................................................................................ ≥150 and ≤500 W ............................................. 88 

Magnetic Probe-start ............................................................................................ ≥150 and ≤500 W ............................................. 94 

Nonpulse-start Electronic ..................................................................................... ≥150 and ≤250 W ............................................. 90 

Nonpulse-start Electronic ..................................................................................... ≥250 and ≤500 W ............................................. 92 

* (42 U.S.C. 6295(hh)(1)). 

2. History of Standards Rulemaking for 

Metal Halide Lamp Fixtures 

DOE is conducting this rulemaking to 

review and consider amendments to the 

energy conservation standards in effect 

for metal halide lamp fixtures, as 

required under 42 U.S.C. 6295(hh)(2) 

and (4). On December 30, 2009, DOE 

published a notice announcing the 

availability of the framework document, 

‘‘Energy Conservation Standards 

Rulemaking Framework Document for 

Metal Halide Lamp Fixtures,’’ and a 

public meeting to discuss the proposed 

analytical framework for the 

rulemaking. 74 FR 69036. DOE also 

posted the framework document on its 

Web site; this document is available at 

www1.eere.energy.gov/buildings/

appliance_standards/product.aspx/

productid/49. The framework document 

described the procedural and analytical 

approaches that DOE anticipated using 

to evaluate energy conservation 

standards for metal halide lamp fixtures, 

and identified various issues to be 

resolved in conducting this rulemaking. 

DOE held a public meeting on January 

26, 2010, during which it presented the 

contents of the framework document, 

described the analyses it planned to 

conduct during the rulemaking, sought 

comments from interested parties on 

these subjects, and in general, sought to 

inform interested parties about, and 

facilitate their involvement in, the 

rulemaking. At the meeting and during 

the period for commenting on the 

framework document, DOE received 

comments that helped identify and 

resolve issues involved in this 

rulemaking. 

DOE then gathered additional 

information and performed preliminary 

analyses to help develop potential 

energy conservation standards for metal 

halide lamp fixtures. On April 1, 2011, 

DOE published in the Federal Register 

an announcement (the April 2011 

notice) of the availability of the 

preliminary technical support document 

(the preliminary TSD) and of another 

public meeting to discuss and receive 

comments on the following matters: (1) 

The equipment classes DOE planned to 

analyze; (2) the analytical framework, 

models, and tools that DOE was using 

to evaluate standards; (3) the results of 

the preliminary analyses performed by 

DOE; and (4) potential standard levels 

that DOE could consider. 76 FR 1812 

(April 1, 2011). In the April 2011 notice, 

DOE requested comment on issues that 

would affect energy conservation 

standards for metal halide lamp fixtures 

or that DOE should address in this 

notice of proposed rulemaking (NOPR). 

The preliminary TSD is available at 

www1.eere.energy.gov/buildings/

appliance_standards/product.aspx/

productid/49. 

The preliminary TSD summarized the 

activities DOE undertook in developing 

standards for metal halide lamp fixtures, 

and discussed the comments DOE 

received in response to the framework 

document. It also described the 

analytical framework that DOE uses in 

this rulemaking, including a description 

of the methodology, the analytical tools, 

and the relationships among the various 

analyses that are part of the rulemaking. 

The preliminary TSD presented and 

described in detail each analysis DOE 

performed up to that point, including 

descriptions of inputs, sources, 

methodologies, and results. These 

analyses were as follows: 

• A market and technology 

assessment set the scope of this 

rulemaking, identified the potential 

equipment classes for metal halide lamp 


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9 ‘Regulated lag ballast’ means ballasts designed 

to withstand significant line voltage variation with 

minimum wattage variation to the lamp. 10Specifications for ‘‘wet locations’’ are from the 

National Electrical Code 2002, section 410.4(A). 

11Specifications for ballasts that operate at 

ambient air temperatures above 50 °C are found in 

UL 1029–2001. 

12A notation in the form ‘‘ASAP, Public Meeting 

Transcript, No. 33 at p. 24’’ identifies a comment 

that DOE has received and included in the docket 

of this rulemaking. This particular notation refers 

to a comment: (1) Submitted by ASAP during the 

fixtures, characterized the markets for 

this equipment, and reviewed 

techniques and approaches for 

improving their efficiency; 

• A screening analysis reviewed 

technology options to improve the 

efficiency of metal halide lamp fixtures, 

and weighed these options against 

DOE’s four prescribed screening criteria; 

• An engineering analysis estimated 

the manufacturer selling prices (MSPs) 

associated with more energy-efficient 

metal halide lamp fixtures; 

• An energy-use analysis estimated 

the annual energy use of metal halide 

lamp fixtures; 

• A markups analysis converted 

estimated MSPs derived from the 

engineering analysis to customer prices; 

• A life-cycle cost (LCC) analysis 

calculated, for individual customers, the 

discounted savings in operating costs 

throughout the estimated average life of 

the equipment compared to any increase 

in installed costs likely to result directly 

from the imposition of a given standard; 

• A payback period (PBP) analysis 

estimated the amount of time it would 

take individual customers to recover the 

higher purchase expense of more 

energy-efficient products through lower 

operating costs; 

• A shipments analysis estimated 

shipments of metal halide lamp fixtures 

over the time period examined in the 

analysis. This was then used in the 

national impact analysis (NIA); 

• A national impact analysis assessed 

the national energy savings, and the 

national net present value of total 

customer costs and savings, expected to 

result from specific, potential energy 

conservation standards for metal halide 

lamp fixtures; and 

• A preliminary manufacturer impact 

analysis (MIA) began evaluating the 

effects on manufacturers of amended 

efficiency standards. 

The public meeting announced in the 

April 2011 notice took place on April 

18, 2011 (April 2011 public meeting). At 

this meeting, DOE presented the 

methodologies and results of the 

analyses set forth in the preliminary 

TSD. Interested parties discussed the 

following major issues at the public 

meeting: (1) Alternative approaches to 

performance requirements and the 

various related efficiency metrics; (2) 

the possibility of including design 

standards; (3) amendments to the test 

procedures for metal halide ballasts to 

account for multiple input voltages; (4) 

the cost and feasibility of utilizing 

electronic ballasts in metal halide lamp 

fixtures; (5) equipment class divisions; 

(6) overall pricing methodology; (7) 

lamp lifetimes; (8) cumulative 

regulatory burden; (9) shipments; and 

(10) the possibility of merging the metal 

halide lamp fixture and the highintensity discharge (HID) lamp 

rulemakings. This NOPR responds to 

the issues raised in the comments 

received since publication of the April 

2011 notice, including those received at 

the April 2011 public meeting. 

3. Compliance Date 

EPCA, as amended by EISA 2007, 

contains guidelines for the compliance 

date of the standards amended by this 

rulemaking. EPCA requires DOE to 

determine whether to amend the 

standards in effect for metal halide lamp 

fixtures and whether any amended 

standards should apply to additional 

metal halide lamp fixtures. The 

Secretary was directed to publish a final 

rule no later than January 1, 2012 to 

determine whether the energy 

conservation standards established by 

EISA 2007 for metal halide lamp 

fixtures should be amended, with any 

amendment applicable to products 

manufactured after January 1, 2015. (42 

U.S.C. 6295(hh)(2)(B)) 

III. Issues Affecting the Scope of This 

Rulemaking 

A. Additional Metal Halide Lamp 

Fixtures for Which DOE Is Proposing 

Standards 

As noted in section II.B.1, the existing 

energy conservation standards for metal 

halide lamp fixtures are established in 

EPCA through amendments made by 

EISA 2007. (42 U.S.C. 6295(hh)(1)(A)) 

EISA 2007 prescribed energy 

conservation standards for metal halide 

lamp fixtures by setting minimum 

ballast efficiency requirements for 

fixtures manufactured after January 1, 

2009. Currently, coverage is limited to 

certain rated wattages of lamps used in 

metal halide lamp fixtures (150 W to 

500 W). Such fixtures must be equipped 

with a ballast that has a designated 

starting method (pulse-start or probestart) and electronic configuration 

(magnetic or electronic). However, the 

statute excludes from coverage metal 

halide lamp fixtures with regulated-lag 

ballasts,9 electronic ballasts that operate 

at 480 V, and fixtures that: (1) Are rated 

only for 150 W lamps, (2) are rated for 

use in wet locations,10 and (3) contain 

a ballast that is rated to operate at 

ambient air temperatures greater than 50 

°C.11 (42 U.S.C. 6295(hh)(1)(A)). 

In the preliminary TSD, DOE 

requested comment from interested 

parties on the scope of energy 

conservation standards rulemaking for 

metal halide lamp fixtures. DOE 

received several comments related to 

expanding the scope to include fixtures 

exempted by EISA 2007, fixtures 

designed to be operated with additional 

rated lamp wattages, and the definition 

of a general lighting application. 

1. EISA 2007 Exempted Metal Halide 

Lamp Fixtures 

DOE considered expanding its energy 

conservation standards to cover metal 

halide lamp fixtures exempted by EISA 

2007, including fixtures with regulatedlag ballasts; electronic ballasts that 

operate at 480 V; and ballasts that are 

rated only for (1) use with 150 W lamps, 

(2) use in wet locations, and (3) 

operation in ambient air temperatures 

higher than 50 °C. (42 U.S.C. 

6295(hh)(1)(B)) 

Fixtures With Regulated-Lag Ballasts 

In the preliminary analysis, DOE 

tentatively decided to continue the 

exemption for regulated-lag ballasts. 

Through information gathered in 

manufacturer interviews and market 

research, DOE determined that 

regulated-lag ballasts are mainly used 

for specialty applications where line 

voltage variation is large. Regulated-lag 

ballasts are designed to withstand 

significant line voltage variation with 

minimum wattage variation to the lamp, 

which results in an efficiency penalty 

compared to ballasts whose output 

changes more significantly with line 

voltage variation. To be able to 

withstand large variations, regulated-lag 

ballasts are currently designed to be 

significantly larger than standard 

ballasts, and as a result exhibit poor 

efficiency. According to manufacturers 

and market research, EISA 2007’s 

exemption did not lead to a significant 

market shift to regulated-lag ballasts. 

The Appliance Standard Awareness 

Project (ASAP) encouraged DOE to 

consider coverage for regulated-lag 

ballasts. While ASAP stated that they 

understood that regulated-lag ballasts 

may be inherently less efficient, they 

suggested a separate equipment class 

with a lower standard might be more 

appropriate than no standard. They also 

stated that little information about the 

market for regulated-lag ballasts is 

available. (ASAP, Public Meeting 

Transcript, No. 33 at p. 24) 12 DOE 


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public meeting on April 18, 2011; (2) in the 

transcript of that public meeting, document number 

33 in the docket of this rulemaking; and (3) 

appearing on page 24 of the transcript. 

13A notation in the form ‘‘Empower Electronics, 

No. 36 at pp. 3–4’’ identifies a written comment that 

DOE has received and included in the docket of this 

rulemaking. This particular notation refers to a 

comment: (1) Submitted by Empower Electronics; 

(2) in document number 36 of the docket; and (3) 

on pages 3 to 4 of that document. 

conducted additional research on 

regulated-lag ballasts and found none of 

these products available in major 

manufacturers’ catalogs. DOE assumed 

that absence from catalogs indicates a 

very small market share, and concluded 

that there was no potential for 

significant energy savings through 

inclusion of these products in the scope 

of coverage. In addition, DOE continues 

to agree with the preliminary analysis 

that the size and weight of regulated-lag 

ballasts prohibit their use as substitutes 

in traditional applications. For the 

NOPR, DOE proposes to continue 

exempting from energy conservation 

standards fixtures that include 

regulated-lag ballasts and requests 

comment on this proposal. 

Fixtures With 480 V Electronic Ballasts 

In the preliminary analysis, DOE also 

considered continuing the exemption of 

480 V electronic ballasts based on their 

unavailability in the market. In its 

comments, Empower Electronics 

disagreed with the exemption, stating 

that 347 V and 480 V electronic ballasts 

for metal halide lamps are now feasible, 

and suggested that regulations could 

help the maturation of these 

technologies. (Empower Electronics, No. 

36 at pp. 3–4) 13 Following additional 

research for the NOPR, DOE did identify 

one manufacturer of 480 V electronic 

ballasts, but determined that these 

ballasts have a very small market share 

based on their limited availability from 

distributors and only being 

manufactured by one company. 

Therefore, DOE concluded that there is 

no potential for significant energy 

savings and proposes to continue 

exempting fixtures that use 480 V 

electronic ballasts until DOE has an 

opportunity to analyze commercially 

available products. DOE requests 

comment on this proposal. 

Exempted 150 W Fixtures 

In the preliminary analysis, DOE 

considered eliminating the current 

exemption for 150 W outdoor fixtures 

rated for wet and hot locations because 

these products could be made more 

efficient and have the potential for 

significant energy savings. Shipments 

for these exempted 150 W fixtures 

increased in response to the EISA 2007 

regulations (a shift from 175 W fixtures), 

further increasing the potential energy 

savings for regulations targeted at this 

product type. In addition, DOE found 

that many fixtures commonly used 

indoors (high- and low-bay fixtures for 

high-ceiling buildings) meet the hightemperature requirements and have the 

option of being rated for wet locations. 

DOE preliminarily concluded that some 

fixtures used indoors were using the 

exemption designed for outdoor 

fixtures, negating possible energy 

savings for indoor 150 W fixtures. DOE 

requested comment on the impact of 

eliminating the exemption for 150 W 

outdoor fixtures rated for wet and hightemperature locations. 

The National Electrical Manufacturers 

Association (NEMA), Philips Lighting 

Electronics (Philips), and Georgia Power 

commented that the wet-location and 

high-temperature outdoor 150 W fixture 

exemption was created in part to move 

the market from the popular 175 W 

ballast to the 150 W ballast, and lead to 

energy savings through a wattage 

reduction, and therefore does not 

constitute a loophole. (NEMA, No. 34 at 

p. 4; Philips, Public Meeting Transcript, 

No. 33 at pp. 24–25; Georgia Power, No. 

28 at p. 1) NEMA stated that this 

exemption is critical for outdoor 

lighting ballasts because 150 W 

magnetic ballasts cannot meet the 88 

percent EISA 2007 requirement. NEMA 

contended that the power savings 

realized by shifting from 175 W lamps 

to 150 W lamps, and the risk that the 

market would migrate back to 175 W 

without the exemption, far outweigh 

any additional savings generated by 

requiring that 150 W ballasts meet a 

ballast efficiency requirement. (NEMA, 

No. 34 at p. 4) DOE disagrees with 

NEMA that the removal of the 

exemption will result in a shift to 175 

W fixtures. DOE is not required to set 

the standard for 150 W fixtures at or 

above the 88 percent minimum set by 

EISA 2007. Because these fixtures were 

not previously covered, setting a less 

stringent standard than 88 percent 

would not constitute backsliding and 

has the potential to save significant 

energy. DOE would analyze efficiency 

levels for 150 W fixtures according to 

the same criteria it uses for all other 

wattages. Section V.C.9 describes the 

efficiency levels under consideration in 

the NOPR for 150 W fixtures. 

Northwest Energy Efficiency Alliance 

(NEEA) commented that there is no 

reason to continue the exclusion for 

fixtures rated for wet locations and 

ambient temperatures higher than 50 °C. 

If electronic ballasts with their higher 

efficiencies cannot be utilized in these 

fixtures, NEEA suggested placing them 

in a separate class for standards 

purposes rather than excluding them 

from coverage. (NEEA, No. 31 at pp. 1, 

3) ASAP and, in a joint comment, 

Pacific Gas and Electric Company, San 

Diego Gas & Electric, Southern 

California Gas Company, and Southern 

California Edison (hereafter the 

‘‘California Investor-Owned Utilities’’ 

[CA IOUs]) also supported the coverage 

of 150 W fixtures because the exemption 

may have become a loophole. (ASAP, 

Public Meeting Transcript, No. 33 at p. 

23; CA IOUs, No. 32 at p. 1) 

DOE agrees that these 150 W ballasts 

should be covered by this rulemaking 

and notes that the criteria for the scope 

of coverage for this rulemaking is 

defined as technology which is 

technologically feasible, economically 

justified, and has the potential for 

significant energy savings. Because a 

range of ballast efficiencies exist or are 

achievable in commercially available 

ballasts, DOE believes that improving 

the efficiencies of ballasts in 150 W 

fixtures in wet locations and high 

ambient temperatures is technologically 

feasible. DOE’s analysis indicates that 

removing the wet-location and highambient-temperature 150 W fixture 

exemption has the potential for energy 

savings and is economically justified. 

Therefore, in this NOPR, DOE proposes 

to remove the exemption for fixtures 

that are rated only for use with 150 W 

lamps, wet environments, and in 

ambient temperatures greater than 50 °C 

and include these fixtures in the scope 

of coverage. DOE requests comment on 

this proposal. 

2. Additional Rated Lamp Wattages 

During the preliminary analysis, DOE 

considered expanding its coverage of 

energy conservation standards to 

include metal halide lamp fixtures that 

operate lamps rated from 50 W to 150 

W and fixtures that operate lamps rated 

greater than 500 W. DOE’s review of 

ballast manufacturer catalogs (an 

indication of product availability) 

showed many types of metal halide 

ballasts for fixtures operating lamps 

rated outside the currently regulated 

wattage range. The catalogs showed that 

approximately 30 percent (by number of 

products, not by market share) of 

available metal halide ballasts are 

designed for lamps rated less than 150 

W and approximately 13 percent of 

available metal halide ballasts are 

designed for lamps rated greater than 

500 W. Due to the number of ballasts 

outside of the existing scope of 

coverage, DOE believed that there was 

potential for significant energy savings 

and considered including fixtures 

designed to operate lamps with rated 


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14The general lighting application definition 

prescribed by EISA 2007 was previously 

incorporated into the consumer products section 

(10 CFR Part 430), but has not yet been added to 

the commercial and industrial equipment section 

(10 CFR Part 431). 

wattage ≥50 W in the analysis. DOE 

received comment on expanding the 

scope to fixtures that operate lamps 

rated from 50 W to 150 W and fixtures 

that operate lamps rated greater than 

500 W. 

In response to request for comment in 

the preliminary TSD, NEMA suggested 

that there is little energy savings to be 

realized by regulating fixtures for the 50 

W to 150 W range due to their low 

energy usage and the movement of the 

market to the greater than 150 W power 

range. (NEMA, Public Meeting 

Transcript, No. 34 at p. 13) ASAP, 

NEEA, the CA IOUs, Empower 

Electronics, and Progress Energy 

Carolinas supported the expansion of 

scope to the greater than 50 W and less 

than 150 W range discussed in the 

preliminary TSD. (ASAP, Public 

Meeting Transcript, No. 33 at p. 23; 

NEEA, No. 31 at p. 1; CA IOUs, No. 32 

at p. 1; Empower Electronics, No. 36 at 

p. 3; Progress Energy Carolinas, No. 24 

at p. 2) DOE conducted testing within 

the 50 W to 150 W range and identified 

varying efficiencies within a single 

wattage, which suggests that standards 

to improve the least-efficient ballasts are 

technologically feasible. Furthermore, as 

discussed in section VI.B.3, DOE 

determined that standards for this 

wattage range have the potential for 

significant energy savings. Therefore, 

DOE proposes to include fixtures 

designed to operate lamps rated ≥50 W 

and <150 W. 

DOE also received comment on the 

greater than 500 W equipment class. 

Georgia Power stated that regulating 

high wattages (such as 1000 W and 1500 

W) would save little energy at 

significant cost. (Georgia Power, No. 28 

at p. 2) ASAP, NEEA, the CA IOUs, 

Empower Electronics, and Progress 

Energy Carolinas, however, agreed with 

DOE’s preliminary findings and 

supported the expansion of scope to the 

>500 W range discussed in the 

preliminary TSD. (ASAP, Public 

Meeting Transcript, No. 33 at p. 23; 

NEEA, No. 31 at p. 1; CA IOUs, No. 32 

at p. 1; Empower Electronics, No. 36 at 

p. 3; Progress Energy Carolinas, No. 24 

at p. 2) In terms of technological 

feasibility, NEMA stated that the 

ballasts included in high-wattage 

fixtures are already up to 92 percent 

efficient. NEMA took the position that 

because this efficiency is comparable to 

the efficiencies of lower-wattage 

equipment with the highest-grade 

components, it would be difficult, if not 

impossible, to define energy efficiency 

requirements that would result in 

appreciable savings. Still, NEMA 

supported DOE’s determination that 

ballasts greater than 500 W were within 

the scope of DOE’s authority for 

preclusion of ‘‘state-by-state’’ 

rulemaking through preemption 

(NEMA, No. 34 at p. 3) In terms of 

potential for significant energy savings, 

NEMA noted that market estimates for 

greater-than-500–W ballasts are on the 

order of 15 percent, while the total 

energy use for equipment in this power 

range is estimated to be as high as 40 

percent of the total of installed metal 

halide lamp fixtures. Id. 

DOE agrees that the greater-than-500– 

W ballasts have higher efficiencies than 

the lower-wattage equipment. However, 

based on test data, DOE still found a 

range of efficiencies present in 

commercially available ballasts, 

indicating technological feasibility. DOE 

also verified NEMA’s comment that 

these high-wattage products have fewer 

shipments than the lower-wattage 

products included in this rulemaking, 

but they consume more energy per 

installation. DOE’s analysis indicates 

that regulation of these higher wattages 

could be economically justified and has 

the potential for significant energy 

savings. Finally, based on review of 

product catalogs, DOE determined that 

fixtures rated for use with lamps rated 

for wattages greater than 2000 W served 

small-market-share applications like 

graphic arts, ultraviolet curing, and 

scanners. Therefore, DOE proposes not 

to include fixtures rated for wattages 

greater than 2000 W in this rulemaking. 

In summary, because DOE finds 

economic justification and potential 

energy savings in regulating ballasts 

greater than 500 W and less than or 

equal to 2000 W, DOE proposes that 

these fixtures be included in the scope 

of this rulemaking. DOE requests 

comment on this proposal. 

3. General Lighting 

EISA 2007 defines the scope of this 

rulemaking as applying to fixtures used 

in general lighting applications. (42 

U.S.C. 6291(64)) In section 2 of 10 CFR 

Part 430, Subpart A, a general lighting 

application is defined as lighting that 

provides an interior or exterior area 

with overall illumination. DOE is 

proposing to add this definition to 10 

CFR 431.2,14 the section of the CFR that 

relates to commercial and industrial 

equipment. DOE applies this definition 

to determine which lighting 

applications DOE has the authority to 

cover. 

NEMA and OSRAM SYLVANIA (OSI) 

recommended capping the greater-than500 W class at 1000 W because 1000 W 

is the highest wattage used for general 

lighting applications, arguing that DOE 

does not have authority to consider 

higher wattages. (NEMA, No. 34 at pp. 

13–14; OSI, No. 27 at p. 4) OSI also 

commented that metal halide systems 

are also used in specialty applications 

such as stage, theater, television, film, 

solar simulation, airfield, medical/

surgical, microscope, endoscope, video 

projection, display, treatment of skin 

disorders, sports, and automotive. OSI 

recommended that these specialized 

applications be excluded from this 

rulemaking. (OSI, No. 27 at p. 7) 

DOE’s research indicated that there 

are a number of fixtures available for 

general lighting applications above 1000 

W. The primary application of such 

fixtures is outdoor sports lighting, 

which commonly uses metal halide 

ballasts of 1000 W to 2000 W. Because 

sports lighting provides overall 

illumination to an exterior area (playing 

field and stadium), DOE believes sports 

lighting does meet the definition of a 

general lighting application. While DOE 

agrees that some special applications 

listed by OSI do not fit under the 

covered general illumination definition, 

others, such as sports and airfield 

lighting, do provide general 

illumination to an exterior area and are 

covered by this rulemaking. DOE 

requests comment on this proposal. 

4. Summary 

DOE proposes to include metal halide 

lamp fixtures designed to operate 

ballasts rated from 50 W to 2000 W and 

for use in general lighting applications 

in the scope of coverage. EISA 2007 

exempted specific metal halide lamp 

fixtures from regulation. These included 

(a) fixtures that include regulated-lag 

ballasts, (b) fixtures that include 480 V 

electronic metal halide ballasts, and (c) 

fixtures that include lamps rated at 150 

W with ballasts that (1) are rated for use 

in wet locations and (2) contain a ballast 

that is rated to operate at ambient air 

temperatures greater than 50 °C. In this 

rulemaking, DOE proposes to continue 

the exemption for the first two 

categories (regulated-lag ballasts and 

480 V electronic ballasts) but not for the 

third, certain 150 W fixtures. DOE finds 

that regulating these 150 W ballasts 

could provide considerable potential 

energy savings and would be 

economically justifiable. As such, DOE 

proposes that the 150 W ballasts rated 

for use in wet locations and containing 

a ballast that is rated to operate at 

ambient air temperatures greater than 50 

°C be covered in this rulemaking. 


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B. Alternative Approaches to Energy 

Conservation Standards: System 

Approaches 

EISA 2007 requires DOE to set 

standards for metal halide lamp fixtures. 

(42 U.S.C. 6295(hh)(2)) As previously 

stated, although metal halide lamp 

fixtures usually comprise a metal halide 

lamp, a metal halide ballast, and other 

fixture components, EPCA established 

MHLF energy conservation standards by 

setting minimum efficiency 

requirements for only the ballast. For 

the preliminary analysis, DOE 

considered three system approaches as 

alternatives to regulating only ballast 

efficiency. The first was a lamp and 

ballast system approach in which the 

lamp and ballast would be rated 

together in terms of lumens per lampballast system watts. The second was a 

whole fixture system approach in which 

the ballast, lamp, and optics/enclosure 

would all be rated together in terms of 

a fixture-level metric such as Fitted 

Target Efficacy (FTE) or Target Efficacy 

Rating (TER). The third was an 

approach similar to California Title 20, 

which allowed for multiple compliance 

pathways utilizing a combination of 

design standards, ballast efficiency 

standards, and lamp wattage 

requirements. DOE received several 

comments on these three system 

approaches. 

In general, interested parties 

recognized the potential value for 

system approaches over a ballast 

efficiency approach, but also noted 

several limitations related to each 

possible approach. NEEA supported 

systems approaches to rating 

equipment, but did not find any of the 

three specific approaches discussed in 

the preliminary analysis to be 

practicable to implement. (NEEA, No. 

31 at p. 2) Philips stated that, generally, 

NEMA considers the system approach to 

be the preferred approach for any 

rulemaking. (Philips, Public Meeting 

Transcript, No. 33 at p. 32) Philips 

noted that a system approach is an 

extremely complex issue and pointed 

out that there are other metrics beyond 

those that DOE listed as under 

consideration. (Philips, Public Meeting 

Transcript, No. 33 at pp. 36–37) DOE 

found that the three system approaches 

considered in the preliminary TSD have 

the theoretical potential of saving more 

energy than the current ballast-only 

approach, but also have many practical 

limitations. DOE weighed the benefits 

and drawbacks of each system 

approach, but for this rulemaking, DOE 

proposes a ballast-efficiency approach 

consistent with the current EISA 2007 

regulations. DOE discusses each of the 

system approaches in the following 

sections. DOE also discusses the 

possibility of a coordinated metal halide 

lamp fixture and high-intensity 

discharge lamp rulemaking in section 

III.C as an additional approach to 

considering all aspects of the metal 

halide lighting system when considering 

energy conservation standards. 

1. Lamp-Ballast System 

In the lamp-ballast system approach, 

metal halide lamp fixtures would be 

regulated on the basis of a lumens-perwatt metric that assesses the 

performance of the lamp and ballast 

included in the fixture. Fixture 

manufacturers would be required to 

report the system lumens per watt (lm/ 

W) of every lamp and ballast pair 

included in their fixtures. This 

approach has the potential to save more 

energy and allow more design flexibility 

for manufacturers. However, this 

approach is somewhat at odds with 

current fixture sales practices. Fixture 

manufacturers commonly ship fixtures 

with the ballast installed to ensure that 

the fixture is compliant with fire safety 

requirements and meets energy 

conservation standards. There are 

currently no requirements for fixtures to 

be shipped with certain lamps, and in 

general, fixture manufacturers noted 

that few fixtures are sold with lamps, 

giving customers flexibility to choose 

lamps from a variety of manufacturers. 

In a lamp-ballast system approach, 

fixture manufacturers would be required 

to provide fixtures with installed lamps 

and ballasts, and customers would be 

limited to predetermined lamp and 

ballast combinations. 

During preliminary interviews, DOE 

found that there are several metal halide 

ballast manufacturers that do not 

manufacture metal halide lamps. In a 

lamp-ballast system approach, these 

manufacturers could have a competitive 

disadvantage compared with 

manufacturers that manufacture both 

lamps and ballasts. Manufacturers said 

that for fixture manufacturers that are 

not vertically integrated (i.e., fixture 

manufacturers that do not also produce 

lamps and ballasts), sourcing lamp and 

ballast systems is problematic as only a 

few manufacturers have the capability 

to provide them. Non-verticallyintegrated manufacturers also said that 

they would not have the same ability to 

optimize the fixtures as their lamp and 

ballast-manufacturer competitors. Based 

on the concern that some manufacturers 

would be at a disadvantage to their 

vertically integrated competitors and 

that fixtures are typically not shipped 

with lamps, DOE preliminarily 

determined that ballast efficiency was a 

better approach than lamp-ballast 

systems. 

NEMA described the pros and cons of 

a simple lumens-per-watt standard 

based on a lamp-ballast system. NEMA 

stated that this methodology provides 

more technological flexibility and can 

yield overall higher performance by 

including the effect of lamp efficacy. On 

the other hand, NEMA stated that there 

are compatibility issues with operation 

of certain lamp and ballast pairs. While 

some of these compatibility issues 

would be resolved through use of a 

database, that database would require 

management by the industry, which 

represents additional cost and a 

reporting burden if manufacturers are 

required to report on various lamp and 

ballast combinations. It also might 

require manufacturers to transport 

mercury (if DOE mandates that a fixture 

be sold with a lamp). (NEMA, No. 34 at 

p. 5) 

Georgia Power and NEEA commented 

on the practical limitations of a lampballast system approach. Georgia Power 

pointed out that utilities buy lamps and 

fixtures separately and strive to 

minimize the number of lamp types that 

they must stock to use in new and 

existing fixtures. Georgia Power said 

that matching different lamps to 

different ballasts of the same wattage 

would be costly and very confusing. 

Additionally, Georgia Power noted that 

training the installers and relampers 

would be costly and impractical for the 

utilities. (Georgia Power, No. 28 at p. 1) 

NEEA commented that because there is 

no way to control which replacement 

lamps are used after the initial lamp 

fails, real system energy savings may be 

smaller than forecasts that assume an 

equivalent lamp is used as a 

replacement. (NEEA, No. 31 at p. 2) 

With regards to lamp-ballast 

compatibility concerns with a lampballast approach to setting standards, 

OSI commented that lamp and 

electronic ballast manufacturers already 

maintain lists of compatible products, 

indicating a lamp-ballast approach 

would not create additional burden. OSI 

stated that NEMA’s main concern is 

with high-frequency electronic ballasts 

operating high-wattage lamps. As noted 

in section V.C.8, these ballasts can 

create acoustic resonance problems with 

lamps. The issue is further complicated 

by the fact that different lamps have 

different acoustic resonance points. OSI 

noted that NEMA has assembled a task 

force on lamp and electronic ballast 

compatibility issues, and the task force 

is close to finalizing compatibility test 

procedures. Once finalized, each 

manufacturer will conduct testing based 

on the procedure to determine 


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15There are two main calculation methods—one 

for indoor and one for outdoor applications. The 

methods are then customized to each classification. 

compatibility with other products. OSI 

recommended that all electronic metal 

halide ballasts be designed to meet 

existing American National Standards 

Institute (ANSI) standards based on 

magnetic operation. This redesign will 

help assure lamp and ballast 

compatibility. (OSI, No. 27 at p. 7) 

In the preliminary TSD, DOE also 

considered a ‘table of standard lamps’ 

for use in a lamp-ballast system 

standard approach. The use of a table of 

standard lamps would allow for fixture 

performance to be assigned to all 

fixtures, including those not shipped 

with lamps. This table of standard 

lamps would allow for conversion of 

tested ballast efficiency to lumens per 

watt for determination of compliance 

with a lamp-ballast system standard, 

mitigating the potential for lost 

competitive advantage for ballast-only 

manufacturers. NEEA commented that 

they did not agree that a table of 

standard lamps (and a lamp-ballast 

system approach without a table of 

standard lamps) would adequately 

control which replacement lamps are 

used in fixtures. (NEEA, No. 31 at p. 2) 

DOE recognizes these positive and 

negative aspects of the lamp and ballast 

approach (both with and without the 

table of standard lamps) and has 

weighed them carefully and tentatively 

decided not to propose this approach. 

DOE found that a lamp and ballast 

system approach might be burdensome 

due to unresolved compatibility and 

compliance issues related to specifying 

performance of every lamp and ballast 

combination sold. DOE tentatively 

agrees with Georgia Power’s concern 

that some users could need to stock 

multiple lamps for pairing with 

different manufacturers’ ballasts of the 

same wattage, unless they were willing 

to place all of their lamp and ballast 

orders from a single supplier. 

Additionally, once the original lamp 

fails, customers may replace it with a 

lower-efficacy alternative. A lampballast system approach could also 

complicate defining categories and 

classes. In regards to a lamp-ballast 

system approach with a table of 

standard lamps, DOE agrees with NEEA 

that such a table would not address 

customers using less-efficacious 

replacement lamps and does not 

provide an adequate improvement over 

a traditional lamp-ballast system 

approach or a simple ballast efficiency 

approach. Though inclusion of the table 

could be more equitable for ballast-only 

manufacturers, it is still hindered by 

compliance and compatibility issues, 

and would likely result in less energy 

savings than a pure lamp-ballast system 

approach. 

2. Fixtures Systems—Lamp, Ballast, 

Optics, and Enclosure 

For the preliminary TSD, DOE 

analyzed fixture-level metrics by 

conducting independent research and 

interviewing manufacturers. DOE found 

that fixture energy use depends on four 

variables: (1) Lamp efficacy; (2) ballast 

efficiency; (3) light absorption by the 

fixture; and (4) usefulness of light 

emitted by the fixture (direction or light 

distribution pattern). DOE considered 

two alternative metrics to quantify these 

areas of importance, namely FTE and 

TER. DOE drafted the FTE metric for the 

solid-state lighting (SSL) ENERGY 

STAR® program. NEMA, along with its 

luminaire division, developed TER. FTE 

and TER metrics treat each fixtureenergy-use area of importance more 

effectively in some ways than others. 

The FTE metric measures the fixture 

performance by fitting a rectangle to a 

uniform ‘‘pool’’ of light for each fixture, 

then multiplying the lumens delivered 

to this pool by the percent coverage of 

the rectangular target, and dividing the 

result by input watts to the fixture. 

Because FTE was developed for 

roadway and parking lot applications, 

separate algorithms for each respective 

application would need to be calculated 

and verified. As FTE is calculated using 

a rectangular area, a fixture that is 

designed to (1) light a non-rectangular 

area, (2) produce a large amount of 

unlighted area within the rectangle, or 

(3) produce specific light patterns that 

light both a horizontal plane and a 

vertical plane, or even above the fixture, 

will be at a disadvantage. 

TER involves calculating fixture 

efficacy by multiplying the light leaving 

the fixture by the Coefficient of 

Utilization (CU), which factors in the 

distribution of light, room geometry, 

and room surface reflectances. CU 

represents the percentage of rated lamp 

lumens reaching the workplane. The 

calculation of efficacy for TER also takes 

into account lamp and ballast efficiency. 

TER has 22 different types of luminaire 

classifications, each with a different 

TER calculation method and value,15

though every classification is not 

applicable to metal halide lamp fixtures. 

For the preliminary TSD, DOE 

tentatively decided not to implement 

either FTE or TER. DOE found that FTE 

only accounts for light hitting the 

specified test area and does not take into 

account other surfaces that the fixture is 

designed to light. This methodology 

disadvantages fixture types not designed 

to light a uniform, flat, rectangular 

space. DOE tentatively decided not to 

use TER out of concern that certain 

fixtures could fall within multiple 

categories of fixture due to their designs. 

Because of the need for uniformity and 

more simplicity, DOE preliminarily 

found TER unsuitable this rulemaking. 

The following discussion describes the 

comments DOE received about the use 

of these metrics. 

Georgia Power and Progress Energy 

Carolinas suggested that TER and FTE 

were better metrics than the current 

ballast-efficiency metric because they 

address the optical performance of the 

entire fixture, accounting for light 

directionality and losses. (Georgia 

Power, No. 28 at p. 1; Progress Energy 

Carolinas, No. 24 at p. 1) However, 

NEEA commented that it did not believe 

that FTE or TER is appropriate as the 

basis for energy efficiency standards at 

this time. NEEA stated that either 

approach could be used as a design 

optimization framework, but both have 

sufficient drawbacks and lack of field 

implementation experience that render 

them unusable as the basis for a 

minimum efficiency standard. (NEEA, 

No. 31 at p. 2) NEMA agreed with the 

preliminary TSD, stating that because 

this rulemaking covers all types of 

products (e.g., downlights, track 

lighting, industrial highbay/lowbay, 

streetlighting, roadway lighting, 

floodlights, parking lots, parking 

garages), it is challenging to define a 

metric that effectively covers all 

applications without flawed 

assumptions. Specifically, NEMA 

pointed out that none of the metrics 

considered covers equipment that is 

designed to be aimed or tilted. (NEMA, 

No. 34 at p. 6) Both NEEA and Empower 

Electronics also supported DOE’s 

determination from the preliminary TSD 

not to use either FTE or TER. (NEEA, 

No. 31 at p. 2; Empower Electronics, No. 

36 at p. 4) 

Though a fixture-level metric has the 

potential to save the most energy, DOE 

does not believe an approach currently 

exists that adequately assesses the types 

of metal halide lamp fixtures included 

in this rulemaking. Because FTE is 

focused on applications that deliver 

light to a horizontal space and a TER 

standard would require fixture 

classifications that have not yet been 

developed, DOE has determined that 

ballast efficiency is a better approach at 

this time. Therefore, DOE does not find 

fixture-level metrics practicable for 

setting standards for this equipment at 

this time, and proposes not to use a 

system-approach metric in this 

rulemaking. 


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16www.energy.ca.gov/regs/title20/index.html. 

17California’s term ‘metal halide luminaire’ refers 

to the same item as DOE’s ‘metal halide lamp 

fixture.’ 

3. California Title 20 Approach 

California’s Title 20 16 includes 

regulations that aim to reduce energy 

consumption in appliances, including 

metal halide lamp fixtures.17 For metal 

halide lamp fixtures, Title 20 requires 

compliance through one of four primary 

paths: (1) The use of lamps from 

reduced-wattage bins with a minimum 

88 percent efficient ballast; (2) an 

integrated motion sensor and high-low 

control with a minimum 88 percent 

efficient ballast; (3) an integrated 

daylight sensor and high-low control 

(for indoor only) with a minimum 88 

percent efficient ballast; and (4) highefficiency ballasts with a minimum 

efficiency of 90 percent for 150 W to 250 

W lamps or 92 percent for 251 W to 500 

W lamps. In the preliminary TSD, DOE 

requested comment on the 

implementation of a similar approach, 

with multiple options for compliance, 

including the integration of controls. 

Several commenters gave direct 

feedback on the Title 20 approach. 

Energy Solutions supported DOE’s 

consideration of a Title 20 or Title-20- 

like approach. (Energy Solutions, Public 

Meeting Transcript, No. 33 at p. 39) 

NEMA and Acuity Brands Lighting 

(Acuity) stated that although it also adds 

complexity to the associated 

enforcement and reporting, the Title 20 

approach provides flexibility for 

manufacturers and designers. 

Additionally, NEMA and Acuity noted 

that the Title 20 requirement for 336 W 

to 500 W reduced-wattage lamps to 

produce 80 lm/W is not currently 

achievable. Acuity requested that DOE 

not consider these lamp specifications, 

and stated that they have been working 

with the California Energy Commission 

(CEC) to correct that efficacy level. 

(NEMA, No. 34 at p. 6; Acuity, Public 

Meeting Transcript, No. 33 at p. 41) 

NEMA and Philips then addressed 

regulations that consider lamps and 

ballasts simultaneously for analysis, but 

assign performance metrics to each 

component individually. NEMA 

commented that they would support 

regulation that allows for lower ballast 

efficiency requirements in conjunction 

with higher lamp efficacy requirements. 

However, NEMA noted that a 

requirement to ship high-efficacy lamps 

in new fixtures would not prevent 

future replacement of these lamps with 

lower-efficacy alternatives. (NEMA, No. 

34 at p. 5) Philips noted that it is 

possible to specify certain lamps for 

particular fixtures through an 

Underwriters Laboratories (UL) listing. 

Philips explained that if a ballast and a 

fixture are labeled for a particular lamp, 

then that fixture would only keep its UL 

listing when that lamp is used. This 

could mitigate the risk that the type of 

lamp originally packaged with the 

fixture would be replaced with a lessefficacious alternative. Additionally, 

Philips pointed out that for ENERGY 

STAR and fluorescent lamps, NEMA has 

maintained a table of corresponding 

lamp and ballast efficacies so that 

fixture manufacturers can easily select 

compliant products. Philips suggested 

that DOE could create a similar database 

for this rulemaking. (Philips, Public 

Meeting Transcript, No. 33 at pp. 33–34) 

DOE also received many comments on 

the controls and dimming compliance 

pathways of the Title 20 approach. The 

CA IOUs noted that dimming and 

occupancy controls can greatly reduce 

the overall electricity consumption of a 

lighting system. The CA IOUs stated 

that many electronic ballasts in the 150 

W to 575 W range include dimming 

circuitry. (CA IOUs, No. 32 at p. 5) OSI 

agreed that the use of dimming as an 

energy-saving tool is growing. OSI 

clarified that it is actually easier to 

develop an electronic metal halide 

dimming ballast than a magnetic one; 

and the electronic ballast will provide 

more utility for the end user. (OSI, No. 

27 at p. 3) The CA IOUs specifically 

noted that for outdoor fixtures, from a 

public safety standpoint, dimming can 

be prohibitively slow in magnetic 

ballasts. However, there are 

commercially available electronically 

ballasted systems with appropriate 

response times that are much better 

suited for the transition towards fully 

controllable and dimmable fixtures. (CA 

IOUs, No. 32 at p. 5) 

Several commenters provided 

feedback on the relative merits of 

electronic metal halide lamp dimming, 

magnetic metal halide lamp dimming, 

and other lighting technologies like 

fluorescent lighting. OSI explained that 

magnetic ballasts (by using a split 

capacitor) can only provide two light 

levels (bi-level dimming). An electronic 

ballast has a microprocessor to provide 

stepped dimming at programmed levels 

or continuous dimming using a 0 to 10 

V signal. A continuously dimming 

ballast is compatible with daylight 

harvesting, scheduling, building 

management, demand response systems, 

and other processes where dimming is 

desirable. OSI stated that dimming can 

be provided in various applications, 

including outdoor lighting, by replacing 

a magnetic ballast with an electronic 

one with no rewiring needed. (OSI, No. 

27 at p. 3) Progress Energy Carolinas 

stated that bi-level dimming in magnetic 

ballasts has been around for years and 

has a proven track record. Although 

there is an efficacy decrease associated 

with dimming to 50 percent, Progress 

Energy Carolinas concluded that bi-level 

dimming is cost effective. (Progress 

Energy Carolinas, No. 24. at pp. 1–2) 

NEMA stated, however, that the 

incremental cost associated with an 

integrated bi-level dimming control in a 

metal halide lamp fixture can almost 

double the overall fixture cost. By 

contrast, the cost of integrated controls 

for a fluorescent lamp fixture designed 

for the same application requirements 

are about 30 to 40 percent higher than 

without controls, and the controls have 

more functionality due to the instant on 

and continuous dimming capability of 

the fluorescent system. For these 

reasons, NEMA argued that bi-level 

dimming with metal halide lamp 

fixtures is more costly and has less 

functionality than alternative 

technologies. (NEMA, No. 34 at p. 9) 

Next, DOE received several comments 

relating to the applications that 

commonly use dimming, and the 

potential for difficulty in distinguishing 

some of these categories based on 

technical features. NEMA pointed out 

that although dimming metal halide 

lamp fixtures in certain applications 

where there is sporadic or limited 

occupancy (e.g., high-bay and low-bay 

applications for warehousing) can result 

in significant energy reduction, many 

MHLF applications are not well suited 

for bi-level control capabilities, such as 

operations and roadway lighting that 

operates 24 hours per day, 7 days per 

week. (NEMA, No. 34 at p. 9) Progress 

Energy Carolinas also noted that apart 

from dusk-to-dawn photocontrol, 

occupancy sensors will not work for 

street lighting. Progress Energy 

Carolinas stated that street lighting 

would need to be controlled with a 

smart-box type of control. (Progress 

Energy Carolinas, No. 24 at p. 2) Cooper 

Lighting suggested that DOE analyze 

dimming in roadway lighting separately 

from other applications. (Cooper, Public 

Meeting Transcript, No. 33 at p. 40) 

Georgia Power recognized that the 

specifics of which applications can and 

cannot be dimmed, and how to measure 

energy reduction in unmetered 

applications (e.g., roadway lighting 

provided by a utility), will be complex. 

(Georgia Power, No. 28 at p. 1) NEMA 

noted that because DOE cannot 

distinguish products based on 

application type, it is unclear how DOE 

would describe regulatory requirements 

without specifying the use of controls 

based on application characteristics. 


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(NEMA, No. 34 at p. 9) Specifically, 

NEMA also observed that the Title 20 

approach requires differentiation 

between indoor and outdoor products, 

which DOE would have to define based 

on product attributes. (NEMA, No. 34 at 

p. 6) 

Several commenters reported on the 

low percentage of fixtures using the 

controls pathways to compliance for 

California Title 20. Energy Solutions 

and the CA IOUs reported that of the 

chosen compliance pathways recorded 

in the CEC Appliance Database, most 

are either the reduced lamp wattage or 

the ballast efficiency requirement; not 

many report the controls compliance 

pathway. (Energy Solutions, Public 

Meeting Transcript, No. 33 at pp. 39–40; 

CA IOUs, No. 32 at p. 2) Philips 

explained that the controls compliance 

pathway has not been embraced because 

Title 20 requires all pieces of a control 

system to be integral to the fixture. 

Philips urged DOE to consider that a 

simplified approach to controllable 

fixtures would encourage more 

dimming systems and, therefore, more 

energy savings. (Philips Lighting 

Electronics, Public Meeting Transcript, 

No. 33 at p. 40) Similarly, NEMA 

supported the concept of controllable 

fixtures and also suggested that controls 

be separate from the fixture for any 

regulations. NEMA stated that any 

incorporation of controls should be 

technology-neutral, allowing various 

control technologies without requiring 

the control to be integral to the fixture. 

(NEMA, No. 34 at p. 6) 

NEEA expressed concern over any 

forecasted energy savings resulting from 

the implementation of dimming ballasts, 

commenting that the presence of 

controls and the capability of dimming 

are no guarantee of use, and therefore, 

no guarantee of the promised energy 

savings. Consequently, NEEA did not 

agree with a Title 20 approach as part 

of a federal minimum efficiency 

standard. Furthermore, NEEA opposed 

DOE’s adoption of the Title 20 approach 

because California’s regulatory approach 

depends heavily on the existence of its 

Title 24 regulations (which have no 

DOE analog) for compliance and 

enforcement, including verifying the 

installation of the qualifying 

components that would meet the system 

requirements. For these reasons, NEEA 

felt that the Title 20 approach is 

unworkable at the federal level. (NEEA, 

No. 31 at p. 3) 

In response to the various approaches 

in California Title 20, DOE is concerned 

that adopting these methods would risk 

reducing energy savings and 

complicating compliance and 

enforcement relative to ballastefficiency-only regulations. With 

regards to the controls/dimming 

approach, DOE tentatively agrees that a 

standard requiring the presence of 

controls or dimming does not ensure 

energy savings. DOE believes that the 

use of such technologies is much less 

popular for metal halide systems 

relative to other lighting technologies. 

Metal halide lamp fixtures typically take 

5 to 10 minutes to re-strike and turn on 

again after being turned off, so controls 

that would turn metal halide lamp 

fixtures on and off more frequently have 

less utility relative to lighting with 

instant restarting capability. 

Additionally, a majority of metal halide 

lamp fixtures installed today use 

magnetic ballasts. Magnetic ballasts are 

typically only capable of bi-level 

dimming, giving them less functionality 

compared to other lighting technologies. 

Regarding the approach to allow lessefficient ballasts when sold in fixtures 

with more efficacious lamps, DOE is 

concerned that some energy savings 

could be lost if the lamp is replaced 

with a less efficacious lamp after the 

first failure, similar to its conclusions 

with lamp and ballast systems. Given 

the uncertainty of resulting energy 

savings, DOE has tentatively decided 

not to propose Title-20-like standards in 

this rulemaking. 

C. Combined Rulemakings 

In addition to system approaches, 

another method for maximizing energy 

savings and simplifying compliance 

would be to combine the metal halide 

lamp fixture and high-intensity 

discharge (HID) lamp rulemakings 

(Docket EERE–2010–BT–STD–0043). 

These rulemakings are related because 

the MH lamps used in metal halide 

lamp fixtures are a subset of HID lamps. 

During the comment period and the 

public meeting for the metal halide 

lamp fixture preliminary TSD, and also 

in subsequent manufacturer interviews, 

DOE received requests that DOE 

consider metal halide lamp fixtures and 

HID lamps in a combined manner. The 

stated benefits of this approach include 

maximizing potential energy savings, 

avoiding conflicting rules for related 

technologies, avoiding duplicative 

efforts, improving consistency and ease 

of review, saving taxpayer dollars, and 

simplifying compliance. Based on the 

outcome of this NOPR, DOE will 

consider how to best combine the 

rulemakings. 

OSI, NEMA, and Philips commented 

that the metal halide lamp fixture 

rulemaking should be conducted in 

conjunction with metal halide lamp 

rulemakings. (OSI, No. 27 at p. 6; 

NEMA, Public Meeting Transcript, No. 

33 at p. 15; NEMA, No. 34 at p. 5; 

Philips, Public Meeting Transcript, No. 

33 at p. 32) NEMA expressed concern 

that potential energy savings could be 

missed by keeping the metal halide 

lamp fixtures and HID lamps 

rulemakings separate. (NEMA, Public 

Meeting Transcript, No. 33 at p. 15) OSI 

and NEMA recommended that the 

ballast efficiency and lamp efficacy 

regulations be completed in conjunction 

so that overall system efficacy can be 

recognized in resulting regulations. 

(OSI, No. 27 at p. 6; NEMA, No. 34 at 

p. 21) Additionally, Philips stated that 

keeping the lamp and ballast 

rulemakings separate will add 

complexity to maintaining lamp and 

ballast compatibility. (Philips, Public 

Meeting Transcript, No. 33 at p. 32) 

Philips noted that if ballast regulations 

eliminate certain ballast types, they may 

also take certain lamps out of the 

market, losing all energy savings that 

were meant to be generated by the 

lamps’ standards. (Philips, Public 

Meeting Transcript, No. 33 at p. 132) 

In its work to date on the HID lamp 

and MHLF energy conservation 

standards, DOE has identified and is 

using a number of shared data sources 

and analytical processes in the two 

rulemakings. The following is an initial 

inventory of rulemaking data and 

processes either fully or partially shared 

between HID lamps and metal halide 

lamp fixtures: 

• market and technology assessments; 

• distribution channels and price 

markups; 

• annual operating hours; 

• lamp, fixture, and ballast lifetimes; 

• lamp lumen maintenance; 

• installation times and costs; 

• electricity prices; 

• discount rates; 

• lamp and fixture shipments; 

• life-cycle cost (LCC) subgroup 

analysis; and 

• Regulatory impact analysis. 

DOE is currently evaluating the data 

and analytical processes that are shared 

between the two rulemakings. 

D. Standby Mode and Off Mode Energy 

Consumption Standards 

EPCA requires energy conservation 

standards adopted for covered 

equipment after July 1, 2010 to address 

standby mode and off mode energy use. 

(42 U.S.C. 6295(gg)(3)) The requirement 

to incorporate standby mode and off 

mode energy use into the energy 

conservation standards analysis is 

therefore applicable in this rulemaking. 

10 CFR 431.322 defines the terms 

‘‘active mode,’’ ‘‘standby mode,’’ and 

‘‘off mode’’ as follows: 

• ‘‘Active mode’’ is the condition in 

which an energy-using piece of 


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18The definition of ‘‘off mode’’ requires that 

ballasts be connected to a main power source and 

not provide any standby mode or active mode 

function. (42 U.S.C. 6295(gg)(1)(A)(ii)) As discussed 

in the metal halide ballast test procedures, DOE 

does not believe that there is any condition in 

which the ballast is connected to the main power 

source and is not already accounted for in either 

active mode or standby mode. 

equipment is connected to a main 

power source, has been activated, and 

provides one or more main functions. 

• ‘‘Off mode’’ is the condition in 

which an energy-using piece of 

equipment is connected to a main 

power source, and is not providing any 

standby or active mode function. 

• ‘‘Standby mode’’ is 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. 

For the preliminary TSD, DOE 

analyzed these definitions to determine 

their applicability to metal halide lamp 

fixtures. DOE tentatively found that it is 

possible for metal halide fixtures to 

operate in active mode and standby 

mode. The off mode condition does not 

apply because metal halide lamp 

fixtures do not operate in off mode. 74 

FR 33171, 33175 (July 10, 2009).18

Therefore, for this energy conservation 

standard rulemaking, DOE only 

considered the active mode and standby 

mode energy use provisions from EISA 

2007 applicable to metal halide lamp 

fixtures that are (or could be) covered by 

this rulemaking. 

DOE recognizes that metal halide 

lamp fixtures can be designed with 

auxiliary control devices, which could 

consume energy in standby mode. One 

example of this fixture design involves 

Digitally Addressable Light Interface 

(DALI) enabled ballasts. These ballasts 

may draw power in standby mode, as 

the internal circuitry remains on and 

active even when the ballast is not 

driving any lamps. DOE has yet to 

encounter such a ballast that it could 

purchase. DOE has continued to search 

for and consider DALI-enabled fixtures, 

as well as other types of metal halide 

lamp fixtures, to evaluate the issue of 

standby mode energy use in metal 

halide lamp fixtures. In the preliminary 

TSD, DOE tentatively concluded that it 

cannot establish a separate standard that 

incorporates standby mode energy use 

and invited comments on the issue of 

standby mode and ballast designs that 

incorporate it. 

Philips and NEMA both expressed 

NEMA’s view, agreeing that a standard 

cannot be established for standby mode 

energy consumption. (Philips, Public 

Meeting Transcript, No. 33 at p. 29, 

NEMA, No. 34 at p. 3) Empower 

Electronics also commented that a 

standby mode energy standard cannot 

be established. (Empower Electronics, 

No. 36 at p. 2) NEEA agreed with DOE’s 

findings and proposals for standby 

mode and off mode. (NEEA, No. 31 at 

p. 2) 

With no new findings with regard to 

ballasts drawing power in standby and 

off modes and comments supporting 

DOE’s preliminary proposal, DOE 

continues to conclude in this NOPR that 

it cannot establish a separate standard 

that incorporates standby mode or off 

mode energy consumption. 

IV. General Discussion 

A. Test Procedures 

1. Current Test Procedures 

The current test procedures for metal 

halide ballasts and fixtures are outlined 

in Subpart S of 10 CFR Part 431. The 

test conditions, setup, and methodology 

generally follow the guidance of ANSI 

C82.6–2005. Testing requires the use of 

a reference lamp, which is to be driven 

by the ballast under test conditions until 

the ballast reaches operational stability. 

Ballast efficiency for the fixture is then 

calculated as the measured ballast 

output power divided by the ballast 

input power. In this NOPR, DOE 

proposes changes to test input voltage, 

testing electronic ballasts, and rounding 

requirements. 

2. Test Input Voltage 

Metal halide ballasts can be operated 

at a variety of voltages, with different 

voltages chosen based on the 

application and use of the fixture. The 

most common voltages are 120 V, 208 V, 

240 V, 277 V, and 480 V. Ballasts will 

also commonly be rated for more than 

one, such as dual-input-voltage ballasts 

that can be operated on 120 V or 277 V, 

or quad-input-voltage ballasts that can 

be operated on 120 V, 208 V, 240 V, or 

277 V. DOE received manufacturer 

feedback that the specific design of a 

ballast and the voltage of the lamp 

operated by the ballast can affect the 

trend between input voltage and 

efficiency. DOE likewise observed that 

changes in efficiency (on the level of 

several percent) were possible in 

individual ballasts based on its own 

testing of multiple-input-voltage 

ballasts. 

The existing test procedures do not 

specify the voltage at which a ballast is 

to be tested. Therefore, to ensure 

consistency among testing and reported 

efficiencies, the input voltage should be 

specified in the test procedures. To set 

an energy conservation standard based 

on test data, DOE needed to determine 

which input voltage to use for its data. 

In addition, manufacturers would need 

to their equipment at the same input 

voltage that DOE used when developing 

energy conservation standards for the 

regulations to have the intended effect. 

Because the majority of ballasts sold are 

capable of operating at multiple input 

voltages, DOE is considering 

standardizing this aspect of testing. In 

the preliminary TSD, DOE requested 

comment on this issue, specifically on 

the possibility of testing at all input 

voltages and reporting the average of the 

efficiencies. DOE discusses several 

input voltage specification options in 

the following paragraphs. 

a. Average of Tested Efficiency at All 

Possible Voltages 

In the preliminary TSD, DOE asked 

for comment on the possibility of testing 

ballasts at each input voltage at which 

they are able to operate, then having a 

standard for the average of these 

efficiencies. NEEA commented that they 

saw the positive aspects of this method 

of testing. NEEA said that even though 

it would increase testing burden, it 

would also reduce efficiency bias 

associated with input voltage. (NEEA, 

No. 31 at p. 2) Philips commented that 

adapting a magnetic ballast for use with 

multiple input voltages lowers the 

efficiencies on one or more of the 

voltages, but the market has demanded 

the use of multi-tap ballasts, especially 

because the manufacturers desire to 

reduce inventory in an effort to lower 

cost. (Philips, Public Meeting 

Transcript, No. 33 at p. 28) NEMA said 

it disagreed with measuring at multiple 

voltages and then averaging due to the 

increased testing burden and associated 

costs. (NEMA, No. 34 at p. 2) Although 

DOE found little difference in ballast 

efficiency at different input voltages, 

DOE recognizes the possibility for 

efficiencies associated with rarely used 

input voltages to skew the overall 

efficiency of ballasts under this 

averaged-efficiencies approach. For 

example, a ballast might have the 

capability to operate on 120 V and 277 

V at approximately 90 percent 

efficiency, but at 208 V (an uncommon 

input voltage for metal halide lighting) 

it operated at only 88 percent efficiency. 

Averaging these three efficiencies would 

lead to a reported value of about 89 

percent, when the ballast will in all 


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19At the time of development of this NOPR in 

mid-2012, an update to ANSI C82.6–2005 was not 

yet available. 

likelihood only operate at 120 V or 277 

V (at 90 percent efficiency). In this 

instance, averaging the efficiencies 

misrepresents the performance of the 

ballast in its most common uses. 

Additionally, DOE recognizes that 

testing at each input voltage could 

increase the burden relative to a 

requirement of testing ballasts at only a 

single voltage. For these reasons, in this 

NOPR, DOE is not proposing to test at 

all available input voltages and average 

the resulting efficiencies. 

b. Posting the Highest and Lowest 

Efficiencies 

Another approach, suggested by 

Empower Electronics, would require 

testing at each input voltage and listing 

the best and worst efficiencies on the 

product label. (Empower Electronics, 

No. 36 at p. 2) DOE acknowledges that, 

as with voltage averaging, this method 

could help address the concern that a 

manufacturer could optimize their 

ballasts on a voltage that could easily 

increase in efficiency, while most 

customers would be using a nonoptimized voltage. Also similar to 

voltage averaging, however, DOE finds 

that this approach would lead to a 

compliance burden for manufacturers 

and would increase the required tests 

compared to a requirement to test 

ballasts only at a single voltage. 

c. Test at Single Manufacturer-Declared 

Voltage 

In response to the preliminary TSD, 

NEMA suggested that the test 

procedures should allow testing at a 

single voltage determined by the 

manufacturer and declared in the test 

report. (NEMA, No. 34 at p. 2) In 

manufacturer interviews, DOE received 

feedback that manufacturers optimize 

ballasts at a specific voltage and prefer 

to test their products at that voltage. 

DOE is concerned, however, that 

manufacturers might optimize efficiency 

at a voltage that is most convenient or 

least expensive rather than the voltage 

most used by customers. Were 

manufacturers to optimize efficiency at 

a less commonly used voltage, the 

efficiency claimed at this voltage would 

not be representative of typical 

efficiency in the more common uses. 

Because the efficiency at the 

manufacturer-declared voltage and the 

efficiency at the more commonly used 

voltages may not have direct correlation, 

such test procedures could potentially 

reduce the energy savings of this 

rulemaking. 

d. Test at Highest-Rated Voltage 

Another input voltage specification 

could be that the ballast should be 

tested at the highest voltage possible. 

OSI commented, and NEEA agreed, that 

fluorescent ballast test procedures set 

the precedent for having to test only at 

the highest rated voltage. They also said 

that this would reduce costs associated 

with additional testing for metal halide 

ballasts. (OSI, Public Meeting 

Transcript, No. 33 at p. 29; NEEA, No. 

31 at p. 2) DOE understands the concern 

regarding increased burdens and costs 

associated with being required to test 

ballasts at multiple input voltages. 

DOE’s research, however, found that a 

ballast’s highest-rated voltage is not 

always its most common input voltage. 

For example, DOE found a significant 

number of 70 W ballasts that were 

capable of operating on 120 V, 208 V, 

240 V, and 277 V. Testing at the highestrated voltage would mean these ballasts 

are tested at 277 V, but manufacturer 

feedback indicated that 70 W ballasts 

are much more likely to be actually used 

in 120 V applications. One possible 

reaction to energy conservation 

standards based on this test procedure 

specification could be for manufacturers 

to optimize 70 W ballasts at 277 V (the 

tested voltage) as opposed to 120 V (the 

more commonly used voltage). Because 

of this possibility, DOE finds that testing 

and enforcing standards at the highest 

voltage could reduce the potential 

energy savings of this rulemaking. 

e. Test on Input Voltage Based on 

Wattage and Available Voltages 

In this NOPR, DOE is proposing that 

the most common input voltages for 

each wattage range be used in testing. 

Progress Energy Carolinas commented 

that an amendment to the current test 

procedures that would specify the 

required input voltage for testing would 

not provide enough energy savings for 

the additional expense. (Progress Energy 

Carolinas, No. 24 at p. 2) DOE disagrees 

with Progress Energy Carolinas’ 

assertion that an added expense is 

inherent in specification of the input 

voltage for testing. DOE’s proposal only 

requires testing at one input voltage, the 

minimum number of tests possible. By 

proposing testing at a single voltage, 

DOE reduces testing burden relative to 

a requirement for testing at multiple 

input voltages. In addition, because the 

input voltage specification matches the 

most commonly used voltage, the 

requirement encourages optimization of 

efficiency around an input voltage 

commonly used in practice. Finally, 

analysis of the impact of energy savings 

for this rulemaking is made more 

accurate by assessing ballast efficiency 

at the most commonly used input 

voltages. 

In manufacturer interviews, DOE 

received feedback on usage of different 

input voltages. DOE learned that 208 V 

is the least used and least optimized 

voltage. DOE also received feedback that 

efficiencies at 277 V and 240 V are 

similar to each other. In general, DOE 

determined that fixtures with wattages 

less than 150 W were most often used 

at 120 V. Wattages of 150 W and above 

were most commonly used at 277 V. 

Thus, this NOPR proposes that testing of 

metal halide ballasts use the following 

input voltages: 

• For ballasts less than 150 W that 

have 120 V as an available input 

voltage, ballasts are to be tested at 120 

V. 

• For ballasts less than 150 W that 

lack 120 V as an available voltage, 

ballasts should be tested at the highest 

available input voltage. 

• For ballasts operated at greater than 

or equal to 150 W and less than or equal 

to 2000 W that also have 277 V as an 

available input voltage, ballasts are to be 

tested at 277 V. 

• For ballasts greater than or equal to 

150 W and less than or equal to 2000 W 

that lack 277 V as an available input 

voltage, ballasts should be tested at the 

highest available input voltage. 

3. Testing Electronic Ballasts 

With regards to testing electronic 

metal halide ballasts, DOE received 

feedback on several issues in response 

to the preliminary TSD. Some interested 

parties commented that the test 

procedures do not apply to any 

electronic ballasts and others 

commented that high-frequency 

electronic ballast testing is not specified 

and is more prone to measurement 

variation than low-frequency electronic 

ballast testing is. DOE discusses these 

comments below. 

In the preliminary TSD, DOE noted 

that it would continue to use the 2005 

version of ANSI C82.6 for testing both 

electronic and magnetic ballasts. Philips 

and Venture both commented that there 

are currently no test procedures for 

electronic ballasts. (Philips, Public 

Meeting Transcript, No. 33 at p. 130; 

Venture, Public Meeting Transcript, No. 

33 at p. 130) Both Cooper and NEMA 

noted that an update to ANSI C82.6 that 

was to be released by the end of 2011 

would include test procedures for lowfrequency electronic (LFE) ballasts, but 

not high-frequency electronic (HFE) 

ballasts.19 (Cooper, Public Meeting 

Transcript, No. 33 at pp. 27–28; NEMA, 

No. 34 at p. 2) NEEA commented that 


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this delay should preclude DOE from 

altering the test procedures for 

electronic metal halide ballasts at this 

time. (NEEA, No. 31 at p. 2) In DOE’s 

reading of ANSI C82.6, the scope 

dictates testing HID lamp ballasts 

without specifying applicability only to 

magnetic ballasts. In interviews with 

manufacturers, DOE received feedback 

confirming that ANSI C82.6–2005 does 

provide a method for testing lowfrequency ballasts. Additionally, section 

4.4.3 of ANSI C82.6–2005 discusses 

low-frequency electronic ballasts in the 

context of alternative stabilization 

methods. 

DOE also received comments that 

HFE ballasts should be excluded from 

the rulemaking because there are no test 

procedures for them. Philips, OSI, and 

NEMA noted that the available 

equipment cannot test HFE ballast 

frequencies above 125 kHz as accurately 

as other ballasts, and Philips noted that 

HFE ballast testing accuracy can range 

from plus or minus two to five percent. 

(Philips, Public Meeting Transcript, No. 

33 at p. 130; NEMA, No. 34 at p. 14; 

OSI, No. 27 at p. 4) NEEA commented 

that manufacturers stated that there are 

no ANSI or NEMA HFE standards, and 

that no test procedures could accurately 

assess the efficiency of these ballasts to 

within plus or minus one percent. Based 

on this information, NEEA 

recommended that DOE should not 

consider these products in this 

rulemaking. (NEEA, No. 31 at p. 9) 

Empower Electronics commented that 

the test procedures should be amended 

to include HFE ballast testing. 

(Empower Electronics, No. 36 at p. 2) 

DOE agrees that the instrumentation in 

ANSI C82.6–2005 is specified only up to 

800 Hz for ammeters and voltmeters and 

to 1 kHz for wattmeters, and also that 

these would be insufficient for 

measurements of HFE ballasts. 

DOE is proposing to amend the metal 

halide ballast and fixtures test 

procedures to specify the 

instrumentation required to test HFE 

ballasts. DOE found that the 

instrumentation commonly used for 

high-frequency electronic metal halide 

ballast testing is the same 

instrumentation used for fluorescent 

lamp ballast testing. DOE proposes that 

instrumentation at least as accurate as 

required by ANSI C82.6–2005 be used to 

assess the output frequency of the 

ballast. Once the output frequency is 

determined to be greater than or equal 

to 1000 Hz, (the frequency at which 

DOE proposes to define high-frequency 

electronic ballasts), the test procedure 

instrumentation would be required to 

include a power analyzer that conforms 

to ANSI C82.6–2005 with a maximum of 

100 picofarads (pF) capacitance to 

ground and frequency response between 

40 Hz and 1 MHz. The test procedures 

would also require a current probe 

compliant with ANSI C82.6–2005 that is 

galvanically isolated and has a 

frequency response between 40 Hz and 

20 MHz, and lamp current measurement 

where the full transducer ratio is set in 

the power analyzer to match the current 

to the analyzer. The full transducer ratio 

would be required to satisfy: 

Where: 

Iin is current through the current transducer; 

Vout is the voltage out of the transducer; 

Rin is the power analyzer impedance; and 

Rs is the current probe output impedance. 

4. Rounding Requirements 

DOE also proposes to amend the 

metal halide ballast test procedure 

requirements for measuring and 

recording input wattage and output 

wattage to require rounding to the 

nearest tenth of a watt, and the resulting 

calculation of efficiency to the nearest 

tenth of a percent. Through testing, DOE 

found that testing multiple samples of 

the same ballast yielded a range of 

ballast efficiencies typically differing by 

less than one percent. Because this data 

introduces both test measurement and 

sample to sample variation, the test 

measurement itself should be at least 

this accurate. Therefore, DOE believes 

its test procedures can resolve 

differences of less than one percent and 

rounding to the tenths decimal place 

would be reasonable. 

B. Technological Feasibility 

1. General 

In each standards rulemaking, DOE 

conducts a screening analysis based on 

information it has gathered on current 

technology options and prototype 

designs that could improve the 

efficiency of the products or equipment 

that are the subject of the rulemaking. 

As the first step in this analysis, DOE 

develops a list of design options for 

consideration in consultation with 

manufacturers, design engineers, and 

other interested parties. DOE then 

determines which of these options for 

improving efficiency is technologically 

feasible. DOE considers technologies 

incorporated in commercially available 

products or in working prototypes to be 

technologically feasible. 10 CFR part 

430, subpart C, appendix A, section 

4(a)(4)(i) 

Once DOE has determined that 

particular design options are 

technologically feasible, it evaluates 

each of these design options according 

to the following three screening criteria: 

(1) Practicability to manufacture, install, 

or service; (2) adverse impacts on 

product utility or availability; and (3) 

adverse impacts on health or safety. 

Section V.B of this notice discusses the 

results of the screening analysis for 

metal halide lamp fixtures. In particular, 

it lists the designs DOE considered, 

those it screened out, and those that are 

the basis for the TSLs in this 

rulemaking. For further details on the 

screening analysis for this rulemaking, 

see chapter 4 of the NOPR TSD. 

2. Maximum Technologically Feasible 

Levels 

Section 325(o) of EPCA requires that 

when DOE amends standards for a type 

or class of covered equipment, it must 

determine the maximum improvement 

in energy efficiency or maximum 

reduction in energy use that is 

technologically feasible for that product. 

(42 U.S.C. 6295(o)) Accordingly, DOE 

determined the maximum 

technologically feasible (‘‘max tech’’) 

ballast efficiency in this NOPR’s 

engineering analysis, using the design 

options identified in the screening 

analysis (see chapter 4 of the NOPR 

TSD). 

To determine the max tech level, DOE 

conducted a survey of the MHLF market 

and the research fields that support the 

market. DOE’s view based on test data 

is that within a given equipment class, 

no working prototypes exist that have a 

distinguishably higher ballast efficiency 

than currently available equipment. 

Therefore, the highest efficiency level 

presented, which represents the most 

efficient tier of commercially available 

equipment, is the max tech level for this 

rulemaking. This highest efficiency 

level requires electronic ballasts using 

the best components and circuit 

topologies commercially available for 

fixtures rated ≥50 W to ≤500 W. The 

max tech efficiency level requires the 

highest grades of core steel and copper 

windings for the fixtures rated >500 W 

and ≤2000 W. 

DOE did not screen out any 

technology options in the preliminary 

analysis. DOE received several 

comments regarding its determination of 

max tech ballast efficiency in the 

preliminary TSD. These comments are 

discussed in section V.C.8. For this 

NOPR, DOE conducted additional 

analysis to determine the appropriate 

max tech levels for metal halide ballasts. 

As discussed in section V.C.3, DOE 

added 150 W as a representative 

wattage, and tested ballasts to establish 

an appropriate max tech level for this 

wattage. DOE also conducted additional 


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20 In the past DOE presented energy savings 

results for only the 30-year period that begins in the 

year of compliance. In the calculation of economic 

impacts, however, DOE considered operating cost 

savings measured over the entire lifetime of 

equipment purchased in the 30-year period. DOE 

has chosen to modify its presentation of national 

energy savings to be consistent with the approach 

used for its national economic analysis. 

testing of the 70 W, 250 W, 400 W, and 

1000 W ballasts on the market, and 

determined the highest efficiency levels 

that are technologically feasible within 

each equipment class. As discussed in 

section V.C.9, data for each equipment 

class has been fit with a wattageefficiency equation to determine the 

minimum efficiency levels. Table IV.1 

presents the max tech efficiencies for 

each wattage range analyzed in the 

NOPR. 

TABLE IV.1—MAX TECH LEVELS

Equipment class wattage range Efficiency 

level* 

Efficiency level equation 

% 

≥50 and ≤100 ........................................................................................................................... EL4 .............. 100/(1+0.36*P∧(¥0.3))†. 

>100 and <150* ....................................................................................................................... EL4 .............. 100/(1+0.36*P∧(¥0.3)). 

≥150** and ≤250 ...................................................................................................................... EL4 .............. 100/(1+0.36*P∧(¥0.3)). 

>250 and ≤500 ........................................................................................................................ EL4 .............. 100/(1+0.36*P∧(¥0.3)). 

>500 and ≤2000 ...................................................................................................................... EL2 .............. For >500 W to <1000 W: 

3.2*10∧(¥3)*P + 89.9 

For ≥1000 W to ≤2000 W: 93.1. 

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified 

by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, 

as specified by UL 1029–2001. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 

50 °C, as specified by UL 1029–2001. 

† P is defined as the rated wattage of the lamp that the fixture is designed to operate. 

DOE requests comment on its 

selection of the max tech levels and 

whether it is technologically feasible to 

attain these high efficiencies. 

Specifically, DOE seeks data on the 

potential change in efficiency, the 

design options employed, and the 

associated change in cost. Any design 

option that DOE considers to improve 

efficiency must meet the four criteria 

outlined in the screening analysis: 

technological feasibility; practicability 

to manufacture, install, and service; 

adverse impacts on product or 

equipment utility to customers or 

availability; and adverse impacts on 

health or safety. DOE also requests 

comment on any technological barriers 

to an improvement in efficiency above 

the max tech efficiency levels for all or 

certain types of ballasts. 

C. Energy Savings 

1. Determination of Savings 

For each TSL, DOE projected energy 

savings from the equipment that are the 

subject of this rulemaking purchased in 

the 30-year period that begins in the 

year of compliance with new or 

amended standards (2016–2045). The 

savings are measured over the entire 

lifetime of products purchased in the 

30-year period.20 DOE quantified the 

energy savings attributable to each TSL 

as the difference in energy consumption 

between each standards case and the 

base case. The base case represents a 

projection of energy consumption in the 

absence of amended mandatory 

efficiency standards, and considers 

market forces and policies that affect 

demand for more efficient equipment. 

For example, in the base case, DOE 

models a migration from covered metal 

halide lamp fixtures to higher-efficiency 

technologies such as high-intensity 

fluorescent (HIF), induction lights, and 

light-emitting diodes (LEDs). DOE also 

models a move to other HID fixtures 

such as high-pressure sodium, based on 

data given by manufacturers during the 

2010 framework public meeting. 

(Philips, Public Meeting Transcript, 

No.8 at p. 91) 

DOE used its NIA spreadsheet to 

estimate energy savings from new or 

amended-standards for the metal halide 

lamp fixtures that are the subject of this 

rulemaking. The NIA spreadsheet model 

(described in section V.G of this notice 

and in chapter 11 of the NOPR TSD) 

calculates energy savings in site energy, 

which is the energy directly consumed 

by products at the locations where they 

are used. DOE reports national energy 

savings on an annual basis in terms of 

the source (primary) energy savings, 

which is the savings in the energy that 

is used to generate and transmit the site 

energy. To convert site energy to source 

energy, DOE derived annual conversion 

factors from the model used to prepare 

the Energy Information Administration’s 

(EIA) Annual Energy Outlook 2013 

(AEO2013). 

DOE has begun to also estimate 

energy savings using full-fuel-cycle 

metrics. The full-fuel-cycle (FFC) metric 

includes the energy consumed in 

extracting, processing, and transporting 

primary fuels, and, thus, presents a 

more complete picture of the impacts of 

efficiency standards. DOE’s approach is 

based on application of FFC multipliers 

for each fuel type used by covered 

products and equipment, as discussed 

in DOE’s statement of policy published 

in the Federal Register on August 18, 

2011 (76 FR 51281), and in the notice 

of policy amendment. 77 FR 49701 

(August 17, 2012). 

2. Significance of Savings 

As noted above, 42 U.S.C. 

6295(o)(3)(B) prevents DOE from 

adopting a standard for a covered 

product unless such standard would 

result in ‘‘significant’’ energy savings. 

Although the term ‘‘significant’’ is not 

defined in the Act, the U.S. Court of 

Appeals, in Natural Resources Defense 

Council v. Herrington, 768 F.2d 1355, 

1373 (D.C. Cir. 1985), indicated that 

Congress intended ‘‘significant’’ energy 

savings in this context to be savings that 

were not ‘‘genuinely trivial.’’ The energy 

savings for all of the TSLs considered in 

this rulemaking (presented in section 

VI.B.3) are nontrivial, and, therefore, 

DOE considers them ‘‘significant’’ 

within the meaning of section 325 of 

EPCA. 

D. Economic Justification 

1. Specific Criteria 

As noted in section II.A, EPCA 

provides seven factors to be evaluated in 

determining whether a potential energy 

conservation standard is economically 

justified. (42 U.S.C. 6295(o)(2)(B)) The 

following sections discuss how DOE 

addresses each of those seven factors in 

this rulemaking. 


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a. Economic Impact on Manufacturers 

and Customers 

In determining the impacts of a new 

or amended standard on manufacturers, 

DOE first determines quantitative 

impacts using an annual-cash-flow 

approach. This approach includes both 

a short-term assessment—based on the 

cost and capital requirements during the 

period between the announcement of a 

regulation and when the regulation 

comes into effect—and a long-term (30- 

year) assessment. The quantitative 

impacts analyzed include INPV (which 

values the industry based on expected 

future cash flows), annual cash flows, 

and changes in revenue and income. 

Second, DOE analyzes and reports the 

impacts on different types of 

manufacturers, including an analysis of 

impacts on small manufacturers. Third, 

DOE considers the impact of standards 

on overall and technology-specific 

domestic manufacturer employment and 

manufacturing capacity, as well as the 

potential for standards to result in plant 

closures and loss of capital investment 

for technology-specific manufacturers. 

DOE also takes into account cumulative 

impacts of different DOE regulations 

and other regulatory requirements on 

manufacturers. 

For individual customers, measures of 

economic impact include the changes in 

LCC and PBP associated with new or 

amended standards. LCC is separately 

specified as one of the seven factors to 

consider when determining the 

economic justification for a new or 

amended standard (42 U.S.C. 

6295(o)(2)(B)(i)(II)), and is discussed in 

the following section. For customers 

viewed from a national perspective, 

DOE calculates the net present value of 

the economic impacts on them over the 

30-year equipment shipments period 

used in this rulemaking. 

b. Life-Cycle Costs 

The LCC is the sum of the purchase 

price of a fixture (including its 

installation) and its operating expenses 

(including energy, maintenance, and 

repair expenditures) discounted over 

the lifetime of the fixture. The LCC 

savings for the considered efficiency 

levels are calculated relative to a base 

case that reflects likely trends in the 

absence of new or amended standards. 

The LCC analysis required a variety of 

inputs, such as equipment prices, 

equipment energy consumption, energy 

prices, maintenance and repair costs, 

equipment lifetimes, and customer 

discount rates. DOE assumed in its 

analysis that customers purchase the 

equipment in 2016. 

To account for uncertainty and 

variability in specific inputs, such as 

equipment lifetime and discount rate, 

DOE uses a distribution of values, with 

probabilities attached to each value. 

DOE identifies the percentage of 

customers estimated to receive LCC 

savings or experience an LCC increase, 

in addition to the average LCC savings 

associated with a particular standard 

level. DOE also evaluates the LCC 

impacts of potential standards on 

identifiable subgroups of customers that 

may be affected disproportionately by a 

national standard. 

c. Energy Savings 

Although significant conservation of 

energy is a separate statutory 

requirement for imposing an energy 

conservation standard, EPCA requires 

DOE, in determining the economic 

justification of a standard, to consider 

the total projected energy savings that 

are expected to result directly from the 

standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) 

As discussed in section V.G, DOE uses 

the NIA spreadsheet to project national 

energy savings. 

d. Lessening of Utility or Performance of 

Products 

In establishing classes of equipment 

and evaluating design options and the 

impact of potential standard levels, DOE 

seeks to develop standards that would 

not lessen the utility or performance of 

the equipment under consideration. The 

efficiency levels considered in today’s 

NOPR will not affect features valued by 

customers, such as input voltage and 

light output. Therefore, DOE believes 

that none of the TSLs presented in 

section VI.A would reduce the utility or 

performance of the ballasts considered 

in the rulemaking. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) 

e. Impact of Any Lessening of 

Competition 

EPCA directs DOE to consider any 

lessening of competition likely to result 

from standards. It directs the Attorney 

General to determine the impact, if any, 

of any lessening of competition likely to 

result from a proposed standard and to 

transmit this determination to the 

Secretary, not later than 60 days after 

the publication of a proposed rule, 

together with an analysis of the nature 

and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) DOE has 

transmitted a copy of today’s proposed 

rule to the Attorney General and has 

requested that the Department of Justice 

(DOJ) provide its determination on this 

issue. DOE will address the Attorney 

General’s determination in any final 

rule. 

f. Need for National Energy 

Conservation 

The energy savings from the proposed 

standards are likely to provide 

improvements to the security and 

reliability of the nation’s energy system. 

Reductions in the demand for electricity 

also may result in reduced costs for 

maintaining the reliability of the 

nation’s electricity system. DOE 

conducts a utility impact analysis to 

estimate how standards may affect the 

nation’s needed power generation 

capacity. 

The proposed standards also are 

likely to result in environmental 

benefits in the form of reduced 

emissions of air pollutants and 

greenhouse gases associated with energy 

production. DOE reports the emissions 

impacts from today’s proposed 

standards, and from each TSL it 

considered, in section VI.B.6 of this 

notice. DOE also reports estimates of the 

economic value of emissions reductions 

resulting from the considered TSLs. 

g. Other Factors 

EPCA allows the Secretary to consider 

any other relevant factors in 

determining whether a standard is 

economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)(VII)) Under this 

provision, DOE considered subgroups of 

customers that may experience 

disproportionately adverse effects under 

the standards proposed in this rule. 

DOE specifically assessed the effect of 

standards on utilities, transportation 

facility owners, and warehouse owners. 

In considering these subgroups, DOE 

analyzed differences in electricity 

prices, operating hours, discount rates, 

and baseline ballasts. See section V.H 

for further detail. 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 

6295(o)(2)(B)(iii), EPCA creates a 

rebuttable presumption that an energy 

conservation standard is economically 

justified if the additional cost to the 

customer of equipment that meets the 

standard is less than three times the 

value of the first year’s energy savings 

resulting from the standard, as 

calculated under the applicable DOE 

test procedure. DOE’s LCC and PBP 

analyses generate values used to 

calculate the effects that proposed 

energy conservation standards would 

have on the payback period for 

customers. These analyses include, but 

are not limited to, the 3-year payback 

period contemplated under the 

rebuttable-presumption test. In addition, 

DOE routinely conducts an economic 

analysis that considers the full range of 


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51484 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

21The EIA does not approve use of the name 

‘‘NEMS’’ unless it describes an AEO version of the 

model without any modification to code or data. 

Because the present analysis entails some minor 

code modifications and runs the model under 

various policy scenarios that deviate from AEO 

assumptions, the name ‘‘NEMS–BT’’ refers to the 

model as used here. 

impacts to customers, manufacturers, 

the nation, and the environment, as 

required under 42 U.S.C. 

6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE’s 

evaluation of the economic justification 

for a potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). The rebuttable 

presumption payback calculation is 

discussed in section VI.B.1 of this 

NOPR. 

V. Methodology and Discussion 

DOE used two spreadsheet tools to 

estimate the impact of today’s proposed 

standards. The first spreadsheet tool 

calculates LCCs and PBPs of potential 

new energy conservation standards. The 

second spreadsheet tool provides 

shipment projections and then 

calculates national energy savings and 

net present value impacts of potential 

new energy conservation standards. The 

Department also assessed manufacturer 

impacts, largely through use of the 

Government Regulatory Impact Model 

(GRIM). 

Additionally, DOE estimated the 

impacts of energy efficiency standards 

on utilities and the environment. DOE 

used a version of EIA’s National Energy 

Modeling System (NEMS) for the utility 

and environmental analyses. The NEMS 

model simulates the energy sector of the 

U.S. economy. EIA uses NEMS to 

prepare its Annual Energy Outlook, a 

widely known reference energy forecast 

for the United States. The NEMS-based 

model used for appliance standards 

analysis is called NEMS–BT (BT stands 

for DOE’s Building Technologies 

Program), and is based on the current 

AEO (AEO2013) NEMS with minor 

modifications.21 The NEMS–BT 

accounts for the interactions between 

the various energy supply and demand 

sectors and the economy as a whole. For 

more information on NEMS, refer to The 

National Energy Modeling System: An 

Overview, DOE/EIA–0581 (98) (Feb. 

1998), available at: tonto.eia.doe.gov/

FTPROOT/forecasting/058198.pdf. 

A. Market and Technology Assessment 

1. General 

When beginning an energy 

conservation standards rulemaking, 

DOE develops information that provides 

an overall picture of the market for the 

equipment concerned, including the 

purpose of the products, the industry 

structure, and the market 

characteristics. This activity includes 

both quantitative and qualitative 

assessments based on publicly available 

information. The subjects addressed in 

the market and technology assessment 

for this rulemaking include: Equipment 

classes and manufacturers; historical 

shipments; market trends; regulatory 

and non-regulatory programs; and 

technologies or design options that 

could improve the energy efficiency of 

the product(s) under examination. See 

chapter 3 of the NOPR TSD for further 

discussion of the market and technology 

assessment. 

2. Equipment Classes 

In establishing energy conservation 

standards, DOE divides covered 

equipment into classes by: (a) The type 

of energy used, (b) the capacity of the 

equipment, or (c) any other 

performance-related feature that justifies 

different standard levels, such as 

features affecting consumer utility. (42 

U.S.C. 6295(q)) DOE then considers 

establishing separate standard levels for 

each equipment class based on the 

criteria set forth in 42 U.S.C. 6295(o). 

In the preliminary analysis, DOE 

considered several potential classsetting factors for fixtures, including 

rated lamp wattage, input voltage, 

number of lamps operated, starting 

method, electronic configuration, circuit 

type, and fixture application. DOE 

preliminarily determined that rated 

lamp wattage was the only factor 

affecting both consumer utility and 

efficiency. DOE, therefore, analyzed four 

equipment classes for fixtures with 

rated lamp wattages: (1) Greater than or 

equal to 50 W and less than 150 W; (2) 

greater than or equal to 150 W and less 

than or equal to 250 W; (3) greater than 

250 W and less than or equal to 500 W; 

and (4) greater than 500 W. As 

discussed in the following sections, 

several interested parties commented on 

the preliminary equipment classes and 

the other class-setting factors that DOE 

considered. 

a. Input Voltage 

Metal halide lamp fixtures are 

available in a variety of input voltages 

(such as 120 V, 208 V, 240 V, 277 V, and 

480 V), and the majority of fixtures are 

equipped with ballasts that are capable 

of operating at multiple input voltages 

(for example quad-input-voltage ballasts 

are able to operate at 120 V, 208 V, 240 

V, and 277 V). DOE determined that 

input voltage represents a feature 

affecting consumer utility as certain 

applications demand specific input 

voltages. Although input voltage can 

affect ballast resistive losses and thus, 

efficiency, for the preliminary analysis, 

DOE’s ballast testing did not indicate a 

prevailing relationship (e.g., higher 

voltages are not always more efficient) 

between discrete input voltages and 

ballast efficiencies. Therefore, in the 

preliminary analysis, DOE did not 

establish separate equipment classes for 

metal halide lamp fixtures based on 

input voltage. In the preliminary 

analysis, DOE suggested that efficiency 

be represented by the average of tested 

efficiencies at each of the input voltages 

at which the ballast is rated for 

operation. 

In response to the preliminary 

analysis, DOE received several 

comments supporting and opposing 

input voltage as a class-setting criterion. 

NEMA noted that multiple-inputvoltage ballasts are often optimized for 

the most popular voltage application. 

For example, a quint-input-voltage 

ballast (able to operate at five different 

input voltages) will often have a lower 

efficiency at 480 V than at 277 V 

because the ballast is optimized for 277 

V operation. NEMA suggested that 480 

V-capable ballasts be given an efficiency 

allowance, or that all ballasts be allowed 

to be tested at the optimal operating 

voltage as specified by the 

manufacturer. (NEMA, No. 34 at p. 10) 

Georgia Power also commented that due 

to their increased costs relative to non480 V ballasts, dedicated 480 V and 

quint-input-voltage ballasts should be in 

a separate equipment class. (Georgia 

Power, No. 28 at p. 1) Progress Energy 

Carolinas agreed that separate 

equipment classes should be established 

for ballasts above 300 V. (Progress 

Energy Carolinas, No. 24 at p. 2) NEEA 

found that voltage does not appear to be 

a significant factor in energy efficiency 

performance or system utility. However, 

NEEA had no objection to treating 480 

V systems as a separate class, should 

DOE choose to do so. (NEEA, No. 31 at 

p. 3) Empower Electronics commented 

that a separate classification based on 

input voltage is not needed. (Empower 

Electronics, No. 36 at p. 5) 

As discussed in section IV.A of this 

NOPR, DOE is proposing that metal 

halide ballasts be tested at a single input 

voltage, based on the lamp wattage 

operated by the ballast. Ballasts that 

operate lamps 150 W or less would be 

tested at 120 V, and all others would be 

tested at 277 V, unless the ballast is 

incapable of operating at the specified 

input voltage; in that case, the ballast 

would be tested at the highest input 

voltage possible. DOE’s view is that this 

proposal would reduce the testing 

burden and better characterize the 


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22 ‘‘Institute of Electrical and Electronics 

Engineers Guide on the Surge Environment in LowVoltage (V and Less) AC Power Circuits,’’ Approved 

April 4, 2003. 

23The NEC 2011 states that fixtures installed in 

wet or damp locations shall be installed such that 

water cannot enter or accumulate in wiring 

components, lampholders, or other electrical parts. 

All fixtures installed in wet locations shall be 

marked, ‘‘Suitable for Wet Locations.’’ All fixtures 

installed in damp locations shall be marked 

‘‘Suitable for Wet locations’’ or ‘‘Suitable for Damp 

Locations.’’ 

24UL Standard Publication 1598 defines a wet 

location is one in which water or other liquid can 

drip, splash, or flow on or against electrical 

equipment. A wet location fixture shall be 

constructed to prevent the accumulation of water 

on live parts, electrical components, or conductors 

not identified for use in contact with water. A 

fixture that permits water to enter the fixture shall 

be provided with a drain hole. 

energy consumption of metal halide 

lamp fixtures for the majority of 

applications in which they are installed. 

Based on the proposed test procedures, 

DOE evaluated efficiency differences 

between dedicated 480 V, quint-inputvoltage, and quad-input-voltage ballasts 

(which represent the vast majority of 

ballasts on the market). DOE found that 

the quint-input-voltage ballasts had 

similar efficiencies as the quad-inputvoltage ballasts when both were tested 

at 120 V or 277 V. In contrast, DOE 

found that the dedicated 480 V ballasts 

(tested at 480 V) were, on average, 1.4 

percent less efficient than quad-inputvoltage ballasts (tested at 120 V or 277 

V). 

Because dedicated 480 V ballasts have 

a distinct utility and a difference in 

efficiency relative to ballasts tested at 

120 V and 277 V, DOE proposes 

separate equipment classes for ballasts 

tested at 480 V (in accordance with the 

test procedures). These would include 

dedicated 480 V ballasts and any 

ballasts that are capable of being 

operated at 480 V, but incapable of 

being operated at the input voltage 

specified by the test procedures (either 

120 V or 277 V, depending on lamp 

wattage). DOE requests comment on this 

proposal. 

Fixture Application 

Metal halide lamp fixtures are used in 

a variety of applications such as parking 

lots, roadways, warehouses, big-box 

retail, and flood lighting. Although the 

fixture size, shape, and optics are often 

tailored to the application, generally the 

same types of ballasts are currently 

utilized for most of the applications. 

DOE did not expect fixture-applicationrelated attributes to affect ballast 

efficiency for a given lamp wattage, and 

in the preliminary analysis DOE did not 

analyze separate equipment classes 

based on such attributes. 

In response to the preliminary 

analysis, DOE received several 

comments regarding the problems of 

utilizing electronic ballasts in outdoor 

applications and recommending that 

DOE establish separate equipment 

classes for outdoor fixtures and indoor 

fixtures. Energy Solutions noted that 

there are significant fixture design 

considerations necessitated by outdoor 

use. (Energy Solutions, Public Meeting 

Transcript, No. 33 at pp. 46–47) 

Progress Energy Carolinas clarified that 

ballasts used in outdoor fixtures need to 

be able to withstand high temperatures, 

voltage variations, and lightning and 

other voltage surges. Progress Energy 

Carolinas also indicated that the same 

concerns existed with LED fixtures 

(utilizing electronic drivers) and that 

they were successfully addressed by 

adding heat sinks to dissipate excess 

heat; building regulation into the drivers 

to deal with voltage variations; and 

adding metal oxide varistor (MOV) 

protection (typically 10 kilo volt [kV] 

ANSI C62.41.1–2002 22 Class C 

protection) to protect against lightning 

and other voltage surges. LED fixtures 

also underwent field testing through all 

four seasons to prove overall reliability. 

Progress Energy Carolinas explained 

that until some of these issues are 

similarly addressed and their solutions 

proven, end users will be reluctant to 

use electronic metal halide ballasts in 

outdoor fixtures. (Progress Energy 

Carolinas, No. 24 at p. 1) Georgia Power 

and Progress Energy Carolinas stated 

that outdoor electronic metal halide 

ballasts have not been widely adopted 

by utilities, largely due to these 

reliability concerns. NEMA urged DOE 

to establish MHLF standards for outdoor 

applications (which have higher 

transient requirements and wider 

operating temperature ranges) such that 

magnetic ballasts would be compliant. 

(NEMA, No. 34 at p. 9) If electronic 

ballasts are mandated for outdoor 

fixtures, Progress Energy Carolinas 

recommended that utilities be exempt 

until reliability concerns decrease. 

(Georgia Power, No. 28 at p. 2; Progress 

Energy Carolinas, No. 24 at p. 2) 

The CA IOUs, however, stated that 

electronic ballasts have been 

successfully applied in outdoor 

applications and are readily available on 

the market today, citing examples of 

commercially available electronic metal 

halide products rated for outdoor use 

and municipalities that have adopted 

electronically ballasted metal halide 

streetlights. The CA IOUs expressed 

their belief that the application 

environment does not affect the utility 

or the achievable efficiency of a ballast. 

The CA IOUs also stated that should 

DOE decide that the use of electronic 

ballasts in outdoor environments 

requires additional fixture 

modifications, DOE would need to 

conduct separate cost and savings 

analyses for indoor versus outdoor 

applications. If DOE decides to set 

different equipment classes for indoor 

and outdoor metal halide lamp fixtures, 

the CA IOUs suggested that DOE adopt 

California’s approach for differentiation 

of these types by specifying fixtures that 

are ‘‘UL 1598 Wet Location Listed and 

labeled ‘Suitable for Wet Locations’ as 

specified by the National Electrical 

Code [NEC] 2005, Section 410.4(A).’’ 

(CA IOUs, No. 32 at pp. 2–3) 

Although electronic ballasts are being 

successfully used in certain outdoor 

applications, DOE acknowledges that 

there is currently a market reluctance to 

use electronic metal halide ballasts in 

outdoor applications, particularly due to 

concerns with the electronic ballast’s 

ability to withstand voltage transients. 

However, DOE disagrees with NEMA 

that an efficiency level that requires 

electronic ballasts should not be 

analyzed or proposed on the basis of the 

features of transient suppression and 

operating temperature ranges. DOE’s 

view is that addressing these concerns 

with either (1) an external surge 

protection device or (2) internal 

transient protection of the ballast using 

MOVs in conjunction with other 

inductors and capacitors is 

technologically feasible, as shown by 

the CA IOUs’ list of examples. DOE 

understands that this added protection 

also adds an incremental cost to the 

ballast or fixture (further discussed in 

section V.C.12). As these incremental 

costs could affect the cost effectiveness 

of fixtures for outdoor applications, 

DOE proposes separate equipment 

classes for indoor and outdoor fixtures. 

DOE proposes that outdoor fixtures be 

defined as those that (1) are rated for use 

in wet locations and (2) have 10 kV of 

voltage transient protection. Conversely, 

fixtures that do not meet these 

requirements will be defined as indoor 

fixtures. 

DOE proposes to define the wet 

location rating as specified by the 

National Electrical Code 2011,23 section 

410.10(A) or Underwriters Laboratories 

(UL) 1598 Wet Location Listed.24 DOE 

believes that providing two possible 

definitions will reduce the compliance 

burden as many manufacturers are 

already familiar with one or both of 

these ratings (the NEC definition was 

included in EISA 2007 and both are 

used in California energy efficiency 

regulations). For 10 kV voltage transient 

protection, DOE proposes to use the 10 


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25FCC regulations at 47 CFR part 18, subpart C 

set forth technical standards for industrial, 

scientific, and medical equipment that specify 

frequency bands and tolerance ranges as well as 

electromagnetic field strength limits. Some metal 

halide ballasts may be covered under these 

‘‘industrial, scientific, and medical (ISM) 

equipment’’ standards, which list the general 

operating conditions for ISM equipment. Ballasts 

designed to exceed 9 kHz ballast frequency have to 

be designed so that interference with transmitted 

radio frequencies is eliminated. 47 CFR 18.111, 

18.301–11 

kV voltage pulse withstand requirement 

from ANSI C136.2–2004 as a 

characteristic unique to outdoor 

fixtures. As discussed in section VI.C, 

based on weighing the benefits and 

drawbacks of different requirements, 

DOE is proposing efficiency standards 

that are the same for indoor and outdoor 

equipment classes. If a different 

requirement is ultimately adopted by 

DOE in the final rule, the definitions of 

indoor and outdoor will be added to the 

Code of Federal Regulations for metal 

halide lamp fixtures. 

c. Electronic Configuration and Circuit 

Type 

Of the two metal halide ballast types 

(electronic and magnetic), magnetic 

ballasts are currently more common. 

Magnetic ballasts typically use 

transformer-like copper or aluminum 

windings on a steel or iron core. The 

newer electronic ballasts, which are 

more efficient but less common, rely on 

integrated circuits, switches, and 

capacitors/inductors to control current 

and voltage to the lamp. Both electronic 

and magnetic ballasts are capable of 

producing the same light output and, 

with certain modifications (e.g., thermal 

management, transient protection, 120 V 

auxiliary power functionality), can be 

used interchangeably in all applications. 

Magnetic metal halide ballasts are 

available in the market in several types 

of circuit configurations including highreactance autotransformer, constantwattage isolated transformer, constantwattage autotransformer (CWA), linear 

reactor (reactor), and magnetically 

regulated-lag (reg-lag or mag-reg) 

ballasts. Each magnetic circuit type 

listed has different characteristics that 

may be preferred in certain applications. 

These characteristics (discussed further 

in chapter 3 of the NOPR TSD) include 

size, efficiency, and power regulation. 

For example, magnetically regulated-lag 

ballasts are typically the largest and 

heaviest circuit type, but provide the 

greatest degree of resistance to input 

voltage variation (which sustains light 

output). In the preliminary analysis, 

DOE determined that although magnetic 

ballasts are usually less efficient and 

have a lower initial cost than electronic 

ballasts, neither configuration provides 

a distinct consumer utility over the 

other. Because electronic ballasts can 

provide the same utility as any magnetic 

circuit type, can be used as substitutes 

in all applications, and are generally 

more efficient than magnetic ballasts, 

DOE determined in the preliminary 

analysis that setting separate equipment 

classes based on electronic 

configuration (magnetic vs. electronic) 

or on circuit type was unnecessary. 

At wattages greater than 500 W, few 

electronic ballasts are available due to 

their higher cost and lower expected 

efficiency improvement over magnetic 

ballasts. Electronic ballasts have two 

primary circuit types that operate the 

lamp at either ‘‘high’’ or ‘‘low’’ 

frequency. DOE proposes to define a 

high-frequency ballast to be a ballast 

with output frequency greater than or 

equal to 1000 Hz. For low-frequency 

electronic ballasts, a square current 

waveform is used to diminish acoustic 

resonance and maintain lamp life. All 

lamps operate well on low-frequency 

square waves, so these low-frequency 

ballasts have few compatibility issues 

with lamps. At higher frequencies, 

however, acoustic resonance issues and 

electromagnetic interference (EMI) 

effects cause compatibility issues with 

lamps. At these high frequencies, 

ballasts have to be designed to have the 

right frequency for a desired lamp, but 

the selected frequency may be 

incompatible with other lamps designed 

for different frequencies. Therefore, 

high-frequency electronic ballasts are 

less widely compatible with lamps 

relative to low-frequency electronic 

ballasts. High-frequency ballasts may 

also have difficulty complying with 

Federal Communications Commission 

(FCC) standards.25

In response to DOE’s preliminary 

determination not to use electronic 

configuration or circuit type as a classsetting factor, DOE received several 

comments relating to replacement of 

magnetic ballasts with electronic 

ballasts, possible reliability issues with 

electronic ballasts, and non-efficiencyrelated benefits to using electronic 

ballasts. Cooper Lighting stated that 

electronic ballasts are not direct 

replacements for magnetic ballasts in 

fixtures. (Cooper Lighting, Public 

Meeting Transcript, No. 33 at p. 64) 

With regard to reliability, Georgia Power 

said that (1) electronic ballasts are 

unproven in outdoor applications and 

(2) electronic ballasts are vulnerable to 

failures due to high temperature, 

moisture, and voltage variations and 

surges caused by lightning and other 

outdoor events. Progress Energy 

Carolinas did not disagree with 

including electronic and magnetically 

ballasted fixtures in the same equipment 

class, but commented that the expected 

energy savings are small. They stated 

that other operating characteristics drive 

the use of electronic ballasts in indoor 

applications (i.e., correlated color 

temperature variation, lamp lumen 

depreciation, and dimming). (Progress 

Energy Carolinas, No. 24 at p. 2) The CA 

IOUs agreed with Georgia Power that 

electronic ballasts, especially in 

conjunction with pulse-start ceramic 

metal halide lamps that offer higher 

efficacy and improved color rendering 

index (CRI), have other advantages that 

can offset their added cost. The CA 

IOUs also stated that electronic ballasts 

do save energy relative to magnetically 

ballasted systems. (CA IOUs, No. 32 at 

p. 4) Finally, Empower Electronics 

supported DOE’s preliminary 

determination, stating that equipment 

classes need not be set according to 

electronic configuration and circuit 

type. (Empower Electronics, No. 36 at 

p. 6) 

As discussed in section V.C.12, DOE 

recognizes the technological differences 

between magnetic and electronic 

ballasts and has incorporated the cost of 

additional devices or modifications 

necessary for certain applications into 

its analysis. In section V.I.2, DOE 

addresses impacts on manufacturers of 

a transition to electronic ballasts, but 

does not consider these impacts in 

development of equipment classes. 

While acknowledging that customers 

make purchasing decisions on 

electronic versus magnetic ballasts after 

consideration of other parameters in 

addition to efficiency, DOE has 

determined that significant energy 

savings can be realized through a 

transition from magnetic to electronic 

ballasts (see section VI.B.3). For this 

NOPR, DOE maintains that electronic 

configuration does not affect consumer 

utility because with the necessary 

design adders, electronic ballasts can 

provide the same utility as magnetic 

ballasts. Because of this, DOE is not 

proposing to define equipment classes 

based on electronic configuration and 

requests comment on this matter. 

d. Lamp Wattage 

As lamp wattage increases, lamp and 

ballast systems generally (but not 

always) produce increasing amounts of 

light (lumens). The goal of efficiency 

standards is to decrease the wattage 

needed for the same lumens—resulting 

in an increase in energy efficiency. 

Because certain applications require 

more light than others, wattage often 

varies by application. For example, lowwattage (less than 150 W) lamps are 


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used today in commercial applications 

for general lighting. Medium-wattage 

(150–500 W) lamps are the most widely 

used today and include warehouse, 

street, and general commercial lighting. 

High-wattage (greater than 500 W) 

lamps are used today in searchlights, 

stadiums, and other applications that 

require powerful white light. In the 

preliminary analysis, based on its 

impact on light output, DOE determined 

that lamp wattage affects consumer 

utility. DOE also determined that the 

wattage of a lamp operated by a ballast 

is correlated with the ballast efficiency, 

which generally increases for higherwattage loads. For electronic ballasts, 

this efficiency gain can be attributed to 

the decreasing proportion of fixed losses 

(e.g., switches) to total losses. For lowwattage electronic ballasts, certain fixed 

losses contribute a larger proportion of 

total losses than they do for highwattage ballasts. Magnetic ballasts— 

essentially transformers (sometimes 

with capacitors for power correction 

and igniters for pulse-starting)—have 

proportionally lower overall losses with 

increased wattage. Transformer losses 

(resistive losses in windings, eddy 

currents, and hysteresis) do not scale 

linearly with wattage, meaning that 

overall efficiency increases with 

wattage. Because wattage affects 

consumer utility (lumen output) and has 

a strong correlation to efficiency, DOE 

determined that separate equipment 

classes based on wattage were 

warranted. As a result in the 

preliminary analysis, DOE analyzed four 

lamp wattage class bins: ≥50 W and 

<150 W, ≥150 W and ≤250 W, >250 W 

and ≤500 W, and >500 W. 

NEEA, Empower Electronics, and 

Progress Energy Carolinas supported 

DOE’s determination in the preliminary 

analysis that wattage should be a classsetting factor. (NEEA, No. 31 at p. 3; 

Empower Electronics, No. 36 at p. 7; 

Progress Energy Carolinas, No. 24 at p. 

3) Because no adverse comments were 

received on DOE’s determination, DOE 

proposes to continue using lamp 

wattage as a class-setting factor for this 

NOPR. 

For the NOPR, DOE found that even 

within a designated wattage range (such 

as between 100 W and 150 W), the 

potential efficiencies manufacturers can 

reach is not constant, but rather varies 

with wattage. Instead of setting a 

constant efficiency standard within a 

wattage bin, DOE is proposing the use 

of an equation-based energy 

conservation standard for certain 

equipment classes (see section V.C). 

DOE is also continuing to use wattage 

bins (instead of a single equation 

spanning the entire covered wattage 

range) to define equipment classes, for 

two reasons. First, the range of ballast 

efficiencies considered can differ 

significantly by lamp wattage, thus 

making it difficult to construct a single 

continuous equation for ballast 

efficiency from 50 W to 2000 W. This 

efficiency difference can be attributed to 

the varying cost of increasing ballast 

efficiency for different wattages and the 

impact of legislated (EISA 2007) 

standards that affect only some wattage 

ranges. Second, different wattages often 

serve different applications and have 

unique cost-efficiency relationships. 

Analyzing each wattage range as a 

separate equipment class allows DOE to 

establish the energy conservation 

standards that are cost-effective for each 

wattage bin. 

DOE also received comment that 

certain wattage ranges used in the 

preliminary analysis should be further 

divided. Progress Energy Carolinas 

commented that further division of the 

50 W to 250 W equipment class was 

warranted on the basis of different 

levels of efficiency being possible for 

different wattages. (Progress Energy 

Carolinas, No. 24 at p. 1) For this NOPR, 

DOE determined that the ≥50 W and 

<150 W range should be further 

subdivided. DOE’s test data indicates 

that efficiency varies more significantly 

for ballasts that operate 50 W to 150 W 

lamps than for any other wattage range 

considered in the preliminary TSD. 

Based on catalog information and 

manufacturer interviews, DOE 

determined that 50 W and 100 W 

fixtures typically serve the same 

applications, while 150 W products 

begin to serve applications with 

increased light demand such as area 

lighting or parking lots. DOE used this 

natural division in wattage based on 

application to further divide the lowestwattage range from the preliminary 

analysis. 

With regards to the specification of 

the boundary between fixtures rated to 

operate at wattages above and below 150 

W, Georgia Power commented that 150 

W fixtures should be included with 

fixtures less than 150 W, not those 

greater than 150 W. (Georgia Power, No. 

2 at p. 2) DOE agrees that some 150 W 

fixtures (those exempted by EISA 2007) 

should be included in the >100 to <150 

W equipment classes. As discussed 

previously in section III.A.1, there is an 

existing EISA 2007 exemption for 

ballasts rated for only 150 W lamps, 

used in wet locations, and that operate 

in ambient air temperatures higher than 

50 °C. This exemption has led to a 

difference in the commercially available 

efficiencies for ballasts that are 

exempted or not exempted from EISA 

2007. The exempted ballasts have a 

range of efficiencies similar to wattages 

less than 150 W. Ballasts not exempted 

by EISA 2007 have efficiencies similar 

to ballasts greater than 150 W. As a 

result, DOE is proposing that 150 W 

fixtures previously exempted from EISA 

2007 be included in a >100 W and <150 

W range, while 150 W fixtures subject 

to EISA 2007 standards would be 

included in a ≥150 W to ≤250 W range. 

In the preliminary analysis, DOE 

included all fixtures rated to operate at 

wattages greater than 500 W in the same 

equipment class. OSI suggested that 

DOE include 500 W ballasts in the 

highest-wattage range. OSI stated that 

electronic ballasts that operate lamps 

greater than or equal to 500 W have not 

been developed yet. (OSI, No. 27 at p. 

4) In response to the lack of electronic 

ballasts operating lamps greater than or 

equal to 500 W, DOE agrees that there 

are not commercially available 

electronic ballasts at these wattages 

today, but also notes that magnetic 

ballasts are also unavailable at this 

wattage. Because leaving the boundary 

between these two wattage ranges at 500 

W does not affect any commercially 

available products, DOE proposes to 

maintain the >250 W and ≤500 W range 

for consistency with the EISA 2007 

covered wattage range. 

In summary, DOE is proposing to 

define metal halide lamp fixture 

equipment classes by rated lamp 

wattage ranges ≥50 W to ≤100 W, >100 

W to <150 W, ≥150 W to ≤250 W, >250 

W to ≤500 W, and >500 W to ≤2000 W. 

DOE proposes that 150 W fixtures 

previously exempted by EISA 2007 be 

included in the >100 W to <150 W 

range, while 150 W fixtures subject to 

EISA 2007 standards continue to be 

included in the ≥150 W to ≤250 W 

range. DOE requests comment on these 

wattage ranges. 

e. Number of Lamps 

Metal halide lamp fixtures are 

commonly designed to operate with a 

single lamp because of lamp 

characteristics related to re-striking 

(turning the lamp on again after being 

turned off, because metal halide lamps 

require time to cool down before being 

lighted again) and voltage regulation. 

DOE’s review of manufacturer catalogs 

revealed that while a majority of 

available ballasts operate only one lamp, 

a small fraction are designed for two 

lamps. Based on this review, DOE 

determined that there is little to no 

change in efficiency between one-lamp 

and two-lamp metal halide ballast 

fixtures. In the preliminary analysis, 

DOE determined it unnecessary to 

consider multiple-lamp ballasts in 


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26 DOE is aware of some metal halide lamps that 

can be operated by a pulse-start or a probe-start 

ballast. These lamps are much less common than lamps designed to be operated by ballasts of only 

one starting method. 

equipment classes separate from singlelamp ballasts. 

NEMA agreed with DOE on the 

limited number of two-lamp metal 

halide lamp fixtures. Because two-lamp 

ballasts represent such a small part of 

the market, NEMA suggested they be 

excluded from the rulemaking. Given 

the optical size of a metal halide lamp, 

NEMA found it unlikely that a 

manufacturer would use this exemption 

as a loophole. Fixtures using multiplelamp ballasts would have to be larger, 

more expensive, and less optically 

efficient than those with single-lamp 

ballasts. (NEMA, No. 34 at p. 10) 

Because catalog data shows no 

difference in efficiency, in this NOPR, 

DOE continues to propose including 

ballasts with differing numbers of lamps 

in the same equipment class. DOE is not 

proposing to exclude 2-lamp ballasts 

from the scope of coverage. 

f. Starting Method 

Metal halide lamp fixtures currently 

available in the market are designed to 

operate with either probe-start or pulsestart lamps, but not a mixture of both 

types at the same time.26 The main 

differences between these starting 

methods are: (1) The inclusion of a third 

probe in probe-start lamps, (2) the need 

for an igniter circuit for pulse-start 

lamps, and (3) the different wiring 

specification for ballasts of each starting 

method. Most new applications in the 

market are pulse-start due to its higher 

efficacy (pulse-start lamps provide more 

lumens per watt than probe-start lamps). 

In the preliminary analysis, DOE did not 

consider probe versus pulse-starting to 

be a class-setting factor. While pulsestart lamps are more efficacious than 

probe-start lamps, probe and pulse-start 

ballasts can achieve the same levels of 

ballast efficiency and are used in similar 

applications. DOE did not receive any 

adverse comment relating to this 

preliminary determination, so in this 

NOPR, DOE proposes that both probe 

and pulse-start ballasts be included in 

the same equipment class. 

EISA 2007 distinguishes nonpulsestart electronic equipment classes by 

separating them into two rated lamp 

wattage ranges (≥150 W and ≤250 W, 

and >250 W and ≤500 W) and applying 

a more stringent standard to them than 

to other ballast types. According to 

DOE’s review of manufacturer catalogs 

and information provided by 

manufacturers during interviews, 

nonpulse-start electronic metal halide 

lamp fixtures are not available in the 

market. While EISA 2007 contemplated 

the creation of additional classes for 

alternative technologies that could 

become available in the future, DOE has 

no information that indicates 

differences in efficiency or consumer 

utility based on pulse-start versus 

nonpulse-start ballast fixtures. Based on 

this information, in the preliminary 

analysis, DOE determined that a 

separate equipment class for nonpulsestart ballasts was unnecessary. DOE did 

not receive adverse comments relating 

to this preliminary determination, so in 

this NOPR, DOE is proposing that 

nonpulse-start electronic ballasts be 

included in the same equipment class as 

all other starting methods. The term 

nonpulse-start electronic ballast is 

currently undefined in the CFR. To 

avoid confusion, DOE is proposing to 

define ‘nonpulse-start electronic ballast’ 

in 10 CFR 431.322 as an electronic 

ballast with a starting method other than 

pulse-start. 

Due to their apparent 

interchangeability and lack of unique or 

separate utility that would affect 

efficiency, DOE proposes not to use 

ballast-starting method as a class-setting 

feature. 

g. Conclusions 

Based on interested party input and 

additional research, in this NOPR, DOE 

has decided to propose the equipment 

classes in the following table. DOE has 

revised the wattage bins considered in 

the preliminary analysis to account for 

a varying number of efficiency levels, 

different cost-efficiency relationships in 

the lower wattages, and the lack of 

general lighting applications for 

wattages higher than 2000 W. 

Additionally, each of these wattage bins 

is further divided into indoor and 

outdoor applications to account for the 

difference in consumer utility and the 

cost-efficiency relationships for these 

application types (see section V.C.12 for 

further details about the cost adders that 

effect these relationships). Finally, each 

of these classes is subdivided by input 

voltage, with one class for ballasts tested 

at 480 V (in accordance with the 2009 

test procedures, supplemented with the 

testing guidance included in this 

document), and the non-480 V ballasts 

in a separate class. Ballasts tested at 480 

V include dedicated 480 V ballasts and 

any ballast capable of being operated at 

480 V, but incapable of being operated 

at the input voltage specified by the 

amendments to the test procedures 

proposed in this NOPR (either 120 V or 

277 V, depending on lamp wattage). 

DOE invites comments on these 

proposed equipment classes. 

TABLE V.1—METAL HALIDE LAMP FIXTURE NOPR EQUIPMENT CLASSES

Equipment classes Rated lamp wattage Indoor/outdoor † Input voltage type ‡

1 ............................................ ≥50 W and ≤100 W ............................................................ Indoor ................................... Tested at 480 V. 

2 ............................................ ≥50 W and ≤100 W ............................................................ Indoor ................................... All others. 

3 ............................................ ≥50 W and ≤100 W ............................................................ Outdoor ................................ Tested at 480 V. 

4 ............................................ ≥50 W and ≤100 W ............................................................ Outdoor ................................ All others. 

5 ............................................ >100 W and <150 W * ....................................................... Indoor ................................... Tested at 480 V. 

6 ............................................ >100 W and <150 W * ....................................................... Indoor ................................... All others. 

7 ............................................ >100 W and <150 W * ....................................................... Outdoor ................................ Tested at 480 V. 

8 ............................................ >100 W and <150 W * ....................................................... Outdoor ................................ All others. 

9 ............................................ ≥150 W ** and ≤250 W ...................................................... Indoor ................................... Tested at 480 V. 

10 .......................................... ≥150 W ** and ≤250 W ...................................................... Indoor ................................... All others. 

11 .......................................... ≥150 W ** and ≤250 W ...................................................... Outdoor ................................ Tested at 480 V. 

12 .......................................... ≥150 W ** and ≤250 W ...................................................... Outdoor ................................ All others. 

13 .......................................... >250 W and ≤500 W ......................................................... Indoor ................................... Tested at 480 V. 

14 .......................................... >250 W and ≤500 W ......................................................... Indoor ................................... All others. 

15 .......................................... >250 W and ≤500 W ......................................................... Outdoor ................................ Tested at 480 V. 

16 .......................................... >250 W and ≤500 W ......................................................... Outdoor ................................ All others. 

17 .......................................... >500 W and ≤2000 W ....................................................... Indoor ................................... Tested at 480 V. 

18 .......................................... >500 W and ≤2000 W ....................................................... Indoor ................................... All others. 


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TABLE V.1—METAL HALIDE LAMP FIXTURE NOPR EQUIPMENT CLASSES—Continued 

Equipment classes Rated lamp wattage Indoor/outdoor † Input voltage type ‡

19 .......................................... >500 W and ≤2000 W ....................................................... Outdoor ................................ Tested at 480 V. 

20 .......................................... >500 W and ≤2000 W ....................................................... Outdoor ................................ All others. 

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified 

by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, 

as specified by UL 1029–2001. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 

50 °C, as specified by UL 1029–2001. 

† DOE’s proposed definitions for ‘‘indoor’’ and ‘‘outdoor’’ metal halide lamp fixtures are described in section V.A.2. 

‡ Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 120 

V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these voltages would be 

tested at the highest voltage the ballast is designed to operate. See section IV.A for further detail. 

DOE requests comment on the 

proposed equipment classes. 

B. Screening Analysis 

For the screening analysis, DOE 

consults with industry, technical 

experts, and other interested parties to 

develop a list of technology options for 

consideration and to determine which 

technology options to consider further 

and which to screen out. 

Section 325(o)(2) of EPCA requires 

that any new or revised standard 

achieve the maximum improvement in 

energy efficiency determined to be 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)) Appendix A to subpart C of 

10 CFR part 430, ‘‘Procedures, 

Interpretations, and Policies for 

Consideration of New or Revised Energy 

Conservation Standards for Consumer 

Products’’ (the Process Rule), sets forth 

procedures to guide DOE in its 

consideration and promulgation of new 

or revised energy conservation 

standards. These procedures elaborate 

on the statutory criteria provided in 42 

U.S.C. 6295(o) and, in part, eliminate 

problematic technologies early in the 

process of prescribing or amending an 

energy conservation standard. In 

particular, sections 4(b)(4) and 5(b) of 

the Process Rule provide guidance to 

DOE for determining which design 

options are unsuitable for further 

consideration: 

Technological feasibility. DOE will 

consider technologies incorporated in 

commercial products or in working 

prototypes to be technologically 

feasible. 

Practicability to manufacture, install, 

and service. If mass production and 

reliable installation and servicing of a 

technology in commercial products 

could be achieved on the scale 

necessary to serve the relevant market at 

the time the standard comes into effect, 

then DOE will consider that technology 

practicable to manufacture, install, and 

service. 

Adverse impacts on product utility or 

product availability. If DOE determines 

a technology would have significant 

adverse impacts on the utility of the 

product to significant subgroups of 

consumers, or would 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, it will not consider this 

technology further. 

Adverse impacts on health or safety. 

If DOE determines that a technology 

will have significant adverse impacts on 

health or safety, it will not consider this 

technology further. 

For the preliminary analysis, DOE 

identified the design options listed in 

Table V.2 as technologies that could 

improve MHLF ballast efficiency and 

pass the screening criteria discussed 

above. For further details on these 

design options, see chapter 3 of the 

NOPR TSD. DOE received several 

comments, discussed below, in response 

to the design options presented in the 

preliminary analysis, particularly on 

‘‘improved core steel’’ for magnetic 

ballasts and ‘‘improved components’’ 

for electronic ballasts. 

TABLE V.2—METAL HALIDE LAMP FIXTURE PRELIMINARY ANALYSIS DESIGN OPTIONS

Ballast type Design option Description 

Magnetic .............................. Improved Core Steel Use a higher grade of electrical steel, including grainoriented silicon or amorphous steel, to lower core 

losses. 

Copper Wiring Use copper wiring in place of aluminum wiring to 

lower resistive losses. 

Increased Stack Height Add steel laminations to lower core losses. 

Increased Conductor Cross-Section Increase conductor cross section to lower winding 

losses. 

Electronic Ballast Replace magnetic ballasts with electronic ballasts. 

Electronic ............................. Improved Components ...... Magnetics .......................... Use grain-oriented or amorphous electrical steel to reduce core losses. 

Use optimized-gauge copper or litz wire to reduce 

winding losses. 

Add steel laminations to lower core losses. 

Increase conductor cross section to lower winding 

losses. 

Diodes ............................... Use diodes with lower losses. 

Capacitors ......................... Use capacitors with a lower effective series resistance 

and output capacitance. 

Transistors ......................... Use transistors with lower drain-to-source resistance. 


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TABLE V.2—METAL HALIDE LAMP FIXTURE PRELIMINARY ANALYSIS DESIGN OPTIONS—Continued 

Improved Circuit Design .... Integrated Circuits ............. Substitute discrete components with an integrated circuit. 

DOE received comment on whether 

improved core steel was a design option 

or if the highest-grade steels are already 

used in commercially available ballasts. 

NEEA was generally in support of the 13 

selected design options and DOE’s 

decision to not screen any of them 

further. However, NEEA did comment 

that if higher-grade electrical steels are 

already being utilized in the baseline 

efficiency ballasts, this may limit DOE’s 

ability to apply ‘‘improved core steel’’ as 

a design option for improving 

efficiency. (NEEA, No. 31 at p. 4) DOE 

agrees that some ballasts available on 

the market today already use some of 

the highest grades of grain-oriented core 

steel available. For example, DOE has 

received feedback that 175 W magnetic 

ballasts typically require M6 steel, a 

high-grade, grain-oriented steel, to reach 

88 percent, the minimum EISA 2007 

requirement. (Philips, Public Meeting 

Transcript, No. 33 at p. 69–70) However, 

through manufacturer interviews, DOE 

has learned that there exists significant 

opportunity for improvement in the 

steels used for other wattage ballasts. 

Therefore, DOE continues to consider 

higher-grade, grain-oriented silicon steel 

as a design option to improve magnetic 

ballast efficiency. 

ASAP commented that DOE should 

evaluate the efficiency potential of using 

amorphous steel in cores for the highest 

efficiency levels analyzed. (ASAP, 

Public Meeting Transcript, No. 33 at pp. 

68–69) Conversely, NEMA stated that 

amorphous steel is neither 

technologically feasible nor practicable 

to manufacture for any HID ballast, 

including metal halide ballasts. NEMA 

commented that distribution 

transformers are linear devices that have 

relatively simpler core configurations. 

In contrast, metal halide ballasts are 

non-linear devices that require specific 

flux leakages and wave shaping. These 

unique characteristics are achieved 

through reconfiguring flux pathways 

within the metal halide ballast by using 

flux choke points and leakage paths 

between the primary and secondary 

circuits. NEMA explained that these 

manipulations of the core are extremely 

difficult with relatively brittle 

amorphous steel without causing 

fractures. (NEMA, No. 34 at p. 12) Based 

on this feedback and the lack of any 

commercially available metal halide 

ballast or prototype that utilizes 

amorphous steel cores, DOE proposes to 

screen out amorphous steels within the 

‘‘improved core steel’’ design option 

due to the impracticability to 

manufacture at the scale necessary to 

serve the relevant market. 

NEMA also commented that 

commercially available electronic 

ballasts already utilize the high-quality 

components. (NEMA, No. 34 at p. 12) 

Based on its teardown analysis and 

assessment of the components in 

commercially available metal halide 

electronic ballasts, DOE concurs with 

NEMA that these ballasts generally use 

low-loss components. However, as 

discussed in section V.C, DOE found a 

range of efficiencies commercially 

available for electronic ballasts. As these 

efficiency differences were, at least in 

part, due to variations in components 

used, DOE believes that ‘‘improved 

components’’ is a valid design option 

and continues to consider it in the 

engineering analysis. 

C. Engineering Analysis 

1. Approach 

The engineering analysis develops 

cost-efficiency relationships depicting 

the fixture manufacturing costs of 

achieving increased ballast efficiency. 

DOE applies two methodologies to 

estimate manufacturing costs for the 

engineering analysis: (1) The designoption approach, which provides the 

incremental costs of adding the design 

options (e.g., improved core steels) 

discussed in section V.B to improve the 

efficiency of a baseline model; and (2) 

the efficiency-level approach, which 

estimates the costs of achieving 

increases in energy efficiency levels, 

through ballast efficiency testing and 

teardowns, without regard to the design 

options used to achieve such increases. 

Details of the engineering analysis are in 

chapter 5 of the NOPR TSD. The 

following discussion summarizes the 

general steps of the engineering 

analysis: 

Determine Representative Equipment 

Classes. When multiple equipment 

classes exist, to streamline testing and 

analysis, DOE selects certain classes as 

‘‘representative’’ primarily because of 

their high market volumes. DOE then 

adapts the efficiency levels (ELs) from 

representative equipment classes to 

those equipment classes it does not 

analyze directly. 

Determine Representative Wattages. 

Within each representative equipment 

class, DOE also selects a particular 

wattage fixture as ‘‘representative’’ of 

the wattage range, primarily because of 

their high market volumes. In this 

NOPR, DOE assigns only one 

representative wattage per 

representative equipment class. 

Representative Fixture Types. To 

calculate the typical cost of a fixture at 

each representative wattage, DOE selects 

certain types of fixtures to analyze as 

representative. 

Select Baseline Units. DOE establishes 

a baseline unit for each representative 

wattage. The baseline unit has attributes 

(circuit type, input voltage capability, 

electronic configuration) typical of 

ballasts used in fixtures of that wattage. 

The baseline unit also has the lowest 

(base) efficiency for each equipment 

class. DOE measures changes resulting 

from potential amended energy 

conservation standards compared with 

this baseline. For fixtures subject to 

existing Federal energy conservation 

standards, a baseline unit is a metal 

halide lamp fixture with a commercially 

available ballast that just meets existing 

standards. If no standard exists for a 

fixture, the baseline unit is the metal 

halide lamp fixture with a ballast within 

that equipment class with the lowest 

tested ballast efficiency that is sold. To 

determine energy savings and changes 

in price, DOE compares each higher 

energy-efficiency level with the baseline 

unit. 

To determine the ballast efficiency, 

DOE tested a range of metal halide 

ballasts from multiple ballast 

manufacturers. Appendix 5A of the 

NOPR TSD presents the test results. In 

some cases, DOE selects more than one 

baseline for a representative wattage to 

ensure consideration of different fixture 

and ballast types and their associated 

customer economics. 

Select More Efficient Units. DOE 

selects commercially available metal 

halide lamp fixtures with higher-thanbaseline-efficiency ballasts as 

replacements for each baseline model in 

each representative equipment class. In 

general, DOE can identify the design 

options associated with each moreefficient ballast model by considering 

the 12 design options identified in the 

technology assessment (chapter 3 of the 

NOPR TSD) and screening analysis 

(chapter 4 of the NOPR TSD). Where 

design options cannot be identified for 

that class by the product number or 

catalog description, DOE uses a database 


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27The MSP is the price at which the 

manufacturer can recover all production and nonproduction costs and earn a profit. Non-production 

costs include selling, general, and administration 

(SG&A) costs, the cost of research and development, 

and interest. 

of commercially available ballasts. DOE 

then tests these ballasts to determine 

their efficiency. Appendix 5A of the 

NOPR TSD presents these test results. 

All ballast efficiencies were calculated 

according to the metal halide ballast test 

procedures (10 CFR 431.324) unless 

otherwise specified. DOE estimates the 

design options likely to be used in the 

ballast to achieve a higher efficiency 

based on information gathered during 

manufacturer interview and information 

presented in ballast catalogs. 

Determine Efficiency Levels. DOE 

develops ELs based on: (1) The design 

options associated with the equipment 

class studied and (2) the maximum 

technologically feasible (max tech) 

efficiency level for that class. As just 

noted and as discussed in section 

IV.B.2, DOE’s efficiency levels are based 

on catalog data, test data collected from 

commercially available equipment, and 

manufacturer input. 

Conduct Price Analysis. DOE 

generated a bill of material (BOM) by 

disassembling multiple manufacturers’ 

ballasts from a range of efficiency levels 

and fixtures that span a range of 

applications for each equipment class. 

The BOMs describe the equipment in 

detail, including all manufacturing steps 

required to make and/or assemble each 

part. DOE then developed a cost model 

to convert the BOMs for each 

representative unit into manufacturer 

production costs (MPCs). By applying 

derived manufacturer markups to the 

MPCs, DOE calculated the manufacturer 

selling prices 27 and constructed 

industry cost-efficiency curves. In cases 

where DOE was not able to generate a 

BOM for a given ballast, DOE estimated 

an MSP based on the relationship 

between teardown data and retail data. 

DOE also estimated ballast and fixture 

cost adders necessary to allow 

replacement of more efficient 

substitutes for baseline models. 

2. Representative Equipment Classes 

As described above, DOE selects 

certain equipment classes as 

‘‘representative’’ to focus its analysis. 

The 20 equipment classes proposed in 

this NOPR (based on rated lamp 

wattage, test voltage, and indoor or 

outdoor designation) and the criteria 

used for development are presented in 

section V.A.2. Due to their low 

shipment volume (as indicated through 

manufacturer interviews), DOE does not 

directly analyze the equipment classes 

containing only fixtures with ballasts 

tested at 480 V. DOE selected all other 

equipment classes as representative, 

resulting in a total of ten representative 

classes covering the full range of lamp 

wattages, as well as indoor and outdoor 

designations. 

3. Representative Wattages 

In the preliminary analysis, DOE 

selected four representative rated 

wattages of fixtures (70 W, 250 W, 400 

W, and 1000 W) to analyze in the 

engineering analysis. Each 

representative wattage was typically the 

most commonly sold wattage within 

each equipment class, based on analysis 

of fixture availability from catalogs and 

manufacturer input. DOE received 

several comments relating to the criteria 

for representative wattage selection, as 

well as recommendations to change 

specific wattages analyzed in the 

preliminary analysis. Also, because of 

the addition of the 101 W to 150 W 

equipment classes (discussed in section 

V.A.2), DOE proposes to add an 

additional representative wattage at 150 

W. These comments and proposed 

changes are discussed further below. 

In general, NEMA recommended that 

DOE use the lowest-rated-wattage 

ballast to propose energy efficiency 

levels and the most prevalent model 

within a class to determine the volume 

of shipments. NEMA explained that the 

highest attainable efficiency for a rated 

wattage range is determined by the 

lowest-rated-wattage ballast, while in 

many cases that equipment may not 

represent the highest volume. OSI 

explained that the ballast losses (power 

dissipated within the ballast) in a lowerrated-wattage ballast represent a higher 

percentage of the total system wattage, 

thus resulting in lower efficiencies at 

lower rated powers. In particular, 

NEMA, OSI, and NEEA disagreed with 

the choice of the 250 W fixture as the 

representative wattage for the 150 W to 

250 W equipment class, recommending 

instead 175 W as a more appropriate 

wattage due to its high market share. 

(OSI, Public Meeting Transcript, No. 33 

at p. 54; NEEA, No. 31 at p. 4; OSI, No. 

27 at p. 3; NEMA, No. 34 at p. 13) 

DOE recognizes that lower-ratedwattage ballasts will have lower 

efficiencies than higher-rated-wattage 

ballasts. To account for this effect in the 

NOPR, as discussed in section V.C.9, 

DOE is proposing to use equations for 

each wattage range to define minimum 

efficiency requirements as a function of 

rated lamp wattage. This equation-based 

approach allows DOE to, in general, 

base its selection of representative 

wattages, and thus the resulting 

economic analysis, on the high-marketshare products, while still ensuring 

technological feasibility of the entire 

equipment class. DOE has continued to 

use 250 W as the representative wattage 

primarily because it is the only wattage 

in the 150 W to 250 W equipment class 

with a range of commercially available 

magnetic ballast efficiencies above the 

EISA 2007 minimum requirements. By 

conducting a cost-efficiency analysis on 

250 W fixtures, DOE is able to 

characterize the potential energy savings 

of equipment within this class at 

efficiency levels below those 

characterized by electronic ballasts. 

Although 175 W fixtures may 

currently have high market share, DOE 

understands that EISA 2007 has caused, 

and may continue to cause, a significant 

shift from 175 W probe-start metal 

halide fixtures to the 150 W pulse-start 

fixtures exempted from EISA 2007 

standards. DOE believes that this may 

result in 250 W fixtures gaining market 

share (relative to 175 W fixtures) in the 

future. Thus, DOE believes that 250 W 

is an appropriate representative wattage 

for analysis. 

Because of the current and projected 

high market share of 150 W fixtures 

exempted from EISA standards, and to 

match the newly proposed equipment 

class for fixtures rated from 100 W to 

150 W (discussed in section V.A.2), 

DOE has decided to add a 150 W 

representative unit. Based on an 

assessment of commercially available 

fixtures and manufacturer interviews, 

DOE has come to the conclusion that 

150 W fixtures represent the vast 

majority of the equipment class and, 

therefore, believes it to be an 

appropriate representative wattage. 

In summary, after considering the 

comments received and changes to the 

proposed equipment class structure, 

DOE has selected five representative 

wattages for analysis: 70 W, 150 W, 250 

W, 400 W, and 1000 W. 

4. Representative Fixture Types 

After selecting representative wattages 

for analysis, DOE identified the 

applications commonly served by each 

equipment class’s wattage range in order 

to select representative Fixture Types. 

Although DOE is evaluating ballast 

efficiency only as a metric for reducing 

MHLF energy consumption, DOE 

recognizes that technological changes in 

the ballast, specifically moving from 

magnetic ballasts to electronic ballasts, 

can necessitate alterations to the fixture. 

These changes, discussed in further 

detail in section V.C.12, often incur 

additional costs dependent on the 

Fixture Type that is redesigned. In the 

engineering analysis, DOE estimates a 

baseline fixture cost as well as 


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28 Descriptions of each of these fixture types can 

be found in chapter 3 of the NOPR TSD. 

incremental costs to the fixture (with 

increasing ballast efficiency) based on 

the representative Fixture Types 

selected. 

For the preliminary analysis, DOE 

selected one to three representative 

Fixture Types for each rated wattage 

range. For wattages less than 150 W, 

DOE selected canopy fixtures as the 

representative Fixture Types. For 

wattages from 150 W to 250 W, DOE 

identified three representative fixture 

types: canopy, low-bay, and wallpack. 

For wattages greater than 250 W, DOE 

chose canopy, flood, and high-bay 

fixtures as representative fixture 

types.28 Georgia Power commented that 

DOE should consider post tops as a 

representative fixture for 150 W fixtures. 

(Georgia Power, No. 28.1 at p. 2) During 

metal halide lamp fixture manufacturer 

interviews, DOE requested market data 

on the most common Fixture Types sold 

for each wattage range analyzed. For the 

equipment class represented by the 150 

W fixture, DOE did not receive feedback 

that post-tops were a large portion of 

that market. Instead, manufacturers 

responded that area lighting and 

wallpacks comprised the majority of the 

150 W market. Thus, for this NOPR, and 

similar to the representative fixtures for 

the 150 W to 250 W equipment, DOE 

selected canopy, low-bay, and wallpack 

fixtures as representative fixture types 

for the 100 W to 150 W equipment class. 

5. Ballast Efficiency Testing 

After selecting representative wattages 

and fixture types, DOE purchased and 

tested a multitude of metal halide 

ballasts, ranging from low-efficiency 

magnetic to high-efficiency electronic, 

in order to evaluate the range of 

commercially available ballast 

efficiencies. In selecting units for testing 

and analysis, DOE focused its effort on 

representative wattage ballasts with 

operating characteristics similar to 

ballasts prevalent in the market. For 

example, through interviews and an 

assessment of commercially available 

products, DOE learned that the majority 

of metal halide ballasts sold are quadinput voltage ballasts. Thus, DOE 

primarily tested metal halide ballasts 

capable of quad-input or multiple-input 

voltage operation. 

Regarding magnetic circuit types, 

Progress Energy Carolinas commented 

that there is wide variation between 

magnetic operating characteristics of the 

different magnetic ballast types, such as 

regulated, magnetic regulated, CWA, 

reactor, and high-power-factor reactor. 

They suggested that DOE study this 

issue further to ensure proper selection 

of representative units for analysis. 

(Progress Energy Carolinas, No. 24 at p. 

2) In response, DOE has investigated the 

technical differences between magnetic 

circuit types and provides its 

assessment in Chapter 3 of the NOPR 

TSD. In addition, through an assessment 

of commercially available products and 

manufacturer interviews, DOE has 

learned that at low wattages (less than 

or equal to 150 W), high reactance 

autotransformer (HX–HPF) ballasts and 

CWA ballasts are most prevalent. At 

higher wattages, CWA ballasts compose 

the vast majority of the market. In 

consideration of these findings, DOE 

focused its testing and analysis on HX– 

HPF and CWA ballasts for the 70 W and 

150 W representative units and CWA 

ballasts for all other wattage units. 

Average ballast efficiencies (across 

four samples) were determined in 

accordance with metal halide ballast 

test procedures (10 CFR 431.324) by 

dividing measured output power by 

measured input power. As discussed in 

sections V.C.7 and V.C.8, DOE selects 

baseline and higher-efficiency 

representative units for analysis based 

on these average efficiencies. Also, as 

discussed in the following section, DOE 

determines representative ballast input 

power for each efficiency level based on 

these tested ballast efficiencies. To 

determine the efficiency levels under 

consideration, as discussed in section 

V.C.9, DOE uses a reported efficiency 

value based on the four tested samples, 

pursuant to the metal halide ballast 

certification procedures in 10 CFR 

429.54. 

6. Input Power Representations 

In the preliminary analysis, ballast 

input powers for use in the downstream 

analyses (such as the LCC and NIA 

analyses) were normalized such that the 

ballast outputted the rated lamp input 

power by dividing rated lamp wattage 

by measured ballast efficiency. In 

response, NEMA commented that 

ballast efficiency should not be 

calculated based on rated lamp power 

and input power. They remarked that 

not all ballasts operate lamps at their 

rated wattages and, thus, these ballasts 

could appear to have higher efficiencies 

than technologically feasible if this 

method is used. (NEMA, No. 34 at p. 13) 

To clarify, DOE is not calculating 

ballast efficiencies based on rated lamp 

powers. Rather, DOE is using measured 

ballast efficiencies and rated lamp 

output to calculate normalized input 

powers for the downstream energy-use 

analyses. Although DOE’s test results 

indicate slight variations in ballast 

output power relative to rated lamp 

power from unit to unit, based on the 

marketing of these ballasts, DOE 

concludes that the metal halide ballasts 

tested are generally designed to operate 

lamps at their rated wattages. DOE 

believes these variations (on the order of 

three percent of the rated lamp power) 

are unlikely to significantly affect 

average ballast efficiency. In this NOPR, 

DOE continues to utilize normalized 

input powers in order to best 

characterize the energy use of all 

products that meet a particular 

efficiency level and to eliminate any 

artifacts due to the particular model 

chosen. 

Additionally, OSI noted that the 

system wattage of magnetic ballasts 

increases up to 11 percent over lamp 

life. In contrast, electronic ballasts do 

not exhibit this behavior and, thus, have 

lower energy use relative to a magnetic 

system of the same efficiency when 

considering operation over the lifetime 

of the lamp. (OSI, No. 27 at p. 7) DOE’s 

research indicates that as metal halide 

lamps age, they require higher voltages. 

Electronic ballasts have the capability to 

sense that the lamp voltage has 

increased and, in response, decrease 

their output current to maintain 

constant wattage throughout the life of 

the ballast. The CA IOUs also noted that 

electronic ballasts can improve lamp 

efficacy and lumen maintenance, 

resulting in higher mean rated lumens 

over the lifetime of the lamp. The CA 

IOUs urged DOE to consider scenarios 

where either reduced-wattage lamps or 

fewer (but more luminous) total fixtures 

can be used with electronic ballasts to 

capture even greater energy savings 

while maintaining the same mean 

system light output as the baseline 

system. (CA IOUs, No. 32 at p. 4) 

DOE accounted for the increase in 

wattage for magnetic ballasts by using a 

multiplier when calculating magnetic 

efficiencies. DOE assumed that magnetic 

ballasts’ wattage increase occurs in a 

linear fashion over the life of the ballast. 

With this assumption, the ballast would 

average a 5.5 percent increase in output 

wattage over its lifetime. Therefore, DOE 

multiplied the rated lamp wattage by 

1.055 when calculating the input power 

normalized to rated lamp power for all 

magnetic ballasts, but not for electronic 

ballasts. To investigate electronic ballast 

lumen maintenance, DOE reviewed 

lamp and ballast manufacturer product 

information, but did not find a 

consistent description of the impact of 

an electronic ballast on lumen 

maintenance. Based on the limited 

information and uncertainty of the 

potential impacts, DOE is not proposing 

an adjustment to electronic ballast input 

power to account for improved lumen 


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maintenance relative to magnetic ballast 

operation. DOE requests comment on 

using a 5.5 percent increase when 

calculating the representative input 

power of magnetic ballasts. 

7. Baseline Ballast Models 

DOE selected baseline models as 

reference points for each representative 

equipment class, against which DOE 

measured changes in energy use and 

price resulting from potential amended 

energy conservation standards. For 

metal halide lamp fixtures and ballasts 

subject to existing Federal energy 

conservation standards, a baseline 

model is a commercially available 

ballast that just meets existing standards 

and provides basic consumer utility. If 

no standard exists for a specific fixture 

type (e.g., less than 150 W or greater 

than 500 W fixtures), DOE chooses 

baselines that represent lowest 

efficiency products (based on average 

test ballast efficiencies) or highestvolume products within the 

representative parameters defined (e.g., 

representative wattage, magnetic circuit 

type, input voltage). For the preliminary 

analysis, DOE analyzed a CWA, quadinput voltage, pulse-start baseline 

ballast for each of the 70 W, 250 W, 400 

W, and 1000 W representative wattages. 

As DOE received no adverse comment 

to the selection of the 70 W, 250 W, and 

400 W baselines, DOE continues to use 

the same baseline ballasts for the NOPR. 

The following paragraphs discuss 

changes to the 1000 W baseline and the 

additions of a second 70 W baseline and 

a new 150 W baseline. 

a. 70 W Baseline Ballast 

In the preliminary analysis, DOE 

analyzed a single 70 W magnetic ballast 

with an efficiency of 72.0 percent as the 

baseline unit. However, through 

manufacturer interviews, DOE has 

learned that electronic ballasts compose 

a significant portion (estimated as more 

than 25 percent) of the ≥50 W and ≤100 

W ballasts shipped with indoor fixtures. 

Therefore, for this NOPR, DOE has 

added an electronic baseline ballast for 

analysis. This ballast utilizes an LFE 

circuit, operates at quad-voltage, and 

has an efficiency of 88.0 percent. DOE 

requests comment on the addition of 

this electronic 70 W baseline ballast. 

150 W Baseline Ballast 

As discussed earlier, to analyze the 

new equipment classes with a rated 

wattage range of 100 W to 150 W, DOE 

has added a 150 W representative unit 

to its analysis. Through market research 

and ballast efficiency testing, DOE has 

determined that both CWA and HX– 

HPF ballasts are common at the 150 W 

level. Based on test results, DOE found 

the lowest efficiency ballast that could 

be incorporated into a fixture exempt 

from EISA 2007 standards was a 

magnetic pulse-start, quad-voltage CWA 

ballast with an efficiency of 81.2 

percent, and, thus, analyzed this ballast 

as a baseline. 

1000 W Baseline Ballast 

In the preliminary analysis, DOE 

selected a 1000 W CWA, quad-input 

voltage, magnetic, pulse-start ballast 

with an efficiency of 91.8 percent as a 

baseline for the >500 W equipment 

class. Since publication of the 

preliminary analysis, DOE has learned 

that although pulse-start ballasts are 

available at the 1000 W level, probestart, CWA, quad-voltage units 

predominate in this wattage category, 

and are, therefore, more appropriate 

baselines. Because DOE’s analysis 

indicates that ballast efficiency is not 

affected by starting method, DOE 

created a probe-start baseline by 

utilizing the same baseline ballast 

efficiency (91.8 percent) and applying a 

manufacturer production cost 

representative of a probe-start ballast. 

DOE further discusses the derivation of 

manufacturing production costs in 

section V.C.12 of this NOPR and in 

chapter 5 of the NOPR TSD. 

8. Selection of More Efficient Units 

After selection of baseline models, 

DOE used a combination of two 

methods to determine more efficient 

units for analysis within each 

representative equipment class. The first 

method was by examining DOE’s own 

test data (discussed in section V.C.5) to 

select commercially available ballasts to 

represent higher efficiency levels. The 

second method involved filling in large 

gaps of efficiency present in the test 

data (often between commercially 

available magnetic and electronic 

ballasts) through estimating efficiency 

increases due to the implementation of 

several of the design options described 

in section V.B. DOE derived those 

estimates based on manufacturer 

interviews and by validating or 

supplementing that input with 

independent modeling of potential 

reductions in losses. Specifically, DOE 

used the watts loss/pound 

characteristics for various steel types 

and the resistive losses for various 

winding materials to determine the 

levels of efficiency modeled ballasts 

could achieve. In modeling more 

efficient magnetic ballasts, DOE 

maintained the physical size of the 

higher-efficiency models relative to 

commercially available products within 

the representative wattages. DOE seeks 

comment on whether features or 

consumer utility of the ballasts such as 

the physical size, including footprint, 

stack height, and weight can be 

maintained or if they would be 

adversely affected for the magnetic 

ballast efficiencies associated with the 

modeled ballasts. 

In summary, for the NOPR, DOE 

developed a maximum technologically 

feasible magnetic ballast based on either 

commercially available equipment (for 

the 1000 W level) or a modeled ballast 

(for other representative wattages) that 

utilizes the highest grade steels 

practicable for manufacturing metal 

halide ballasts. DOE also developed a 

maximum technologically feasible 

electronic ballast (which also serves to 

represent the maximum technologically 

feasible level overall) for the 70 W, 150 

W, 250 W, and 400 W representative 

wattages. To determine this level, DOE 

conducted a survey of the MHLF market 

and the research fields that support the 

market. DOE concluded that, within a 

given equipment class, no working 

prototypes exist that have a 

distinguishably higher ballast efficiency 

than currently available electronic 

ballasts. As such, the highest-efficiency 

units analyzed in the engineering 

analysis represent the most efficient tier 

of commercially available equipment. 

For further details on the higherefficiency units analyzed in the NOPR, 

see chapter 5 of the NOPR TSD. 

DOE received several comments, 

discussed below, on the higherefficiency magnetic and electronic units 

analyzed in the preliminary analysis. 

a. Higher-Efficiency Magnetic Ballasts 

NEMA noted that magnetic ballasts 

are already as efficient as possible while 

still being cost-effective, and further 

changes to their designs could make 

them cost-prohibitive and not 

physically feasible for use in current 

products. In particular, NEMA stated 

that 150 W magnetic ballasts only exist 

on the market due to their current 

exemption from standards, and to make 

them any more efficient would involve 

a size increase and redesign. (NEMA, 

No. 34 at p. 7, 13–14) Similarly, Philips 

stated that 88 percent efficiency is the 

highest possible efficiency for 175 W 

magnetic ballasts, but it is not 

achievable for lower-wattage magnetic 

ballasts. (Philips, Public Meeting 

Transcript, No. 33 at pp. 69–70) 

On the other hand, the CA IOUs 

recommended that DOE re-examine the 

maximum technologically feasible 

efficiency for magnetic ballasts. They 

noted that according to the CEC 

database, 12 fixtures (at the 

representative 400 W level) listed by 


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manufacturers in 2010 used magnetic 

ballasts that claimed 93 percent or 

higher ballast efficiency, which 

significantly more efficient than DOE’s 

highest magnetic ballast analyzed. (CA 

IOUs, No. 32 at p. 5–6) 

As discussed in the screening analysis 

(section V.B), DOE recognizes that 

several commercially available magnetic 

ballasts (such as the 175 W 88-percent 

efficient ballast) may already utilize the 

highest efficiency design options and 

have reached their efficiency limits. 

However, based on feedback from 

manufacturer interviews, DOE has 

learned that for each of the 

representative wattages analyzed, there 

exist design options to improve 

efficiency. Therefore, DOE utilizes these 

design options to estimate the maximum 

technologically feasible efficiency for 

magnetic ballasts for each representative 

wattage. DOE does account for 

efficiency limits of non-representative 

wattages by creating efficiency-level 

equations (dependent on rated wattage) 

for each equipment class. In response to 

the CA IOUs comment, DOE reviewed 

the CEC database, but was unable find 

any of the more-efficient 400 W ballasts 

available for purchase. As DOE was 

unable to test these ballasts and confirm 

their higher efficiencies, DOE could not 

include them in this analysis. 

b. Electronic Ballasts 

In the preliminary analysis and in this 

NOPR, DOE analyzed electronic ballasts 

as higher-efficiency replacements to 

magnetic ballasts and based max tech 

efficiencies on commercially available 

electronic ballasts independently tested 

by DOE. In response to those 

efficiencies, DOE received several 

comments, discussed below, regarding 

the appropriate electronic max tech 

efficiencies, use of high-frequency 

electronic ballasts as representative 

units of analysis, and whether electronic 

ballasts should be considered the 

maximum technologically feasible level 

for 1000 W ballasts. 

Maximum Technologically Feasible 

Efficiencies 

Regarding the maximum 

technologically feasible efficiency of 

electronic ballasts, OSI stated that their 

commercially available ballasts 

represent the current max tech. Any 

further increases in efficiency would be 

theoretical and not proven through 

actual performance. (OSI, No. 27 at p. 5) 

In contrast, the CA IOUs noted that the 

CEC database contains several electronic 

ballasts from manufacturers such as 

Metrolight and Advance with 

efficiencies significantly higher than 

those identified as max tech. The CA 

IOUs encouraged DOE to revisit 

maximum achievable efficiencies for 

each equipment class and technology 

option. (CA IOUs, No. 32 at p. 5–6) 

As DOE does not have any indication 

electronic ballast efficiency can exceed 

that which is currently commercially 

available, DOE agrees with OSI’s 

assessment that any efficiency 

improvement above commercially 

available electronic ballasts would be 

widely speculative. Therefore, all of the 

max tech levels proposed by DOE reflect 

existing commercially available ballasts. 

DOE has attempted to purchase and test 

the highest-efficiency ballasts, as 

determined through catalog rated 

efficiencies and the CEC metal halide 

lamp fixture database. Thus, DOE 

believes that its max tech electronic 

ballast efficiencies represent the highest 

efficiencies that are commercially 

available and validated by independent 

testing in accordance with DOE’s metal 

halide ballast test procedures. 

High-Frequency Electronic Ballasts 

In the preliminary analysis, the 

maximum technologically feasible level 

for 400 W fixtures was based on a highfrequency electronic ballast. DOE 

requested comment on the 

appropriateness of using high-frequency 

electronic ballasts as representative 

units, particularly with respect to lamp 

and ballast compatibility concerns. 

In response, OSI, Philips, and NEMA 

opposed regulatory requirements 

obtainable only with high-frequency 

electronic ballasts. While they 

recognized that high-frequency 

electronic ballasts can have higher 

efficiencies, they noted that their test 

measurements also have a significantly 

higher degree of error (as high as five 

percent) than those obtained with lowfrequency ballasts. OSI and NEMA 

argued that if DOE establishes standards 

based on high-frequency technology, 

this increased variation should be 

accounted for. In addition, all three 

stakeholders remarked that highfrequency electronic ballast technology 

is often not compatible with the most 

efficacious systems, specifically noting 

their incompatibility with ceramic metal 

halide lamps, which represent the 

highest efficacy, best lumen 

maintenance, and longest life of metal 

halide lamps. (Philips, Public Meeting 

Transcript, No. 33 at p. 34, 62–63; OSI, 

No. 27 at p. 4; NEMA, No. 34 at p. 14) 

While acknowledging that there are 

some lamp and ballast compatibility 

concerns, Empower Electronics stated 

that high-frequency ballasts can be more 

efficient and should be used as a 

representative unit. (Empower 

Electronics, No. 36 at p. 8) 

In response, DOE has researched 

product application notes in catalogs 

and technical literature regarding lamp 

compatibility with high-frequency 

ballasts. Based on this research, DOE 

agrees that due to acoustic resonance 

issues, high-frequency ballasts may have 

significant compatibility problems with 

some high-efficacy metal halide lamps, 

thus, reducing potential energy savings 

at those levels. Although DOE maintains 

high-frequency electronic ballasts as a 

valid design option to improve ballast 

efficiency, DOE will take the impact of 

lamp and ballast compatibility into 

account when adopting any amended 

standards. 

Acuity also commented that highfrequency ballasts are less reliable in 

outdoor applications because ambient 

temperature and power quality effects. 

(Acuity, Public Meeting Transcript, No. 

33 at p. 63) DOE is considering in this 

NOPR (discussed in section V.C.12) 

fixture redesigns (accounting for 

increased thermal management and 

voltage transient suppression) and 

corresponding incremental costs 

incurred as a result of implementing 

electronic ballasts in outdoor 

applications. DOE has not found 

evidence of any difference between 

high-frequency and low-frequency 

electronic ballasts in this regard. DOE 

requests clarification on whether highfrequency electronic ballasts require 

additional thermal and transient 

protection relative to low-frequency 

electronic ballasts. If so, DOE requests 

comment on technical reasons for this 

difference and whether ballast or fixture 

redesigns can overcome these barriers. 

1000 W Electronic Ballasts 

In the preliminary analysis, DOE 

analyzed only magnetic ballasts as 

higher efficiency replacements for the 

1000 W baseline unit and requested 

comment on whether 1000 W electronic 

metal halide ballasts are technologically 

feasible. Philips and OSI stated that 

1000 W electronic ballasts only exist in 

niche applications, with no ballasts in 

general lighting or area lighting. Even 

though 1000 W electronic ballasts are 

commercially available, Philips pointed 

out that these ballasts do not have a 

significant efficiency improvement over 

the magnetic ballasts at that wattage, but 

may be preferred for technological 

reasons (e.g., in high definition TVs). 

(Philips, Public Meeting Transcript, No. 

33 at pp. 63–64; OSI, No. 27 at p. 5) 

NEEA also recommended that DOE 

analyze only magnetic ballasts at 1000 

W. (NEEA, No. 31 at p. 4) DOE’s 

research has confirmed that the 1000 W 

electronic ballasts on the market today 

appear to be for specialized functions, 


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such as hydroponics and aquariums, 

rather than general illumination 

applications. Because these fixtures may 

have unique thermal characteristics, 

DOE cannot be certain that 

incorporating 1000 W electronic ballasts 

into general lighting fixtures is 

technologically feasible. Thus, DOE 

does not consider electronic ballasts as 

higher efficiency replacements for 1000 

W magnetic ballasts. 

9. Efficiency Levels 

Based on the higher-efficiency ballasts 

selected for analysis, discussed in 

section V.C.8, DOE developed four 

efficiency levels for the 70 W, 150 W, 

250 W, and 400 W representative 

wattages. Due to the fact that DOE did 

not analyze electronic ballasts for the 

1000 W representative wattages, DOE 

analyzes only two efficiency levels for 

this wattage. The baseline of each 

representative equipment class 

represents the lowest-efficiency 

commercially available magnetic ballast 

covered by these standards. EL1 

represents a moderately higher 

efficiency magnetic ballast, and EL2 

represents the maximum 

technologically feasible magnetic 

ballast. EL1 and EL2 are characterized 

by a combination of commercially 

available and modeled magnetic 

ballasts. EL3 represents the lowestefficiency commercially available 

electronic ballast, and EL4 represents 

the maximum technologically feasible 

level for all ballasts incorporated into 

metal halide lamp fixtures. 

In the preliminary analysis, DOE 

considered both binned and equationbased approaches to defining efficiency 

levels within wattage ranges. In a 

binned approach, DOE would set the 

same standard for all wattages within an 

equipment class. In an equation-based 

approach, DOE would define equations 

that relate rated lamp wattage to ballast 

efficiency such that different wattages 

within an equipment class would be 

subject to different efficiency 

requirements. For the preliminary 

analysis, DOE analyzed setting 

standards based on a binned approach 

and received several comments in 

response to this decision. 

Philips noted that there is significant 

change in ballast efficiency throughout 

the 150 W to 250 W range, with a 

definite trend for higher efficiency as 

the wattage increases up to 500 W. 

(Philips, Public Meeting Transcript, No. 

33 at pp. 55, 66) Philips suggested that 

efficiencies in the 150 W to 250 W range 

could benefit from further delineation, 

perhaps in the form of a formula 

approach. (Philips, Public Meeting 

Transcript, No. 33 at p. 47) Based on 

manufacturer comments at the 

preliminary analysis public meeting, 

NEEA supported the proposal to either 

divide the 150 W to 250 W range into 

two classes, or develop efficiency levels 

in the form of wattage-based equations. 

(NEEA, No. 31 at pp. 3–4) 

In contrast, OSI did not recommend 

using an equation-based approach for 

efficiency levels. They commented that 

having a known, fixed efficiency 

requirement allows manufacturers to 

more easily redesign their ballasts to 

incorporate additional features (such as 

dimming or 120 V tap). (OSI, No. 27 at 

p. 4) 

After considering all of the comments, 

DOE agrees with Philips and NEEA that 

an equation-based approach for 

efficiency levels would be most 

appropriate, as it allows DOE to account 

for changes in efficiency across a rated 

wattage range. In addition, this 

approach ensures that efficiency levels 

for all wattages, even those not analyzed 

as representative, are technologically 

feasible. To develop the equation forms 

and efficiency trends for each wattage 

range, DOE utilized its own efficiency 

test data as well as catalog efficiency 

data. The discussion below describes 

the equations used in each wattage bin. 

For further details, see chapter 5 of the 

NOPR TSD. 

For the two lowest wattage bins, 

which consist of 50 W to 150 W ballasts, 

DOE used its own test data as well as 

efficiency trends according to catalog 

data to generate separate power-law best 

fits for magnetic (EL1 and EL2) and 

electronic ballasts (EL3 and EL4). 

The next wattage bin consists of 150 

W ballasts, excluding the currently 

exempted 150 W, up through and 

including 250 W ballasts. Because EISA 

2007 covered equipment in this wattage 

bin, DOE can only evaluate efficiencies 

equal to or above the existing standards 

to avoid backsliding. Manufacturers 

stated during interviews that 150 W 

magnetic ballasts could not be designed 

to meet 88 percent and that 175 W 

ballasts only reached 88 percent by 

using the high-grade-score steel and 

increasing the ballast’s footprint. DOE’s 

test data also indicated that there are no 

150 or 175 W magnetic ballasts available 

that exceed 88 percent efficiency. 

Though DOE did not test any 200 W 

ballasts, a review of catalog data 

indicates that 200 W ballasts are only 

available at 88 percent efficiency. 

Because DOE has no specific 

information indicating that these 

ballasts can be designed to be more 

efficient, DOE assumed that 88 percent 

is also the max tech magnetic ballast 

efficiency for wattages up through 200 

W. Thus, DOE maintained the EISA 

2007 efficiency requirement of 88 

percent for ELs designed to represent 

levels met by magnetic ballasts. DOE 

did not have any information about the 

achievable efficiencies for ballasts >200 

W and <250 W, as products in this range 

are not commercially available. 

Therefore, DOE gradually increased the 

magnetic efficiency levels (EL1 and EL2) 

between 200 W and 250 W ballasts 

using a linear trend from 88 percent to 

the efficiency of the EL1 and EL2 250 

W representative units. For the 

electronic ballast efficiency levels (EL3 

and EL4), DOE continued the power-law 

function fit from the 50 to 150 W range 

up to 250 W. 

The next wattage bin consists of 

ballasts higher than 250 W up through 

and including 500 W. Because the 250 

W and 400 W magnetic representative 

units at EL1 and EL2 have the same 

efficiency and utilize similar design 

options, DOE created a flat efficiency 

requirement for magnetic ballasts within 

this wattage bin. For the electronic 

ballast efficiency levels (EL3 and EL4), 

DOE continued the power-law function 

fit from the 250 to 500 W range up 

through 500 W. 

The highest wattage bin consists of 

ballasts higher than 500 W up through 

and including 2000 W. DOE examined 

catalog data for market availability and 

found no electronic ballasts for general 

lighting applications in this wattage 

range. Manufacturer feedback confirmed 

that there are no electronic ballasts for 

general lighting applications 

commercially available above 500 W. 

Thus, there are two only efficiency 

levels at the highest wattage range rather 

than four. DOE used a linear fit for 

ballasts above 500 W through 1000 W 

after examining the efficiency trends 

within manufacturers’ product lines in 

this wattage bin. DOE fit the linear trend 

from the previous wattage bin’s 500 W 

efficiencies at efficiency levels 1 and 2 

through the representative units at 1000 

W. However, due to the lack of test data 

and limited wattage offerings for ballasts 

over 1000 W, DOE could not develop a 

conclusive trend between wattage and 

efficiency. Thus DOE created a flat 

efficiency requirement extending from 

the tested efficiency of the 1000 W 

representative unit to 2000 W. 

Table V.3 summarizes all of the 

functions and efficiencies describing 

each equipment class. DOE requests 

comment on the described efficiency 

levels. 


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TABLE V.3—NOPR EFFICIENCY LEVEL DESCRIPTIONS FOR THE REPRESENTATIVE EQUIPMENT CLASS

Representative equipment class Rep. 

wattage EL Minimum efficiency equation % 

≥50 W and ≤100 W ......................... 70 W ... EL1 100/(1+3.90*P∧(¥0.60)) † 

............. EL2 100/(1+2.50*P∧(¥0.55)) 

............. EL3 100/(1+0.60*P∧(¥0.34)) 

............. EL4 100/(1+0.36*P∧(¥0.30)) 

>100 W and <150 W* ..................... 150 W EL1 100/(1+3.90*P∧(¥0.60)) 

............. EL2 100/(1+2.50*P∧(¥0.55)) 

............. EL3 100/(1+0.60*P∧(¥0.34)) 

............. EL4 100/(1+0.36*P∧(¥0.30)) 

≥150 W** and ≤250 W .................... 250 W EL1 ≥150 W and ≤200 W: 88.0 ......................... >200 W and ≤250 W: 4.0*10∧(¥2)*P + 

80.0 

............. EL2 ≥150 W and ≤200 W: 88.0 ......................... >200 W and ≤250 W: 7.0*10∧(¥2)*P + 

74.0 

............. EL3 100/(1+0.60*P∧(¥0.34)) 

............. EL4 100/(1+0.36*P∧(¥0.30)) 

>250 W and ≤500 W ....................... 400 W EL1 90.0 

............. EL2 91.5 

............. EL3 100/(1+0.60*P∧(¥0.34)) 

............. EL4 100/(1+0.36*P∧(¥0.30)) 

>500 W and ≤2000 W ..................... 1000 W EL1 >500 W and ≤1000 W: 5.0*10∧(¥3)*P + 

87.5.

>1000 W and ≤2000 W: 92.5 

............. EL2 >500 W and ≤1000 W: 3.2*10∧(¥3)*P + 

89.9.

>1000 W and ≤2000 W: 93.1 

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified 

by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50° C, 

as specified by UL 1029–2001. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 

50° C, as specified by UL 1029–2001. 

† P is defined as the rated wattage of the lamp the fixture is designed to operate. 

As discussed in section V.C.5, DOE 

used a reported efficiency value based 

on the four tested samples, pursuant to 

the metal halide ballast certification 

procedures in 10 CFR 429.54, to 

describe its representative units and to 

develop the ELs. DOE invites comment 

on whether any adjustments to the ELs 

are necessary to account for sources of 

variation not captured by the reporting 

requirements of 10 CFR 429.54. 

10. Design Standard 

In the preliminary TSD, DOE 

considered a design standard that would 

prohibit the sale of probe-start ballasts 

in newly sold fixtures. DOE notes that 

under 42 U.S.C. 6295(hh)(4), DOE is 

permitted to set an energy efficiency 

standard based on both design and 

performance requirements. EISA 

prescribed probe-start ballasts to be 94 

percent efficient, effectively banning 

probe-start ballasts between 150 and 500 

W (except those 150 W ballasts exempt 

by EISA) based on their inability to meet 

this performance requirement. (42 

U.S.C. 6295(hh)(1)(A)(ii) Manufacturers 

responded to the EISA 2007 standards 

by shifting their inventory to pulse-start 

ballasts, which are subject to less 

stringent standards. The following 

paragraphs describe comments received 

and DOE’s analysis of a design standard 

prohibiting probe-start ballasts to be 

sold in new fixtures in these wattages. 

With regards to probe-start ballast 

availability, OSI, NEMA, Hubbell 

Lighting Incorporated, Venture Lighting, 

and NEEA also commented that there 

are no 70 W probe-start ballasts on the 

market. (OSI, Public Meeting Transcript, 

No. 33 at pp. 58–60; NEMA, No. 34 at 

p. 14; Hubbell, Public Meeting 

Transcript, No. 33 at pp. 42, 57, 59–60; 

Venture Lighting, Public Meeting 

Transcript, No. 33 at pp. 59–60; NEEA, 

No. 31 at p. 4) Hubbell also clarified that 

probe-start ballasts are available at 

wattages of 150 W and above. Hubbell 

stated that there are a few probe-start 

ballasts at 150 W and there are no 

probe-start ballasts at smaller wattages 

because the seals for the arc tubes in the 

lamps become too small to contain the 

third electrode needed to start probestart ballasts. OSI added that when 

medium screw-base, low-wattage metal 

halide lamps were first introduced to 

the market, they were all pulse-start. 

The manufacturers never made lowwattage probe-start metal halide lamps. 

(Hubbell, Public Meeting Transcript, 

No. 33 at pp. 58–59; OSI, Public 

Meeting Transcript, No. 33 at p. 59) 

Even though probe-start has become 

technically possible at 150 W, OSI and 

NEMA pointed out that because of EISA 

2007, there are no new fixtures using 

probe-start ballasts less than 500 W, 

and, therefore, no probe-start ballasts at 

less than 500 W on the market. (OSI, No. 

27 at p. 5; NEMA, No. 34 at p. 15) 

Hubbell noted that pulse-start ballasts 

only provide 8 to 15 percent energy 

savings over probe-start ballasts for 250 

W and 400 W products, and anywhere 

from 0 to 8 percent energy savings over 

probe-start ballasts in the 1000 W class. 

(Hubbell, Public Meeting Transcript, 

No. 33 at p. 42–43) GE put forward one 

cause for the mistaken impression that 

there are probe-start ballasts at lower 

wattages: In the manufacturers’ fixture 

catalogues, the lamp designation given 

for lower wattages is ‘‘M,’’ for metal 

halide. Even though the starting method 

of these lower wattage lamps is not 

explicitly labeled, they are all pulsestart. (GE, Public Meeting Transcript, 

No. 33 at p. 60) Finally, NEMA and 

Hubbell commented further that only 

1000 W ballasts have a probe-start 

baseline. (NEMA, No. 34 at p. 14; 

Hubbell, Public Meeting Transcript, No. 

33 at pp. 57–58) 


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DOE reexamined ballast availability 

in manufacturer catalogs and, in 

response to GE, was careful not to 

consider ‘‘M’’ designated lamps as 

probe-start. DOE determined that probestart ballasts are only available at 

wattages above 150 W and also 

confirmed that there are no 70 W probestart ballasts currently on the market. 

EISA 2007 allowed probe-start ballasts 

in the 150 W to 500 W range, but set a 

minimum efficiency standard of 94 

percent. None of the probe-start ballasts 

DOE found could meet this minimum 

efficiency level, so the standards from 

EISA 2007 essentially prohibit probestart ballasts less than or equal to 500 

W for use in new fixtures. However, 

because certain fixtures designed for use 

with lamps rated at 150 W are exempted 

from EISA 2007 standards, probe-start 

ballasts can be used at 150 W in new 

fixtures. However, DOE’s review of 

manufacturer catalogs indicates that 

probe-start ballasts are not sold at 150 

W. Therefore, the only wattage range in 

which probe-start ballasts are available 

for use in new fixtures is the greater 

than 500 W to 2000 W range. In this 

NOPR, DOE is analyzing the impact of 

a design standard that would prohibit 

probe-start ballasts from being sold in 

new fixtures in the greater than 500 to 

2000 W range. 

NEMA and Hubbell also commented 

that at that high wattage, there is very 

little to be gained from a switch to 

pulse-start, stating that 1000 W probestart ballasts are already 92 percent 

efficient and these lamp-ballast systems 

produce only slightly fewer mean 

lumens than pulse-start lamp-ballast 

systems. (NEMA, No. 34 at p. 14; 

Hubbell, Public Meeting Transcript, No. 

33 at pp. 57–58) Given the absence of 

probe-start ballasts at the lower 

wattages, and the insignificant 

discrepancy between probe-start and 

pulse-start ballasts at the higher 

wattages, NEEA did not see much utility 

in a design standard that prohibits 

probe-start systems. (NEEA, No. 31 at p. 

3) DOE notes that the major motivation 

for prohibiting probe-start ballasts is not 

the efficiency difference between the 

ballasts, but the decreased mean efficacy 

of probe-start lamps when compared to 

pulse-start lamps. Even a small 

percentage gain in mean lamp efficacy 

could yield energy savings on the order 

of the ballast efficiency savings 

calculated in other equipment classes. 

Progress Energy Carolinas, however, 

supported requiring pulse-start ballasts 

in all wattages. Yet, Progress Energy 

Carolinas also urged DOE to consider 

other technologies to realize significant 

efficiency gains over pulse-start. 

Specifically, Progress Energy Carolinas 

cited the examples of ceramic arc tube 

metal halide lamps and the super metal 

halide technology as seen in the Elite 

and Cosmopolis models from Philips. 

Progress Energy Carolinas argued that 

both of these measures improve not only 

efficiency, but also other operating 

characteristics. While Progress Energy 

Carolinas noted that the super 

technology may be sole-source, 

proprietary technology only available in 

low- to mid-range wattages, Progress 

Energy Carolinas commented that 

Philips may be willing to share the 

technology with others like they have 

offered to do with their fluorescent lowmercury lamp technology. (Progress 

Energy Carolinas, No. 24 at p. 2) DOE 

will not consider efficiency levels that 

require proprietary technology like that 

used in the Philips Elite and 

Cosmopolis systems. Though a company 

like Philips may be willing to share 

technology, DOE is unable to analyze 

the impacts of the agreement because 

the terms of the agreement cannot be 

known in advance. In this MHLF 

rulemaking, DOE has decided to only 

consider performance and design 

requirements that affect the ballast 

included in a metal halide lamp fixture. 

Therefore, DOE is not planning to 

consider a design requirement that 

mandates the use of ceramic metal 

halide lamps in new metal halide lamp 

fixtures. 

Empower Electronics disagreed with 

the use of a design standard, instead 

recommending that a minimum ballastand-lamp efficiency standard be 

established regardless of design to 

effectively prohibit the use of inefficient 

probe-start systems. Empower 

Electronics suggested that this standard 

be set at 94 percent for fixtures designed 

to operate lamps rated for 250 W and 

above, effectively requiring electronic 

ballast technology. (Empower 

Electronics, No. 36 at p. 8) DOE notes 

that it is planning to consider efficiency 

levels that require electronic ballasts 

when determining a proposed standard. 

In addition to this consideration, DOE is 

also continuing to analyze a design 

standard as a possibility for a proposed 

standard. 

Georgia Power stated that the concept 

of using fewer fixtures when replacing 

existing probe-start systems with pulsestart systems may be practical for indoor 

applications, but not for outdoor uses. 

Currently, parking lots have lighting 

system designs that use probe-start 

fixtures at an acceptable photometric 

level. DOE assumes that the poles, bases 

and conductors are all in place and the 

investment has been made. Georgia 

Power said that using fewer pulse-start 

fixtures on the same poles at the same 

places will not result in the same 

photometric design. (Georgia Power, No. 

28 at p. 2) In regards to setting a design 

standard requiring reduced wattage 

versions of lamps and the expected 

change in lumen output, Progress 

Energy Carolinas said that in general, 

the percent light reduction is half the 

percent wattage reduction. Progress 

Energy Carolinas also noted that 

reduced wattage pulse-start lamps are 

not currently available; instead, a 

reduced wattage probe-start lamp is 

used as a replacement. (Progress Energy 

Carolinas, No. 24 at p. 3) DOE agrees 

with Georgia Power that in some 

applications, changing the spacing of 

fixtures is not feasible. Instead, users of 

these applications may use the same 

number of pulse-start ballasts in their 

systems, but at reduced wattage to 

maintain light output. This customer 

response to a design standard is 

discussed in more detail in section 

V.C.10. DOE disagrees with Progress 

Energy Carolinas that reduced-wattage 

lamps are only available in the probestart variety. DOE has found several 

pulse-start lamps available at reduced 

wattages such as 320 W and 875 W. 

To quantify the difference in mean 

lumen output of probe-start lamps 

relative to pulse-start lamps of the same 

wattage, DOE compared several major 

manufacturers’ 1000 W lamp catalog 

data for these two lamp start types. DOE 

paired these lamps from the same 

manufacturer and of the same 

characteristics (open vs. enclosed, CRI, 

percentage of rated life at which the 

mean lumen value is recorded) and 

calculated the ratio of probe-start mean 

lumens divided by pulse-start mean 

lumens. Then, DOE averaged the ratio of 

each pairing from every manufacturer 

and determined that, on average, probestart metal halide lamps are 5.6 percent 

less efficacious than comparable pulsestart lamps. Thus, pulse-start metal 

halide lamp and ballast fixtures can 

output 5.6 percent more lm/W than 

probe-start fixtures. Energy savings 

could be achieved in two ways. Because 

each pulse-start metal halide lamp 

fixture outputs 5.6 percent more lumens 

(for a given wattage) than comparable 

probe-start lamp fixtures, customers 

could: 

1. Illuminate an area to the same level 

with 5.6 percent fewer fixtures if they 

switch from probe-start to pulse-start; or 

2. Switch from full-wattage probestart lamp fixtures to the same number 

of reduced-wattage pulse-start lamp 

fixtures, maintaining light output, but 

reducing energy consumption. 

Using fewer fixtures (option 1) would 

lead to reduced energy consumption 

and could save administrative and 


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29When viewed from the company-wide 

perspective, the sum of all material, labor, and 

overhead costs equals the company’s sales cost, also 

referred to as the cost of goods sold (COGS). 

maintenance costs associated with 

purchasing and maintaining fewer 

fixtures. However, this response to the 

design standard is only feasible in 

applications that have flexibility in 

fixture spacing. In some applications, 

such as small parking lots, changing 

spacing means moving poles and 

conductors, which would be expensive 

and could change the targeting of light 

in certain areas. For applications in 

which the height of the fixture is 

limited, the additional light output of a 

full-wattage pulse-start system might 

not be adequately distributed over a 

larger floor space (because the number 

of fixtures has been reduced) without 

fixture redesign. 

For customers using reduced-wattage 

pulse-start fixtures (option 2), a 

customer could, for example, change a 

1000 W probe-start fixture for an 875 W 

pulse-start fixture, maintaining light 

output to near the original level. DOE’s 

view is that replacing probe-start lamp 

fixtures with reduced-wattage pulsestart lamp fixtures is generally more 

realistic and practical than replacing 

them with fewer pulse-start lamp 

fixtures because fixture spacing does not 

need to be changed. For this reason, 

DOE assumed reduced-wattage 

replacements in its analysis of a 

proposed design standard to prohibit 

metal halide lamp fixtures that use 

probe-start as their starting method. 

When analyzing the energy-savings 

impact of a design standard efficiency 

level, DOE multiplied the normalized 

input power of the 1000 W ballast tested 

by 0.944. Because DOE determined that 

using the same number of reducedwattage fixtures is the most likely 

market response to a design standard, 

DOE did not also scale the cost of a 

design standard efficiency level by 

0.944. Instead, DOE assumed that 

reduced-wattage systems would cost 

approximately the same amount as fullwattage systems, with the exception of 

the addition of an igniter (device that 

provides a voltage pulse to start the 

lamp). In the non-design-standard 

scenario, DOE assumed that the 

representative cost of a 1000 W ballast 

would equal the cost of a probe-start 

ballast as this starting method is the 

most common in the greater than 500 W 

but less than or equal to 2000 W 

equipment classes. However, in the 

design-standard scenario, an igniter 

would need to be added, as only pulsestart ballasts could be included in new 

fixtures. 

DOE requests comment on the 

decision to include a design standard 

that would prohibit the sale of probestart ballasts in newly sold fixtures, the 

proposed methods of analyzing these 

levels, and the potential for lessening of 

the utility or the performance through 

the prohibition of the sale of probe-start 

ballasts in newly sold fixtures. 

11. Scaling to Equipment Classes Not 

Analyzed 

In the preliminary analysis, DOE 

analyzed all equipment classes as 

representative and, therefore, did not 

scale. As discussed in section V.C.2, 

DOE has added additional equipment 

classes for the NOPR. Although DOE set 

efficiency levels for quad-voltage 

ballasts directly, DOE did not analyze 

480 V input voltage ballasts directly. 

Thus, it was necessary to develop a 

scaling relationship for this input 

voltage. To do so, DOE compared quadvoltage ballasts to their 480 V ballast 

counterparts using catalog data over all 

representative wattages at various 

efficiencies. DOE found the average 

reduction to ballast efficiency to be 0.6 

percent. Thus, DOE proposes to apply 

this scaling factor to the efficiency 

levels for the quad-volt ballasts to 

determine the appropriate values for the 

480 V ballasts. For the ≥150 W to ≤250 

W equipment classes, DOE made 

adjustments to resulting scaled 

equations to ensure all efficiency levels 

were more stringent than the existing 

standards (see chapter 5 of the NOPR 

TSD for additional detail). DOE requests 

comment on this proposal. 

12. Manufacturer Selling Prices 

For the preliminary analysis, DOE 

developed the manufacturer selling 

prices for metal halide lamp fixtures 

and ballasts by determining a 

manufacturer production cost (MPC), 

either through a teardown or retail 

pricing analysis, and then applying a 

markups analysis to arrive at the 

manufacturer selling price (MSP). For 

further details on this analysis, see 

chapter 5 of the NOPR TSD. 

Based on stakeholder comments and 

manufacturer interviews, DOE adjusted 

a number of parameters in its pricing 

analysis for this NOPR. In calculating 

prices, DOE adjusted material prices to 

better reflect current trends based on 

manufacturer input and commodity 

prices research. Additionally, for this 

NOPR, DOE applied incremental costs 

to fixtures utilizing electronic ballasts 

based on application characteristics 

(indoor vs. outdoor). Finally, DOE 

modified its approach to applying 

manufacturer markups to align better 

with existing fixture component 

manufacturing channels. The following 

sections describe these changes and 

approaches. 

a. Manufacturer Production Costs 

For the NOPR analyses, DOE 

conducted teardown analyses on a total 

of 32 commercially available metal 

halide ballasts (including four 150 W 

ballasts not presented in the preliminary 

analysis) and eight metal halide lamp 

fixtures. Using the information from 

these teardowns, DOE summed the 

direct materials, labor, and overhead 

costs used to manufacture a product to 

calculate the MPC.29 In the case of 

electronic ballasts, direct material costs 

represent the direct purchase price of 

components (resistors, connecting 

wires, etc.). In the case of magnetic 

ballasts, direct material costs represent 

the purchase prices of steel laminations, 

copper wires, and other components. 

The direct labor costs include 

fabrication and assembly labor. 

When determining material costs, 

DOE used material prices based on a 

five-year average to account for the 

fluctuations in the prices of certain raw 

materials, such as steel and copper. 

Several manufacturers of ballasts and 

fixtures noted the high prices and 

scarcity of copper and high-grade steels, 

such as M6 steel. Philips also 

commented that M6 steel is mostly 

manufactured in China, resulting in 

potential import difficulties. Acuity 

stated that volatility of material markets, 

especially in the availability and pricing 

of steel and copper, has greatly 

increased since the preliminary 

analysis. Acuity and NEMA suggested 

that DOE consider availability and price 

volatility of an improved steel core or 

copper wiring in their cost analysis. 

NEMA suggested that DOE factor in 

expected inflation and price volatility 

for materials. (Philips, Public Meeting 

Transcript, No. 33 at p. 71; Hubbell, 

Public Meeting Transcript, No. 33 at p. 

70; NEMA, No. 34 at p. 7, 12, 16; 

Acuity, Public Meeting Transcript, No. 

33 at p. 132–133) 

DOE agrees that high-grade steel 

laminations and copper are materials 

that have seen high price fluctuations in 

recent years. Due to the uncertainty of 

how these prices will continue to 

change, DOE continues to use five-year 

average materials prices, rather than 

projected inflations, to characterize the 

expected cost impacts in years following 

the compliance date of the amended 

standards considered in this rule. For 

this NOPR, DOE updated these averages 

to include 2010 price data. 

For the preliminary analysis, DOE 

used financial data to estimate the 


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30http://www1.eere.energy.gov/buildings/

appliance_standards/product.aspx/productid/62. 

overhead cost (including indirect 

material and labor costs, maintenance, 

depreciation, taxes, and insurance 

related to assets) by calculating it as a 

percentage of the MPC. NEEA noted that 

manufacturers have previously 

recommended that DOE apply overhead 

only to labor costs. NEEA urged DOE to 

ensure that this part of the analysis 

accurately reflects reality in the 

manufacturing world relevant to each 

rulemaking. (NEEA, No. 31 at p. 5) 

NEMA and OSI noted that 

manufacturing and overhead costs can 

vary greatly by manufacturer, 

production volume, and complexity of 

the product (e.g., magnetic versus 

electronic technology). NEMA stated 

that design and overhead costs for 

electronic ballasts are inherently higher 

than those for magnetic ballasts and 

require different engineering 

specializations. (NEMA, No. 34 at p. 16; 

OSI, No. 27 at p. 5) 

DOE recognizes that manufacturing 

and overhead costs can vary and, 

therefore, developed separate estimates 

for material, labor, and overhead for 

each representative unit in the analysis. 

In response to NEEA’s comment, DOE 

notes that because it calculates overhead 

from available financial data, it can 

either calculate overhead as a 

percentage of the material and labor 

costs, or labor costs alone. In either case, 

overhead as a percentage of net sales 

remains the same. Thus, DOE 

maintained its approach from the 

preliminary TSD by utilizing 

information available in the recent 

standards rulemaking for fluorescent 

lamp ballasts.30 In that rulemaking, DOE 

used financial data to estimate the 

overhead cost by calculating it as a 

percentage of the MPC. DOE estimated 

the depreciation cost from a 

representative electronics fabrication 

company’s U.S. Securities and Exchange 

Commission (SEC) 10–K, and 

determined that it is approximately 2.6 

percent of the cost of goods sold or the 

MPC. To determine the material and 

labor percentage, DOE marked down 

aggregated confidential MSPs to an MPC 

using the manufacturer markup. Then, 

DOE computed the ratio of aggregated 

teardown-sourced material and labor 

costs to the manufacturer-markdownsourced MPC. DOE found the material 

and labor costs to be approximately 93.8 

percent of the MPC. DOE then 

subtracted the materials and labor and 

depreciation percentages from 100 

percent to back out the remainder of 

overhead as a percentage of MPC. 

Overhead was estimated to be 3.6 

percent of the MPC. DOE found 

overhead and depreciation to be 6.2 

percent of the MPC or 6.6 percent of the 

material and labor costs. The 6.6 percent 

factor was then used to mark up the 

material and labor costs contained in 

the teardown results to the MPC. 

Incremental Costs for Electronically 

Ballasted Fixtures 

After determining metal halide ballast 

MPCs and baseline fixture MPCs, DOE 

considered whether transitioning from 

magnetic to electronic ballast 

technology would require any further 

ballast or fixture design changes to 

accommodate the electronic ballast or 

maintain similar utility to the baseline 

magnetic ballast. In the preliminary 

analysis, DOE identified three potential 

sources of additional costs of switching 

from magnetic to electronic ballasts: 

Increasing the size of the fixture to 

accommodate the new footprint of the 

electronic ballast; increasing the heat 

sinking of the fixture to reduce thermal 

build up; and including voltage 

transient suppression for outdoor 

applications. 

Based on its initial evaluation, DOE 

did not include any of these incremental 

costs in the preliminary analysis. In 

response, Philips and Georgia Power 

emphasized that electronic ballasts are 

not direct replacements for magnetic 

ballasts due to form factor. (Philips 

Lighting Electronics, Public Meeting 

Transcript, No. 33 at p. 64; Georgia 

Power, No. 28 at p. 1) Georgia Power 

noted that redesign of magnetic ballast 

fixture housing and optics may be 

required to accommodate electronic 

ballasts. (Georgia Power, No. 28 at p. 1) 

NEEA did not agree that there are no 

fixture incremental costs associated 

with a switch to electronic ballasts. 

NEEA recommended that DOE derive 

some incremental cost values for the 

analysis, and to the extent possible, use 

a distribution of costs for the analysis, 

perhaps with zero at the bottom end. 

(NEEA, No. 31 at p. 5) 

While DOE agrees that fixtures may 

require redesign to accommodate a new 

form factor of ballast, based on its 

analysis of selected commercially 

available fixtures, DOE tentatively 

concludes that this redesign does not 

necessarily incur additional material or 

labor costs. Instead, DOE accounts for 

the capital conversion costs of 

redesigning fixtures in the MIA, as 

discussed in section V.I.2. However, for 

this NOPR, DOE further investigated 

three sources of potential incremental 

costs: (1) Outdoor transient protection, 

(2) thermal management, and (3) 120 V 

auxiliary power functionality. 

Outdoor Transient Protection 

In response to the preliminary TSD, 

DOE received a number of comments 

indicating that electronic ballasts were 

unfit to be used outside because of their 

inability to withstand high voltage 

surges. Cooper commented that the 

ANSI standard for area and roadway 

lighting in the utility division, ANSI 

C62.41.1–2002, requires that outdoor 

lighting be able to withstand a voltage 

transient of 10 kV. (Cooper, Public 

Meeting Transcript, No. 33 at p. 78) 

Progress Energy Carolinas specified that 

an inline MOV (a surge-protection 

device external to the ballast) is 

required for electronic ballasts in 

outdoor fixture. (Progress Energy 

Carolinas, No. 24 at p. 3) In response, 

OSI and Empower Electronics 

commented that some electronic ballasts 

incorporate integral transient protection 

and do not require additional 

technology. (OSI, Public Meeting 

Transcript, No. 33 at p. 74; Empower 

Electronics, No. 36 at p. 5) Similarly, 

NEEA agreed that because many 

electronic ballasts have voltage transient 

protection built-in already, transient 

protection will not be an incremental 

cost in all cases. (NEEA, No. 31 at p. 5) 

DOE recognizes the necessity for 

outdoor fixtures to be able to withstand 

large voltage transients, primarily due to 

lightning strikes. While metal halide 

fixtures with magnetic ballasts are 

robust and do not require any additional 

devices or enhancements to withstand 

these transients, based on its evaluation 

of commercially available products, 

DOE finds that fixtures with electronic 

ballasts usually require additional 

design features in order to have 

adequate protection. Some 

manufacturers indicated that a portion 

of their electronic ballasts already have 

10 kV surge protection built in, but most 

electronic ballasts are only rated for 2.5– 

6 kV voltage spikes. Though magnetic 

ballasts are known to provide protection 

in excess of the 10 kV ANSI C62.41.1– 

2002 Class C rating, for this NOPR, DOE 

only considers the cost of meeting the 

10 kV requirement. Through interviews 

and an assessment of commercially 

available voltage-transient suppressors, 

DOE developed an incremental fixture 

cost of $19 for 10 kV inline (external to 

the ballast) surge protection for 

electronically ballasted outdoor fixtures. 

Thermal Management 

Commenters also indicated that 

electronic ballasts are more vulnerable 

than magnetic ballasts to high ambient 

temperatures, which, if not managed 

well, can cause premature ballast 

failure. In order to correct for this 


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difference, fixtures housing electronic 

ballasts would need to be redesigned to 

account for thermal management in both 

indoor and outdoor applications. 

NEMA expressed concern about 

electronic ballasts’ ability to operate at 

high ambient temperatures. (NEMA, 

Public Meeting Transcript, No. 33 at p. 

16) NEMA noted that while magnetic 

ballasts can operate at temperatures as 

high as 150 °C, electronic ballasts 

generally cannot operate at temperatures 

exceeding 90 °C. This temperature limit 

makes it impossible to place electronic 

ballasts in a fixture in the traditional 

location near the lamp. (NEMA, No. 34 

at pp. 8–9) NEMA and Progress Energy 

Carolinas indicated that the sensitivity 

of electronics to thermal conditions 

requires redesign of the fixture or 

ballast, such as larger ballast housing, 

thermal shields, or fixture venting to 

sink the heat outside of the fixture. 

(NEMA, No. 34. at pp. 8–9; Progress 

Energy Carolinas, No. 24 at p. 3) NEMA 

noted that these requirements add 

additional materials, redesigning, 

engineering, UL testing, and warranty 

burden costs. (NEMA, No. 34. at pp. 8– 

9) 

In contrast, OSI explained that 

electronic ballasts are more efficient 

than magnetic ballasts, and, therefore, 

generate less heat and run at cooler 

temperatures. OSI commented that they 

manufacture an electronic metal halide 

ballast with a maximum allowable case 

temperature of 90 °C, and a maximum 

ambient temperature of 55 °C. These 

ballasts also use a power foldback 

feature to manage the temperature of the 

ballast and prevent damage to the 

ballast in extreme high-heat conditions. 

OSI has successfully retrofitted 

magnetically ballasted fixtures with 

these electronic ballasts and achieved 

thermal performance that met the 

requirements of their five-year warranty. 

(OSI, No. 27 at p. 2) Empower 

Electronics noted that several 

companies have made strides in 

managing thermal issues surrounding 

electronic ballasts with a maximum 

tolerable case temperature of 85 °C. 

(Empower Electronics, No. 36 at p. 5) 

DOE agrees that because of 

temperature sensitivity concerns, 

manufacturers cannot directly replace a 

magnetic ballast with an electronic 

ballast in fixtures. Instead, the fixtures 

must be redesigned to tolerate the 

higher sensitivity to temperature of an 

electronic ballast. Manufacturers must 

design new and often larger brackets, 

and apply additional potting material to 

create an adequate thermal contact 

between the ballast and fixture. During 

interviews, manufacturers gave DOE 

information about the cost to add 

thermal management to fixtures with 

electronic ballasts. In aggregate, 

manufacturers indicated a 20-percent 

increase in fixture MPCs associated with 

thermal management. Additionally, 

DOE conducted teardown analyses of 

empty metal halide fixtures. Through 

analysis of pairs of fixtures designed for 

electronic ballasts and fixtures designed 

for comparable magnetic ballasts, DOE 

also found an approximately 20-percent 

increase in fixture MPCs to include 

thermal management for electronic 

ballasts. Accordingly, in the cost 

analysis for this rulemaking, all 

electronically ballasted metal halide 

lamp fixtures incur a 20-percent 

incremental cost to the empty fixture 

MPCs. 

120 V Auxiliary Tap 

In manufacturer interviews, DOE 

learned that for indoor applications, a 

number of magnetic ballasts include a 

120 V auxiliary tap. This output is used 

to operate an emergency incandescent 

lamp after a temporary loss of power 

and while the metal halide lamp is still 

too hot to restart. These taps, primarily 

used in indoor applications, are 

generally required for only one out of 

every ten indoor lamp fixtures. A 120 V 

tap is easily incorporated into a 

magnetic ballast due to its traditional 

core and coil design, and incurs a 

negligible incremental cost. Electronic 

ballasts, though, require additional 

design to add this 120 V auxiliary power 

functionality. Using a combination of 

manufacturer information and market 

research, DOE concluded that a 

representative value for electronic 

ballasts to incorporate this auxiliary tap 

is $7.50. Because this functionality is 

only needed for 10 percent of ballasts in 

indoor fixtures, that number is 

multiplied by 0.10 to get an incremental 

ballast cost of $0.75 per indoor ballast. 

Manufacturer Markups 

The last step in determining 

manufacturer selling prices is 

development and application of 

manufacturer markups to scale the 

MPCs to MSPs. DOE developed initial 

manufacturer markup estimates by 

examining the annual SEC 10–K reports 

filed by publicly traded manufacturers 

of metal halide ballasts and metal halide 

lamp fixtures, among other products. 

DOE recognized that the financial 

information summarized in the 10–K 

reports is not usually exclusive to the 

metal halide portion of their businesses. 

To account for this, DOE asked 

manufacturers during interviews to 

comment on the calculated average 

MSP, and to provide both the 

manufacturer markup and manufacturer 

selling price of metal halide ballasts or 

metal halide lamp fixtures. Using this 

information, DOE determined in the 

preliminary TSD that a manufacturer 

markup of 1.47 was appropriate for both 

the metal halide ballast and fixture 

industries across all distribution 

channels. 

In the preliminary TSD, DOE assumed 

that fixture manufacturers would not 

apply an additional markup to the 

ballasts they either purchase or 

manufacture in-house. Philips 

commented that a manufacturer would 

not carry the overhead of manufacturing 

their own ballasts if they could realize 

the same overall margin by purchasing 

one from a third party. Therefore, 

Philips found it unreasonable to use a 

single markup on the ballast. (Philips, 

Public Meeting Transcript, No. 33 at p. 

74) NEEA suggested that DOE use 

separate markups for ballast 

manufacturers and fixture 

manufacturers, with the ballast 

manufacturer markup split into one 

value for the Original Equipment 

Manufacturer (OEM) channel and one 

value for the distributor channel. 

(NEEA, No. 31 at p. 4) NEEA also 

indicated that DOE should take into 

account the unique distribution channel 

for outdoor fixtures in its analysis when 

estimating markups and pricing for 

fixtures. (NEEA, No. 31 at p. 5) 

DOE has revised its markup structure 

for today’s NOPR. Based on feedback 

from manufacturers, DOE now uses 

separate markups for ballast 

manufacturers (1.47) and fixture 

manufacturers (1.58). DOE also assumes 

that fixture manufacturers apply the 

1.58 markup to the ballasts used in their 

fixtures rather than to only the empty 

fixtures as assumed in the preliminary 

TSD. This assumption is consistent with 

feedback from both fixture 

manufacturers that purchase their 

ballasts and those that produce their 

ballasts in-house. In aggregate, the 

markup also accounts for the different 

markets served by fixture 

manufacturers. The 1.47 markup for 

ballast manufacturers now applies only 

to ballasts sold to fixture OEMs directly 

impacted by this rulemaking. For the 

purpose of the LCC analysis, DOE 

assumes a higher markup of 1.60 for 

ballasts that are sold to distributors for 

the replacement market. 

D. Markups To Determine Equipment 

Price 

By applying markups to the MSPs 

estimated in the engineering analysis, 

DOE estimated the amounts customers 

would pay for baseline and more 

efficient equipment. At each step in the 

distribution channel, companies mark 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51501 

31The Sales Tax Clearinghouse. Available at 

https://thestc.com/STRates.stm. (Last accessed June 

24, 2013.) 

32U.S. Department of Energy, Office of Energy 

Efficiency and Renewable Energy. 2010 U.S. 

Lighting Market Characterization. 2010. Available 

at http://apps1.eere.energy.gov/buildings/

publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

33U.S. Department of Energy, Energy Information 

Agency. Commercial Building Energy Consumption 

Survey: Micro-Level Data, File 2 Building Activities, 

Special Measures of Size, and Multi-building 

Facilities. 2003. Available at www.eia.doe.gov/

emeu/cbecs/public_use.html. 

up the price of the equipment to cover 

business costs and profit margin. 

Identifying the appropriate markups and 

ultimately determining customer 

equipment price depend on the type of 

distribution channels through which the 

equipment moves from manufacturer to 

customer. 

1. Distribution Channels 

Before it could develop markups, DOE 

needed to identify distribution channels 

(i.e., how the equipment is distributed 

from the manufacturer to the end-user) 

for the metal halide lamp fixture designs 

addressed in this rulemaking. In an 

electrical wholesaler distribution 

channel, DOE assumed the fixture 

manufacturer sells the fixture to an 

electrical wholesaler (i.e., distributor), 

who in turn sells it to a contractor, who 

sells it to the end-user. In a contractor 

distribution channel, DOE assumed the 

fixture manufacturer sells the fixture 

directly to a contractor, who sells it to 

the end-user. In a utility distribution 

channel, DOE assumed the fixture 

manufacturer sells the fixture directly to 

the end-user (i.e., electrical utility). 

2. Estimation of Markups 

To estimate wholesaler and utility 

markups, DOE used financial data from 

10–K reports from publicly owned 

electrical wholesalers and utilities. 

DOE’s markup analysis developed both 

baseline and incremental markups to 

transform the fixture MSP into an enduser equipment price. DOE used the 

baseline markups to determine the price 

of baseline designs. Incremental 

markups are coefficients that relate the 

change in the MSP of higher-efficiency 

designs to the change in the wholesaler 

and utility sales prices. These markups 

refer to higher-efficiency designs sold 

under market conditions with new and 

amended energy conservation 

standards. 

In the preliminary analysis, DOE 

assumed a wholesaler baseline markup 

of 1.23 and a contractor baseline 

markup of 1.13, for a total wholesaler 

distribution channel baseline markup of 

1.39 (excluding sales tax). In the public 

meeting, Philips inquired about 

documentation for these values. 

(Philips, Public Meeting Transcript, No. 

33 at p. 89) DOE responded that these 

values were consistent with values used 

in other lighting-related rules (e.g., for 

fluorescent lamp ballasts), and that DOE 

would review the values. In its 

manufacturer interviews and 

background research, DOE confirmed 

that although the individual values for 

wholesaler and contractor markups 

varied, the total value was consistent 

with actual markups. For this proposed 

rule, DOE retained its wholesaler and 

contractor markups, and also assumed 

utility baseline markups of 1.00 and 

1.13 for the utility distribution channel 

in which the manufacturer sells a 

fixture directly to the end-user, and the 

channel in which a manufacturer sells 

a fixture to a contractor who in turn 

sells it to the end-user, respectively. 

The sales tax represents state and 

local sales taxes applied to the end-user 

equipment price. For the preliminary 

analysis, DOE obtained state and local 

tax data from the Sales Tax 

Clearinghouse.31 These data represent 

weighted averages that include state, 

county, and city rates. DOE then 

calculated population-weighted average 

tax values for each census division and 

large state, and then derived U.S. 

average tax values using a populationweighted average of the census division 

and large state values. This approach 

provided a national average tax rate of 

7.13 percent. DOE received no 

comments related to sales tax, and 

retained its approach for this proposed 

rule. 

3. Summary of Markups 

Table V.4 summarizes the markups at 

each stage in the distribution channels 

and the overall baseline and 

incremental markups, and sales taxes, 

for each of the three identified channels. 

TABLE V.4—SUMMARY OF FIXTURE DISTRIBUTION CHANNEL MARKUPS

Wholesaler distribution Utility distribution 

Baseline Incremental 

Via wholesaler & contractor Direct to end-user 

Baseline Incremental Baseline Incremental 

Electrical Wholesaler (Distributor) ........... 1.23 1.05 N/A N/A N/A N/A 

Utility ........................................................ N/A N/A 1.00 1.00 1.00 1.00 

Contractor or Installer .............................. 1.13 1.13 1.13 1.13 N/A N/A 

Sales Tax ................................................. 1.07 1.07 1.07 

Overall ...................................................... 1.49 1.27 1.21 1.21 1.07 1.07 

Using these markups, DOE generated 

fixture end-user prices for each 

efficiency level it considered, assuming 

that each level represents a new 

minimum efficiency standard. Chapter 6 

of the NOPR TSD provides additional 

detail on the markups analysis. 

E. Energy Use Analysis 

For the energy use analysis, DOE 

estimated the energy use of metal halide 

lamp fixtures in actual field conditions. 

The energy use analysis provided the 

basis for other DOE analyses, 

particularly assessments of the energy 

savings and the savings in operating 

costs that could result from DOE’s 

adoption of new and amended standard 

levels. 

To develop annual energy use 

estimates for the preliminary analysis, 

DOE multiplied annual usage (in hours 

per year) by the lamp and ballast system 

input power (in watts). DOE 

characterized representative lamp and 

ballast systems in the engineering 

analysis, which provided measured 

input power ratings. To characterize the 

country’s average use of fixtures for a 

typical year, DOE developed annual 

operating hour distributions by sector, 

using data published in the 2010 U.S. 

Lighting Market Characterization: 

(LMC),32 the Commercial Building 

Energy Consumption Survey (CBECS),33

and the Manufacturer Energy 


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34U.S. Department of Energy, Energy Information 

Agency. Manufacturing Energy Consumption 

Survey, Table 1.4: Number of Establishments Using 

Energy Consumed for All Purpose. 2006. Available 

at www.eia.doe.gov/emeu/mecs/mecs2006/2006

tables.html. 

Consumption Survey (MECS).34 NEMA 

agreed with this approach. (NEMA, No. 

34 at p. 17) 

In the preliminary analysis, DOE 

assumed the different operating hours 

for commercial and industrial (typically 

indoor) fixtures and for outdoor fixtures. 

NEMA stated that outdoor equipment 

operates largely at night. (NEMA, No. 34 

at p. 21) NEEA did its own analysis of 

fixture operating hours and generally 

supported the estimates DOE used in 

the preliminary analysis. (NEEA, No. 31 

at p.6) For this proposed rule, DOE 

revised its assumed fixture operating 

hours to better distinguish indoor and 

outdoor applications. 

DOE’s preliminary energy use 

analysis assumed full operating power 

and no dimmed operation. NEMA 

suggested that HID dimming is possible, 

but significantly increases ballast and 

fixture cost, whereas fluorescent or 

other lighting technologies can be more 

easily and affordably dimmed. (NEMA, 

No. 34 at p. 8) OSI confirmed that they 

are developing dimming electronic 

ballasts for metal halide lamp fixtures. 

(OSI, No. 27 at p.3) DOE maintains that 

dimming is still a small portion of the 

MH market, however, and did not 

assume dimmed operation in the energy 

use analysis for this proposed rule. 

Chapter 7 of the NOPR TSD provides a 

more detailed description of DOE’s 

energy use analysis. DOE is seeking data 

and information on the energy use 

analysis. 

F. Life-Cycle Cost and Payback Period 

Analysis 

DOE conducted the LCC and PBP 

analysis to evaluate the economic effects 

of potential energy conservation 

standards for metal halide lamp fixtures 

on individual customers. For any given 

efficiency level, DOE measured the PBP 

and the change in LCC relative to an 

estimated baseline equipment efficiency 

level. The LCC is the total customer 

expense over the life of the equipment, 

consisting of purchase, installation, and 

operating costs (expenses for energy use, 

maintenance, and repair). To compute 

the operating costs, DOE discounted 

future operating costs to the time of 

purchase and summed them over the 

lifetime of the equipment. The PBP is 

the estimated amount of time (in years) 

it takes customers to recover the 

increased purchase cost (including 

installation) of more efficient equipment 

through lower operating costs. DOE 

calculates the PBP by dividing the 

change in purchase cost (normally 

higher) by the change in average annual 

operating cost (normally lower) that 

results from the more efficient standard. 

Inputs to the calculation of total 

installed cost include the cost of the 

equipment—which includes MSPs, 

distribution channel markups, and sales 

taxes—and installation costs. Inputs to 

the calculation of operating expenses 

include annual energy consumption, 

energy prices and price projections, 

repair and maintenance costs, 

equipment lifetimes, discount rates, and 

the year that compliance with new and 

amended standards is required. To 

account for uncertainty and variability, 

DOE created value distributions for 

selected inputs, including operating 

hours, electricity prices, discount rates, 

and sales tax rates. For example, DOE 

created a probability distribution of 

annual energy consumption in its 

energy use analysis, based in part on a 

range of annual operating hours. The 

operating hour distributions capture 

variations across building types, lighting 

applications, and metal halide systems 

for three sectors (commercial, industrial, 

and outdoor stationary). In contrast, 

fixture MSPs were specific to the 

representative designs evaluated in 

DOE’s engineering analysis, and price 

markups were based on limited publicly 

available financial data. Consequently, 

DOE used discrete values instead of 

distributions for these inputs. 

The computer model DOE uses to 

calculate the LCC and PBP, which 

incorporates Crystal Ball (a 

commercially available software 

program), relies on a Monte Carlo 

simulation to incorporate uncertainty 

and variability into the analysis. The 

Monte Carlo simulations randomly 

sample input values from the 

probability distributions and fixture 

user samples. NOPR TSD chapter 8 and 

its appendices provide details on the 

spreadsheet model and all the inputs to 

the LCC and PBP analysis. 

Table V.5 summarizes the approach 

and data DOE used to develop inputs to 

the LCC and PBP calculations for the 

April 2011 preliminary TSD as well as 

the changes made for today’s NOPR. 

The subsections that follow discuss the 

initial inputs and DOE’s changes to 

them. 

TABLE V.5—SUMMARY OF INPUTS AND KEY ASSUMPTIONS IN THE LCC AND PBP ANALYSIS *

Inputs Preliminary TSD Changes for the proposed rule 

Equipment 

Cost.

Derived by multiplying MHLF MSPs by distribution channel 

markups and sales tax.

No change. 

Installation 

Cost.

Calculated costs using estimated labor times and applicable 

labor rates from RS Means Electrical Cost Data (2009) and 

U.S. Bureau of Labor Statistics.

No change. 

Annual Energy Use.Determined operating hours by associating building-type-specific operating hours with distributions of various building 

types using lighting market and building energy consumption 

survey data: LMC (2002), CBECS (2003), and MECS (2006).

Determined operating hours separately for indoor and outdoor 

fixtures. Used lighting market data: LMC (2012). 

Energy 

Prices.

Electricity: Based on EIA’s Form 861 data for 2010 ................... Electricity: Based on EIA’s Form 826 data for 2012. 

Variability: Energy prices determined at state level; incorporated off-peak electricity prices in the Monte Carlo analysis. 

Energy Price 

Projections.

Projected using AEO2010 ........................................................... Projected using AEO2013. 

Replacement 

Costs.

Included labor and material costs for lamp and ballast replacement at the end of their lifetimes.No change. 

Equipment 

Lifetime.

Ballasts: Assumed 50,000 hours for magnetic ballasts and 

30,000 hours for electronic ballasts.

Ballasts: Assumed 50,000 hours for magnetic ballasts and 

40,000 hours for electronic ballasts. 


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35A draft paper, Using the Experience Curve 

Approach for Appliance Price Forecasting, posted 

on the DOE Web site at www.eere.energy.gov/

buildings/appliance_standards, provides a 

summary of the data and literature currently 

available to DOE that is relevant to price forecasts 

for selected appliances and equipment. 

36U.S. Department of Energy–Office of Energy 

Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Equipment: 

Preliminary Technical Support Document: HighIntensity Discharge Lamps. 2010. Washington, DC 

<www1.eere.energy.gov/buildings/appliance_

standards/product.aspx/productid/60> 

37R.S. Means Company, Inc. 2010 RS Means 

Electrical Cost Data. 2010. Kingston, MA. 

TABLE V.5—SUMMARY OF INPUTS AND KEY ASSUMPTIONS IN THE LCC AND PBP ANALYSIS *—Continued 

Inputs Preliminary TSD Changes for the proposed rule 

Fixtures: Assumed 20 years for indoor fixtures and 25 years for 

outdoor fixtures.

Fixtures: No change. 

Discount 

Rates.

Commercial/Industrial: Estimated cost of capital to affected 

firms and industries; developed weighted average of the cost 

to the company of equity and debt financing.

Commercial/Industrial: Developed a distribution of discount 

rates for each end-use sector. 

Outdoor Stationary: Assumed to be the same as commercial 

sector.

Outdoor Stationary: Developed a distribution of discount rates 

for each end-use sector. 

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the NOPR TSD. 

1. Equipment Cost 

To calculate customer equipment 

costs, DOE multiplied the MSPs 

developed in the engineering analysis 

by the distribution channel markups 

described in section V.D.1 (along with 

sales taxes). DOE used different 

markups for baseline equipment and 

higher-efficiency equipment because the 

markups estimated for incremental costs 

differ from those estimated for baseline 

models. 

For the April 2011 preliminary TSD, 

DOE assumed that the MSPs and retail 

prices of products meeting various 

efficiency levels remain fixed, in real 

terms, after 2010 (the year for which the 

engineering analysis estimated costs) 

and throughout the analysis period. 

Subsequently, examination of historical 

price data for various appliances and 

equipment indicates that the 

assumption of constant real prices and 

costs may, in many cases, overestimate 

long-term appliance and equipment 

price trends. Economic literature and 

historical data suggest that the real costs 

of these products may in fact trend 

downward over time, partially because 

of ‘‘learning’’ or ‘‘experience.’’ 35

On February 22, 2011, DOE published 

a notice of data availability (February 

2011 NODA; 76 FR 9696) stating that 

DOE may consider improving regulatory 

analysis by addressing equipment price 

trends. DOE notes that learning-curve 

analysis characterizes the reduction in 

production cost mainly associated with 

labor-based performance improvement 

and higher investment in new capital 

equipment at the microeconomic level. 

Experience-curve analysis tends to focus 

more on entire industries and aggregates 

over various casual factors at the 

macroeconomic level: ‘‘Experience 

curve’’ and ‘‘progress function’’ 

typically represent generalizations of 

the learning concept to encompass 

behavior of all inputs to production and 

cost (i.e., labor, capital, and materials). 

The economic literature often uses these 

two terms interchangeably. The term 

‘‘learning’’ is used here to broadly cover 

these general macroeconomic concepts. 

For this proposed rule and consistent 

with the February 2011 NODA, DOE 

examined two methods for estimating 

price trends for metal halide lamp 

fixtures: Using historical producer price 

indices (PPIs), and using projected price 

indices (called deflators). With PPI data, 

DOE found both positive and negative 

real price trends, depending on the 

specific time period examined, and did 

not use this method to adjust fixture 

prices. DOE instead adjusted fixture 

prices using deflators used by EIA to 

develop the AEO. When adjusted for 

inflation, the deflator-based price 

indices decline from 100 in 2010 to 

approximately 76 in 2045. 

DOE invites comment on methods to 

improve its fixture price projections 

beyond the assumption of constant real 

prices, as well as any data supporting 

alternate methods. A more detailed 

discussion of price trend modeling and 

calculations is provided in appendix 8B 

of the NOPR TSD. 

2. Installation Cost 

Installation costs for metal halide 

lamp fixtures include the costs to install 

the fixture, maintain the ballast, and 

replace the lamp. For the April 2011 

preliminary TSD, DOE used data 

collected for its July 2010 HID lamps 

determination,36 labor rates for 

electricians from RS Means,37 and other 

research to estimate the installation 

costs. DOE annualized maintenance 

costs in its preliminary analysis, and 

NEEA questioned why DOE annualized 

costs that do not occur annually, but 

rather occur periodically during the 

equipment lifetime. (NEEA, Public 

Meeting Transcript, No. 33 at p. 102) 

For this NOPR, DOE developed a 

methodology that allows the use of 

annualized maintenance costs while 

maintaining the integrity of the NPV 

calculations in the NIA. For further 

detail, see chapter 8 of the NOPR TSD. 

3. Annual Energy Use 

As discussed in section V.E, DOE 

estimated the annual energy use of 

representative metal halide systems 

using system input power ratings and 

sector operating hours. The annual 

energy use inputs to the LCC and PBP 

analysis are based on weighted average 

annual operating hours, whereas the 

Monte Carlo simulation draws on a 

distribution of annual operating hours 

to determine annual energy use. 

4. Energy Prices 

For the April 2011 preliminary TSD, 

DOE developed weighted average 

energy prices for 13 U.S. geographic 

areas consisting of the 9 census 

divisions, with 4 large states (1. 

California, 2. Florida, 3. New York, and 

4. Texas) treated separately. For census 

divisions containing one of these large 

states, DOE calculated the regional 

average excluding the data for the large 

state. Prices were based on data from 

EIA Form 826, ‘‘Monthly Electric Utility 

Sales and Revenue Data, 2011.’’ GE 

commented that metal halide lighting is 

commonly used outdoors during offpeak hours, and recommended that DOE 

account for off-peak electricity prices in 

the analysis. (GE, Public Meeting 

Transcript, No. 33 at p. 135) For this 

proposed rule, DOE incorporated offpeak electricity pricing by using a 

distribution of percentages of average 

electricity prices in its Monte Carlo 

analysis, from which a lower average 

electricity price for the outdoor sector 

was calculated and used in the main 

LCC analysis. For more information, see 

chapter 8 of the NOPR TSD. 

5. Energy Price Projections 

To estimate the trends in energy 

prices, DOE used the price projections 


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38Weibull distribution is a probability density 

function; for more information, see 

www.itl.nist.gov/div898/handbook/eda/section3/

eda3668.htm. 

39The data are available at pages.stern.nyu.edu/ 

∼adamodar. 

in AEO2013. To arrive at prices in 

future years, DOE multiplied current 

average prices by the projected of 

annual average price changes in 

AEO2013. Because AEO2013 projects 

prices to 2040, DOE used the average 

rate of change from 2010 to 2040 to 

estimate the price trend for electricity 

after 2040. In addition, the spreadsheet 

tools that DOE used to conduct the LCC 

and PBP analysis allow users to select 

price forecasts from the AEO lowgrowth, high-growth, and reference-case 

scenarios to estimate the sensitivity of 

the LCC and PBP to different energy 

price forecasts. DOE received no 

comments on the April 2011 

preliminary TSD concerning its energy 

price projecting method for the LCC 

analysis, and retained this approach for 

this proposed rule. 

6. Replacement Costs 

In the April 2011 preliminary TSD, 

DOE addressed ballast and lamp 

replacements that occur within the LCC 

analysis period. Replacement costs 

include the labor and materials costs 

associated with replacing a ballast or 

lamp at the end of their lifetimes and 

are annualized across the years 

preceding and including the actual year 

in which equipment is replaced. For the 

LCC and PBP analysis, the analysis 

period corresponds with the fixture 

lifetime that is assumed to be longer 

than that of either the lamp or the 

ballast. For this reason, ballast and lamp 

prices and labor costs are included in 

the calculation of total installed costs. 

DOE received comments regarding its 

annualizing approach concerning 

replacement costs for the LCC analysis 

in its April 2011 preliminary TSD and 

developed a new annualizing 

methodology for this proposed rule. 

(NEEA, Public Meeting Transcript, No. 

33 at p. 103) 

7. Equipment Lifetime 

For the April 2011 preliminary TSD, 

DOE defined equipment lifetime as the 

age (in hours in operation) when a 

fixture, ballast, or lamp is retired from 

service. For fixtures in all equipment 

classes, DOE assumed lifetimes for 

indoor and outdoor fixtures of 20 and 25 

years, respectively. 

Metal halide lamp fixtures are 

operated by either magnetic or 

electronic ballasts. In the April 2011 

preliminary analysis, DOE assumed that 

magnetic ballasts last for 50,000 hours 

and electronic ballasts last for 30,000 

hours. NEMA and Empower Electronics 

agreed with DOE’s general estimates 

about magnetic and electronic ballast 

lifetimes, but NEMA cautioned that 

fixtures are often removed before end of 

service life, especially as new energyefficient alternatives appear on the 

market. (NEMA, No. 34 at p. 18; 

Empower Electronics, No. 36 at p. 11) 

Similarly, Philips noted that ballasts 

may be replaced prior to physical 

failure. (Philips, Public Meeting 

Transcript, No. 33 at p. 107) OSI 

suggested an average rated life of 50,000 

hours for electronic ballasts, and agreed 

with NEMA and Philips that fixtures 

may be replaced before end of service 

life. (OSI, No. 27 at p. 6) The California 

IOUs believed that DOE underestimated 

electronic ballast lifetime by as much as 

twofold based on their experience with 

electronic ballast manufacturers. 

(California IOUs, No. 32 at p. 3) Finally, 

NEEA suggested that DOE use a 

distribution of ballast lifetimes for LCC 

and other analyses. (NEEA, No. 31 at p. 

7) 

DOE notes that actual ballast lifetime 

data are limited. However, based on 

comments and additional research, DOE 

revised its average electronic ballast 

lifetime to 40,000 hours and maintained 

its average lifetime of 50,000 hours for 

magnetic ballasts for this proposed rule. 

DOE agrees that ballast lifetimes can 

vary due to both physical failure and 

economic factors (e.g., early 

replacements due to retrofits). 

Consequently, DOE accounted for 

variability in lifetime in LCC and PBP 

via the Monte Carlo simulation, and in 

the shipments and NIA analyses by 

assuming a Weibull distribution for 

lifetimes to accommodate failures and 

replacements.38

Metal halide lamp lifetimes vary by 

fixture equipment class. For the April 

2011 preliminary TSD, DOE assumed 

that lamps in the 70 W, 250 W, 400 W, 

and 1000 W equipment classes operate 

for 12,000, 15,000, 20,000, and 12,000 

hours, respectively. Commenters noted 

that lamp lifetime can vary with 

operating position (e.g., vertical, 

horizontal, or tilted), and recommended 

that DOE consider this variation in 

developing weighted-average lamp 

lifetimes. (GE, Public Meeting 

Transcript, No. 33 at p. 97; Hubbell, 

Public Meeting Transcript, No. 33 at p. 

98) DOE agrees with the comments, and 

surveyed published MH lamp life 

ratings in developing weighted-average 

lamp lifetimes for this proposed rule. 

Some public meeting participants 

asked about the effects of ballast type 

(i.e., magnetic vs. electronic) on lamp 

life. (ASAP, Public Meeting Transcript, 

No. 33 at p. 98; Energy Solutions Public 

Meeting Transcript, No. 33 at p. 104) 

Hubbell and Philips acknowledged the 

lack of industry consensus on this 

subject and the variability of related 

lifetime data between manufacturers. 

(Hubbell, Public Meeting Transcript, 

No. 33 at p. 98; Philips, Public Meeting 

Transcript, No. 33 at p. 104) Based on 

its review of industry data and 

literature, DOE could not substantiate 

the effect of ballast type on MH lamp 

lifetimes, and used published lamp life 

ratings only in developing weightedaverage lamp lifetimes for this proposed 

rule. 

8. Discount Rates 

The discount rate is the rate at which 

future expenditures are discounted to 

estimate their present value. In this 

NOPR, DOE estimated separate discount 

rates for commercial, industrial and 

outdoor stationary customers. For all 

such customers, DOE estimated the cost 

of capital for commercial and industrial 

companies by examining both debt and 

equity capital, and developed an 

appropriately weighted average of the 

cost to the company of equity and debt 

financing. For the proposed rule, DOE 

also developed a distribution of 

discount rates for each end-use sector 

from which the Monte Carlo simulation 

samples. 

For each sector, DOE assembled data 

on debt interest rates and the cost of 

equity capital for representative firms 

that use metal halide lamp fixtures. DOE 

determined a distribution of the 

weighted-average cost of capital for each 

class of potential owners using data 

from the Damodaran online financial 

database.39 The average discount rates, 

weighted by the shares of each rate 

value in the sectoral distributions, are 

4.5 percent for commercial end-users, 

4.3 percent for industrial end-users, and 

3.4 percent for outdoor stationary endusers. 

DOE received no comments on the 

April 2011 preliminary TSD concerning 

its estimated discount rates for the LCC 

analysis and retained this approach for 

this proposed rule. 

9. Analysis Period 

DOE calculated the LCC for all endusers as if each one would purchase a 

new fixture in the year 2016. 

10. Fixture Purchasing Events 

DOE designed the LCC and PBP 

analysis for this rulemaking around 

scenarios where customers need to 

purchase a metal halide lamp fixture. 

The ‘‘event’’ that prompts the purchase 


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of a new fixture (either a ballast failure 

or new construction/renovation) was 

assumed to influence the costeffectiveness of the customer purchase 

decision. DOE assumed that a customer 

will replace a failed fixture with an 

identical fixture in the base case, or a 

new standards-compliant fixture with 

comparable light output in the 

standards case. DOE analyzed five 

representative equipment classes for 

fixtures and presented the results for 

each of these representative equipment 

classes by fixture purchasing event, 

which influenced the LCC and PBP 

results. 

DOE received no comments on the 

April 2011 preliminary TSD concerning 

its assumed fixture purchasing events 

for the LCC analysis and retained this 

approach for this proposed rule. 

G. National Impact Analysis—National 

Energy Savings and Net Present Value 

Analysis 

DOE’s NIA assessed the national 

energy savings (NES) and the national 

net present value (NPV) of total 

customer costs and savings that would 

be expected to result from new or 

amended standards at specific efficiency 

levels. (‘‘Customer’’ in this context 

refers to users of the regulated 

equipment.) 

DOE used a Microsoft Excel 

spreadsheet model to calculate the 

energy savings and the national 

customer costs and savings from each 

TSL. The TSD and other documentation 

for the rulemaking help explain the 

models and how to use them, allowing 

interested parties to review DOE’s 

analyses by changing various input 

quantities within the spreadsheet. 

DOE used the NIA spreadsheet to 

calculate the NES and NPV based on the 

annual energy use and total installed 

cost data from the energy use and LCC 

analyses. DOE projected the energy 

savings, energy cost savings, equipment 

costs, and NPV of customer benefits for 

each equipment class for equipment 

sold from 2016 through 2045. The 

projections provided annual and 

cumulative values for all four output 

parameters. 

DOE evaluated the impacts of new 

and amended standards for metal halide 

lamp fixtures by comparing base-case 

projections with standards-case 

projections. The base-case projections 

characterize energy use and customer 

costs for each equipment class in the 

absence of new or amended energy 

conservation standards. DOE compared 

these projections with projections 

characterizing the market for each 

equipment class if DOE adopted new or 

amended standards at specific energy 

efficiency levels (i.e., the TSLs or 

standards cases) for that class. In 

characterizing the base and standards 

cases, DOE considered historical 

shipments, the mix of efficiencies sold 

in the absence of new standards, and 

how that mix may change over time. 

Additional information about the NIA 

spreadsheet is in the NOPR TSD chapter 

11. 

Table V.6 summarizes the approach 

and data DOE used to derive the inputs 

to the NES and NPV analyses for the 

April 2011 preliminary TSD, as well as 

the changes to the analyses for the 

proposed rule. A discussion of selected 

inputs and changes follows. See chapter 

11 of the NOPR TSD for further details. 

TABLE V.6—APPROACH AND DATA USED FOR NATIONAL ENERGY SAVINGS AND CUSTOMER NET PRESENT VALUE

ANALYSES

Inputs Preliminary TSD Changes for the proposed rule 

Shipments ................................................................... Developed annual shipments from shipments model See Table V.7. 

Annual Energy Consumption per Unit ........................ Established in the energy use characterization (preliminary TSD chapter 7).See section V.E. 

Rebound Effect ........................................................... 0% .............................................................................. No change. 

Electricity Price Forecast ............................................ AEO2010 ................................................................... AEO2013. 

Energy Site-to-Source Conversion Factor .................. Assumed to be constant across time: 1 site kWh = 

10,239 source Btu.

Used annually variable site kWh to 

source Btu conversion factor. 

Discount Rate ............................................................. 3% and 7% real ......................................................... No change. 

Present Year ............................................................... 2011 ........................................................................... 2013. 

1. Shipments 

Equipment shipments are an 

important component of any estimate of 

the future impact of a standard. Using 

a three-step process, DOE developed the 

shipments portion of the NIA 

spreadsheet, a model that uses historical 

data as a basis for projecting future 

fixture shipments. First, DOE used a 

combination of historical fixture 

shipment data from the U.S. Census 

Bureau for HID fixtures from 1993 to 

2001. DOE correlated the HID fixture 

data with HID lamp data from 1990 to 

2010 from the HID lamps rulemaking 

(EERE–2010–BT–STD–0043). Fixture 

shipments correlated to roughly a third 

of lamp shipments. DOE applied this 

fixture-to-lamp correlation to the larger 

and more detailed data set of HID lamp 

data to estimate the total historical 

shipments of each fixture type analyzed. 

Second, DOE estimated an installed 

stock for each fixture in 2016 based on 

the average service lifetime of each 

fixture type. Third, DOE developed 

annual shipment projections for 2016– 

2045 by modeling fixture purchasing 

events, such as replacement and new 

construction, and applying growth rate, 

replacement rate, and alternative 

technologies penetration rate 

assumptions. For details on the 

shipments analysis, see chapter 10 of 

the NOPR TSD. DOE is seeking 

comment on whether the assumptions 

and methods used to project MHLF 

shipments are reasonable and likely to 

occur. DOE is also seeking data and 

information that could be used to refine 

DOE’s estimates. DOE also requests 

comment on the impediments that 

prevent users of metal halide lamp 

fixtures from switching to LED lighting 

to garner further energy savings. 

TABLE V.7—APPROACH AND DATA USED FOR THE SHIPMENTS ANALYSIS

Inputs Preliminary TSD Changes for the proposed rule 

Historical Shipments .............. Used historical shipments for 1990–2008 to develop 

shipments and stock projections for the analysis period.

Used historical MH lamp shipments for 1990–2010 to 

develop shipments and stock projections for MH fixtures. 


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40U.S. Census Bureau. Manufacturing, Mining, 

and Construction Statistics. Current Industrial 

Reports, Fluorescent Lamp Ballasts, MQ335C. 2008. 

(Last accessed September 1, 2010). 

<www.census.gov/mcd/>. 

TABLE V.7—APPROACH AND DATA USED FOR THE SHIPMENTS ANALYSIS—Continued 

Inputs Preliminary TSD Changes for the proposed rule 

Fixture Stock .......................... Based projections on the shipments that survive up to 

a given date; assumed Weibull lifetime distribution.

No change. 

Growth ................................... Adjusted based on fixture market .................................. No change. 

Base Case Scenarios ............ Analyzed one scenario incorporating alternative technologies encroaching on fixture shipments.Developed ‘‘low’’ and ‘‘high’’ shipments scenarios. 

Standards Case Scenarios .... Analyzed Roll-up and Shift scenarios ............................ Analyzed Roll-up only. 

a. Historical Shipments 

For the April 2011 preliminary TSD, 

DOE reviewed U.S. Census Bureau data 

from 1993 to 2001 for metal halide lamp 

fixtures.40 DOE compared the MHLF 

census data to NEMA data for historical 

metal halide lamp shipments from 1990 

to 2008 taken from DOE’s final 

determination for HID lamps published 

on July 1, 2010. 75 FR 37975. DOE 

found a correlation between metal 

halide lamp fixture and metal halide 

lamp shipments. From 1993 to 2001, the 

number of MHLF shipments on average 

represented 37 percent of the amount of 

lamp shipments, with a standard 

deviation of 3 percent. Using this 

relationship, DOE multiplied all of the 

metal halide lamp shipments from 1990 

to 2010 by 37 percent to estimate the 

historical shipments of metal halide 

lamp fixtures. DOE received no 

comments on the April 2011 

preliminary TSD regarding historical 

fixture shipments data and estimates 

and retains this approach for this 

proposed rule. 

b. Fixture Stock Projections 

In its preliminary shipments analysis, 

DOE calculated the installed fixture 

stock using historical fixture shipments 

estimated from U.S. Census Bureau 

Current Industrial Reports data (1993– 

2001), data from the HID lamps rule, 

and its projected shipments for future 

years. DOE estimated the installed stock 

during the analysis period by using 

fixture shipments and calculating how 

many will survive up to a given year 

based on a Weibull lifetime distribution 

for each fixture type. DOE received no 

comments on the April 2011 

preliminary TSD regarding its fixture 

stock projection method and retained 

this approach for this proposed rule. 

c. Base Case Shipment Scenarios 

For the April 2011 preliminary TSD, 

DOE’s projection showed fixture 

shipments increasing until 2020 and 

then declining. Several manufacturers 

stated that DOE’s projection 

overestimated fixtures shipments in the 

near term. (Acuity, Cooper, GE, Philips, 

Public Meeting Transcript, No. 33 at pp. 

112–120) Philips noted that T5 and T8 

fluorescent systems are already 

displacing metal halide systems, with 

solid-state lighting also starting to 

penetrate the metal halide lamp fixture 

market. (Philips, Public Meeting 

Transcript, No. 33 at p. 113) DOE 

revisited its preliminary fixture 

shipment estimates and manufacturer 

interview data, and revised its 

projections downward for this proposed 

rule. DOE assumed that shipments for 

metal halide lamp fixtures would peak 

somewhere between 2010 and 2015. 

From the manufacturer interviews, DOE 

was able to approximate the shipments 

in 2010. Through separate data, 

additional assumptions, and research, 

DOE was able to approximate the same 

shipments in 2010 in the DOE model. In 

the ‘‘low’’ shipment scenario, DOE 

reviewed trends in replacement 

technologies and projected a decline 

such that the 2040 shipment projection 

fell back to the level of the 2000 

shipments. In the ‘‘high’’ scenario, the 

decline in metal halide lamp fixture 

shipments is not as large as in the ‘‘low’’ 

scenario. The shipments in the ‘‘high’’ 

scenario in 2040 roughly equal the 

shipments in 2006. 

d. Standards Case Efficiency Scenarios 

Several of the inputs for determining 

NES (e.g., the annual energy 

consumption per unit) and NPV (e.g., 

the total annual installed cost and the 

total annual operating cost savings) 

depend on equipment efficiency. For 

the April 2011 preliminary TSD, DOE 

used two shipment efficiency scenarios: 

‘‘Roll-up’’ and ‘‘Shift.’’ DOE received no 

comments on its efficiency scenarios, 

but eliminated the Shift scenario and 

retained the Roll-up scenario for this 

proposed rule. The Roll-up scenario is 

a standards case in which all equipment 

efficiencies in the base case that do not 

meet the standard would ‘roll up’ to the 

lowest level that can meet the new 

standard level. Equipment efficiencies 

in the base case above the standard level 

are unaffected in the Roll-up scenario, 

as these customers are assumed to 

continue to purchase the same base-case 

fixtures. The Roll-up scenario 

characterizes customers primarily 

driven by the first cost of the analyzed 

equipment, which DOE believes more 

accurately characterizes the metal 

halide lamp fixture marketplace. 

2. Site-to-Source Energy Conversion 

To estimate the national energy 

savings expected from appliance 

standards, DOE uses a multiplicative 

factor to convert site energy 

consumption into primary or source 

energy consumption (the energy 

required to convert and deliver the site 

energy). These conversion factors 

account for the energy used at power 

plants to generate electricity and losses 

in transmission and distribution, as well 

as for natural gas losses from pipeline 

leakage and energy used for pumping. 

For electricity, the conversion factors 

vary over time due to projected changes 

in generation sources (i.e., the types of 

power plants projected to provide 

electricity to the country). The factors 

that DOE developed are marginal 

values, which represent the response of 

the system to an incremental decrease in 

consumption associated with appliance 

standards. 

For the April 2011 preliminary TSD, 

DOE used the average of all annual siteto-source conversion factors based on 

the version of NEMS that corresponds to 

AEO2010, which provides energy 

forecasts through 2035. For 2036–2044, 

DOE used conversion factors that 

remain constant at the 2035 values. 

DOE has historically presented NES 

in terms of primary energy savings. In 

response to the recommendations of a 

committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to 

Energy Efficiency Standards’’ appointed 

by the National Academy of Science, 

DOE announced its intention to use FFC 

measures of energy use and greenhouse 

gas and other emissions in the national 

impact analyses and emissions analyses 

included in future energy conservation 

standards rulemakings. 76 FR 51281 

(August 18, 2011) While DOE stated in 

that notice that it intended to use the 

Greenhouse Gases, Regulated Emissions, 


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41 Docket ID: EERE–2010–BT–NOA–0028, 

comment by Kirk Lundblade. 

42 DOE determined whether a company is a small 

business (65 FR 30836, 30848 (May 15, 2000), as 

amended at 65 FR 53533, 53544 (Sept. 5, 2000) and 

codified at 13 CFR part 121). To be categorized as 

a small business, a metal halide lamp fixture 

manufacturer may have up to 500 employees; a 

metal halide ballast manufacturer may have up to 

750 employees. 

and Energy Use in Transportation 

(GREET) model to conduct the analysis, 

it also said it would review alternative 

methods, including the use of NEMS. 

After evaluating both models and the 

approaches discussed in the August 18, 

2011 notice, DOE published a statement 

of amended policy in the Federal 

Register in which DOE explained its 

determination that NEMS is a more 

appropriate tool for its FFC analysis and 

its intention to use NEMS for that 

purpose. 77 FR 49701 (August 17, 2012). 

DOE received one comment, which was 

supportive of the use of NEMS for 

DOE’s FFC analysis.41

The approach used for today’s NOPR, 

and the FFC multipliers that were 

applied, are described in appendix 11B 

of the NOPR TSD. NES results are 

presented in both primary and FFC 

savings in section VI.B. 

H. Customer Subgroup Analysis 

The life-cycle cost subgroup analysis 

evaluates impacts of standards on 

identifiable groups, such as different 

customer populations or business types 

that may be disproportionately affected 

by any national energy conservation 

standard level. DOE will estimate LCC 

savings and PBPs for customers in the 

commercial, industrial, and outdoor 

stationary sectors. DOE will also analyze 

the LCC effects on customers living in 

or operating different buildings in the 

commercial and industrial sectors. In 

addition, DOE will analyze effects on 

customers in different regions of the 

country. 

I. Manufacturer Impact Analysis 

1. Overview 

DOE performed a manufacturer 

impact analysis (MIA) to estimate the 

financial impact of proposed new and 

amended energy conservation standards 

on manufacturers of metal halide lamp 

fixtures and ballasts, and to estimate the 

impact of such standards on 

employment and manufacturing 

capacity. The MIA has both quantitative 

and qualitative aspects. The quantitative 

part of the MIA primarily relies on the 

GRIM, an industry cash flow model 

using inputs specific to this rulemaking. 

The key GRIM inputs are data on the 

industry cost structure, equipment 

costs, shipments, and assumptions 

about markups and conversion 

expenditures. The key output is the 

industry net present value (INPV). 

Different sets of shipment and markup 

assumptions (scenarios) will produce 

different results. The qualitative part of 

the MIA addresses factors such as 

equipment attributes; characteristics of, 

and impacts on, particular sub-groups of 

firms; and market and product trends. 

Chapter 13 of the NOPR TSD outlines 

the complete MIA. 

DOE conducted the MIA for this 

rulemaking in three phases. In Phase 1, 

Industry Profile, DOE prepared an 

industry characterization based on the 

market and technology assessment, 

preliminary manufacturer interviews, 

and publicly available information. In 

Phase 2, Industry Cash Flow Analysis, 

DOE estimated industry cash flows in 

the GRIM using industry financial 

parameters derived in Phase 1 and the 

shipment scenarios used in the NIA. In 

Phase 3, Sub-Group Impact Analysis, 

DOE conducted structured, detailed 

interviews with a representative crosssection of manufacturers that represent 

more than 65 percent of domestic 

fixture sales and 90 percent of domestic 

ballast sales. During these interviews, 

DOE discussed engineering, 

manufacturing, procurement, and 

financial topics specific to each 

company, and obtained each 

manufacturer’s view of the MHLF 

industry as a whole. The interviews 

provided valuable information that DOE 

used to evaluate the impacts of new and 

amended standards on manufacturers’ 

cash flows, manufacturing capacities, 

and employment levels. See section 

V.I.4 for a description of the key issues 

manufacturers raised during the 

interviews. 

During Phase 3, DOE also used the 

results of the industry characterization 

analysis in Phase 1 and feedback from 

manufacturer interviews to group 

manufacturers that exhibit similar 

production and cost structure 

characteristics. DOE identified one subgroup for a separate impact analysis— 

small manufacturers—using the small 

business size standards published by 

the Small Business Administration 

(SBA).42 These thresholds include all 

employees in a business’ parent 

company and any other subsidiaries. 

Based upon this classification, DOE 

identified 54 small metal halide lamp 

fixture manufacturers and five small 

metal halide ballast manufacturers that 

qualify as small businesses. 

2. GRIM Analysis and Key Inputs 

DOE uses the GRIM to quantify the 

changes in cash flow that result in a 

higher or lower industry value. The 

GRIM analysis uses a standard annual 

cash-flow analysis that incorporates 

manufacturer costs, markups, 

shipments, and industry financial 

information as inputs and models 

changes in costs, investments, and 

manufacturer margins that would result 

from new and amended energy 

conservation standards. The GRIM 

spreadsheet uses the inputs to calculate 

a series of annual cash flows beginning 

with the base year of the analysis, 2013, 

and continuing to 2045. DOE computes 

INPVs by summing the stream of annual 

discounted cash flows during this 

period. DOE uses a real discount rate of 

9.5 percent and 8.9 percent for fixtures 

and ballasts, respectively. The discount 

rate estimates were derived from 

industry corporate annual reports to the 

Securities and Exchange Commission 

(SEC 10-Ks) and then modified 

according to feedback during 

manufacturer interviews. 

The GRIM calculates cash flows using 

standard accounting principles and 

compares changes in INPV between a 

base case and various TSLs (the 

standards cases). The difference in INPV 

between the base case and a standards 

case represents the financial impact of 

the new and amended standard on 

manufacturers. The GRIM results are 

shown in section VI.B.2. Additional 

details about the GRIM can be found in 

chapter 13 of the NOPR TSD. 

DOE typically presents its estimates of 

manufacturer impacts by groups of the 

major equipment types served by the 

same manufacturers. Although the 

covered equipment in today’s proposed 

rulemaking is metal halide lamp 

fixtures, by requiring a particular ballast 

efficiency in this regulation, metal 

halide ballast manufacturers will also be 

affected by new and amended 

standards. Because fixture and ballast 

markets are served by separate groups of 

manufacturers, DOE presents impacts 

on metal halide lamp fixture 

manufacturers and metal halide ballast 

manufacturers separately. 

a. Manufacturer Production Costs 

Manufacturing a higher-efficiency 

product is typically more expensive 

than manufacturing a baseline product 

due to the use of components that are 

more costly than baseline components. 

The changes in the MPCs of the 

analyzed equipment can affect the 

revenues, gross margins, and cash flows 

of the manufacturer, making these 

equipment cost data key GRIM inputs 

for DOE’s analysis. DOE employed one 

of two methods to derive these per-unit 

production costs. DOE was able to 

establish a BOM for those ballasts it tore 


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down. DOE then converted the BOMs at 

each efficiency level into corresponding 

MPCs composed of labor, materials, and 

overhead expenses using its engineering 

cost model. When DOE was not able to 

generate a BOM for a given ballast, DOE 

estimated the per-unit production costs 

based on the relationship between 

teardown data and manufacturersupplied MSPs. DOE included a cost 

adder for indoor electronic ballasts to 

account for the additional cost of 

including a 120 V auxiliary tap in some 

models. DOE also developed fixture 

MPCs for several different fixture types 

using either a teardown analysis or 

retail price scaling. With these costs for 

several common fixture types, DOE 

created a single ‘‘hybrid’’ fixture for 

each of the five representative wattages, 

reflecting the weighted average of the 

common fixture types. DOE included a 

cost adder for all fixtures that use 

electronic ballasts to account for 

thermal management and a cost adder 

for outdoor fixtures that use electronic 

ballasts to account for voltage transient 

protection. For a complete description 

these cost adders, see section V.C.12 of 

this NOPR. In addition, DOE used 

teardown cost data to disaggregate the 

ballast and fixture MPCs into material, 

labor, and overhead costs. 

b. Base Case Shipment Projections 

Changes in sales volumes and 

efficiencies over time can significantly 

affect manufacturer finances. The GRIM 

estimates manufacturer revenues based 

on total unit shipment projections and 

the distribution of shipments by 

efficiency level. For this analysis, the 

GRIM uses the NIA’s annual shipment 

projections from 2013 to 2045, the end 

of the analysis period. The shipments 

analysis also estimated the distribution 

of fixture efficiencies in the base case 

for all equipment classes. 

DOE employed two scenarios that 

affect base case shipments over the 

analysis period (2016 through 2045): a 

low-shipment scenario and a highshipment scenario. In the low-shipment 

scenario, DOE reviewed trends in 

fixture replacement technologies and 

projected a decline in shipments over 

the analysis period. In the highshipment scenario, the decline in metal 

halide lamp fixture shipments is not as 

large as in the low-shipment scenario. 

Manufacturers earn greater revenue 

under the high-shipment scenario 

compared to the low-shipment scenario. 

See chapter 10 of the NOPR TSD for 

additional details on shipments. 

c. Standards Case Shipment Projections 

In addition to the two shipment 

scenarios affecting base case shipments, 

DOE modeled a roll-up scenario to 

estimate the standards case efficiency 

distributions. See chapter 10 of the 

NOPR TSD for more information on the 

standards case shipment scenarios. 

d. Markup Scenarios 

As discussed above, MSPs include 

direct manufacturing production costs 

(i.e., labor, material, and overhead 

estimated in DOE’s MPCs) and all nonproduction costs (i.e., selling, general 

and administrative expenses (SG&A), 

R&D, and interest), along with profit. To 

calculate the MSPs in the GRIM, DOE 

applied markups to the MPCs estimated 

in the engineering analysis for each 

equipment class and efficiency level. 

Modifying these markups in the 

standards cases yields different sets of 

impacts on manufacturers. For the MIA, 

DOE modeled two standards case 

markup scenarios to represent the 

uncertainty regarding impacts on prices 

and profitability: (1) A flat markup 

scenario, and (2) a ‘preservation of 

operating profit’ markup scenario. These 

scenarios lead to different markups 

values, which, when multiplied by the 

MPCs, result in varying revenue and 

cash flow impacts. 

The flat markup scenario assumes that 

the cost of goods sold for each product 

is marked up by a flat percentage to 

cover SG&A expenses, R&D expenses, 

and profit. The flat markup scenario 

uses the baseline manufacturer markup 

(1.47 for ballasts and 1.58 for fixtures, 

as discussed in chapter 5 of the NOPR 

TSD) for all fixture equipment classes in 

both the base case and the standards 

case. This scenario represents the upper 

bound of industry profitability in the 

standards case because it is designed so 

that manufacturers can fully pass 

through additional costs due to 

standards to their customers. To derive 

the flat markup percentage, DOE 

evaluated publicly available financial 

information for manufacturers of metal 

halide ballasts or fixtures. DOE also 

requested feedback on this value during 

manufacturer interviews. 

During interviews, manufacturers 

expressed skepticism that they would be 

able to mark up higher equipment costs 

in the standards case to the same degree 

as in the base case. In recognition of this 

concern, DOE also modeled a scenario 

called the ‘preservation of operating 

profit’ markup scenario. In this scenario, 

markups in the standards case are 

lowered such that manufacturers are 

only able to maintain their total base 

case operating profit in absolute dollars, 

despite higher product costs and 

investments. This scenario represents 

the lower bound of industry profitability 

following new and amended energy 

conservation standards because the 

resulting higher production costs and 

investments do not yield any additional 

operating profits. DOE implemented this 

scenario in the GRIM by lowering the 

manufacturer markups at each TSL to 

yield approximately the same earnings 

before interest and taxes in the 

standards case in 2017, as in the base 

case. 

e. Product and Capital Conversion Costs 

New and amended energy 

conservation standards will cause 

manufacturers to incur conversion costs 

to bring their production facilities and 

product designs into compliance. For 

the MIA, DOE classified these 

conversion costs into two major groups: 

(1) Product conversion costs and (2) 

capital conversion costs. Product 

conversion costs are investments in 

research, development, testing, 

marketing, and other non-capitalized 

costs necessary to make product designs 

comply with the new and amended 

energy conservation standards. Capital 

conversion costs are investments in 

property, plant, and equipment 

necessary to adapt or change existing 

production facilities such that new 

product designs can be fabricated and 

assembled. 

NEMA expressed concern about the 

costs (in time and dollars) that 

manufacturers may incur due to this 

rulemaking, specifically with respect to 

product redesigns and product testing. 

NEMA disagreed with DOE’s 

assumption in the preliminary analysis 

that ballast redesigns would not cause 

fixture redesigns. NEMA argued that 

DOE should account for fixture redesign 

costs for both magnetic and electronic 

ballast efficiency levels and provided 

estimates of these costs. (NEMA, No. 34 

at p. 7, 21) Acuity and OSI agreed that 

fixture manufacturers would face 

increased costs due to additional 

engineering, testing, and material costs. 

(Acuity, Public Meeting Transcript, No. 

33 at p. 79; OSI, No. 27 at p. 6) 

For today’s NOPR, DOE has revised 

its assumption about additional fixture 

costs and believes that empty fixture 

costs are likely to increase for standards 

requiring electronic ballasts, as 

described in section V.C.12, because of 

the need to incorporate thermal 

protection and voltage transient 

protection. Because the use of electronic 

ballasts could necessitate fixture 

redesigns, DOE includes the costs of 

these fixture redesigns in its product 

and capital conversion costs. DOE has 

taken into account the feedback and 

estimates provided by NEMA in its 

analysis, as well as the input from 

individual manufacturers during 


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confidential manufacturer interviews. 

DOE’s methodology for developing 

product and capital conversion cost 

estimates is described below and in 

chapter 13 of the NOPR TSD. DOE 

requests comment on the methodology 

applied to determine the product and 

capital conversion costs. 

Several stakeholders commented that 

the costs to develop and test electronic 

ballasts are higher than for magnetic 

ballasts. (NEMA, No 34 at p. 8; OSI, No. 

27 at p. 6) Cooper noted that the cost of 

UL certification when switching from 

magnetic to electronic ballasts falls into 

this category. (Cooper, Public Meeting 

Transcript, No. 33 at p. 76) Acuity 

added that long lead times accentuate 

the cost of UL certification and make it 

more difficult for manufacturers to 

quickly bring new products to market. 

(Acuity, Public Meeting Transcript, No. 

33 at p. 79) DOE agrees that the 

engineering, testing, and certification 

costs for electronic ballasts may be 

significant and has included these costs 

in today’s analysis, as described in what 

follows. 

Ballast Industry Conversion Costs 

DOE’s interviews with ballast 

manufacturers revealed that they expect 

the need to develop new and improved 

circuit designs—as opposed to the 

purchase of new capital equipment— 

will account for most of the conversion 

costs at each TSL. Due to the flexible 

nature of most ballast production 

equipment and DOE’s assumption that 

the stack height of magnetic ballasts will 

not increase, manufacturers do not 

expect new and amended standards to 

strand (make obsolete in advance of 

complete depreciation) a significant 

share of their production assets. As 

opposed to other more capital-intensive 

appliance manufacturers, much of the 

expenses required to achieve higher 

efficiency levels would occur through 

research and development, engineering, 

and testing efforts. 

DOE based its estimates of the 

product conversion costs that would be 

required to meet each TSL on 

information obtained from manufacturer 

interviews and catalog data on the 

number and efficiency of models that 

each major manufacturer supports. DOE 

estimated the product development 

costs manufacturers would incur for 

each model that would need to be 

converted based on the necessary 

engineering and testing resources 

required to redesign each model. DOE 

assumed higher R&D and testing costs 

for levels requiring electronic ballasts 

compared to magnetic ballasts. Testing 

costs include internal testing, UL 

testing, additional certifications, pilot 

runs, and product training. DOE then 

multiplied these per-model cost 

estimates for each interviewed 

manufacturer by the total number of 

ballast models that would need to be 

converted at each efficiency level in 

each wattage bin, based on information 

from manufacturer catalogs and 

interviews, to estimate the total product 

conversion costs. 

To separate total product conversion 

costs into indoor and outdoor 

equipment classes, DOE assigned costs 

based on the percentage of indoor or 

outdoor shipments in the NIA. Finally, 

DOE scaled these costs to account for 

the market share of the companies not 

interviewed. DOE’s estimates of the 

product conversion costs for metal 

halide ballasts affected by this 

rulemaking can be found in section 

VI.B.2, as follows and in chapter 13 of 

the NOPR TSD. 

As discussed above, DOE also 

estimated the capital conversion costs 

ballast manufacturers would incur to 

comply with the potential new and 

amended energy conservation standards 

represented by each TSL. During 

interviews, DOE asked manufacturers to 

estimate the capital expenditures 

required to expand the production of 

higher-efficiency products. These 

estimates included the required tooling 

and plant changes that would be 

necessary if product lines meeting the 

proposed standard did not currently 

exist. 

DOE estimated capital conversion 

costs, like product conversion costs, 

based on interviews with 

manufacturers. Some manufacturers 

anticipated minimal to no conversion 

costs because of the flexibility of their 

existing equipment or because they 

source certain ballast types rather than 

produce them in-house. Other 

manufacturers expected greater capital 

conversion costs because they would 

need to acquire new stamping dies for 

higher-efficiency magnetic ballasts and/ 

or wave solder machines for electronic 

ballasts. In general, DOE’s view is that 

significant changes to existing 

production lines and equipment would 

not be necessary in response to new or 

amended standards. It is therefore 

unlikely that most manufacturers would 

require high levels of capital 

expenditures compared to ordinary 

capital additions or replacements. 

DOE scaled its estimated conversion 

costs based on interviews to account for 

the market share of the companies not 

interviewed. DOE’s estimates of the 

capital conversion costs for metal halide 

ballasts can be found in section VI.B.2, 

as follows and in chapter 13 of the 

NOPR TSD. 

Fixture Industry Conversion Costs 

To estimate conversion costs for 

fixture manufacturers, DOE again based 

its estimates on manufacturer interviews 

and industry research. DOE doubts that 

the stack height of magnetic ballasts will 

increase in response to new and 

amended standards. As such, DOE 

assumed that fixture manufacturers 

would be able to use higher-efficiency 

magnetic ballasts without incurring 

redesign or capital costs. Even if higherefficiency levels can be met with 

magnetic ballasts, DOE expects 

manufacturers will incur one-time noncapital expenses at these levels 

associated with testing, literature 

changes, and marketing costs. These 

costs are included in DOE’s product 

conversion cost estimates. 

At efficiency levels requiring 

electronic ballasts, DOE expects that 

fixture manufacturers may face more 

significant conversion costs. 

Manufacturers will have to consider 

thermal protection in their product 

designs because more-efficient 

electronic ballasts have lower tolerances 

for high temperatures than magnetic 

ballasts do. DOE estimated product 

conversion costs for fixture 

manufacturers by multiplying the 

number of product families in each 

wattage bin by the expected cost of 

fixture redesign and testing. DOE then 

multiplied these totals by the percentage 

of fixtures that would need to be 

redesigned at each efficiency level. 

DOE employed a similar methodology 

to estimate fixture capital conversion 

costs at efficiency levels associated with 

electronic ballasts. Based on 

manufacturer interviews, DOE estimated 

platform tooling and equipment costs, 

such as costs for die castings, 

bracketing, and extrusions, and 

multiplied these costs by the number of 

fixtures affected by the standard. 

To separate total product and capital 

conversion costs for fixture 

manufacturers into indoor and outdoor 

equipment classes, DOE assigned costs 

based on the percentage of indoor and 

outdoor fixtures each interviewed 

manufacturer offers. DOE’s estimates of 

the product and capital conversion costs 

for metal halide lamp fixtures addressed 

in this rulemaking can be found in 

section VI.B.2, as follows and in chapter 

13 of the NOPR TSD. 

3. Discussion of Comments 

During the April 2011 public meeting, 

interested parties commented on the 

assumptions and results of the 

preliminary TSD. DOE addresses those 

comments below relating to the 

compliance period, the opportunity cost 


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of investments, and impacts on 

competition. 

a. Compliance Period 

NEMA stated that fixture 

manufacturers may be unable to meet 

the compliance date of standards for all 

products. NEMA believes that it could 

take one year to redesign the ballasts, 

one year to test and certify the ballasts, 

and one year to handle marketing of 

fixture phase-outs. NEMA said that this 

entire process may be difficult and 

burdensome given the scope of the 

rulemaking. (NEMA, No. 34 at p. 15) 

OSI also noted its concern about the 

compliance period, stating that any 

change in the standard must provide 

adequate time for the ballast OEMs to 

develop, test, and begin producing the 

additional ballast types needed to 

provide a complete line of electronic 

metal halide ballasts. Fixture OEMs 

would, in turn, need adequate time to 

redesign their products. (OSI, No. 27 at 

p. 6) 

At the same time, OSI stated that 

ballast OEMs could provide bench-top 

temperature-rise data to help reduce the 

UL testing requirements and costs for 

the fixture OEMs. OSI also stated that 

several ballast manufacturers are 

already manufacturing electronic metal 

halide ballasts and are developing 

additional products to broaden their 

product offerings. OSI has plans to 

expand production capacity to supply 

market needs. On the fixture side, 

several manufacturers are already 

developing fixtures using electronic 

metal halide ballasts, and these 

manufacturers will be able to expand 

their fixture offering as more ballast 

types become available. (OSI, No. 27 at 

p. 6, 7) 

DOE acknowledges that fixture 

manufacturers and ballast 

manufacturers may need to coordinate 

production to comply with a MHLF 

energy conservation standard. However, 

EISA 2007 specifies a compliance date 

of January 1, 2015, and DOE proposes to 

adopt this date in today’s NOPR. (42 

U.S.C. 6295(hh)(2)(B)) DOE requests 

comment on the impact and feasibility 

of the compliance date for 

manufacturers. 

b. Opportunity Cost of Investments 

Several manufacturers argued that 

developing products to meet new and 

amended energy conservation standards 

has an opportunity cost due to the 

limited resources at their disposal. 

Manufacturers are currently focusing on 

new technologies such as solid-state 

lighting and controls with greater 

potential energy savings than mature 

technologies such as HID. New and 

amended standards for metal halide 

lamp fixtures could divert finite 

resources away from new product 

development, at a significant cost to the 

manufacturers. (NEMA, No. 34 at p. 7– 

8; Philips, Public Meeting Transcript, 

No. 33 at p. 81; Georgia Power, No. 28 

at p.1) Manufacturers may also choose 

not to convert their products and 

abandon the market because of the high 

opportunity cost. This could effectively 

eliminate the metal halide market and 

negate any potential energy savings 

from MHLF and HID lamp standards as 

well. (Philips, Public Meeting 

Transcript, No. 33 at p. 132; NEMA, No 

34 at p. 16) 

DOE recognizes the opportunity cost 

associated with any investment, and 

agrees that manufacturers would need to 

spend capital to meet today’s standards 

that they would not have to spend in the 

base case. As a result, manufacturers 

must determine the extent to which they 

will balance investment in the metal 

halide market with investment in 

emerging technologies. The companies 

will have to weigh tradeoffs between 

deferring investments and deploying 

additional capital. DOE includes the 

costs of meeting today’s proposed 

standard in its analysis. 

c. Impact on Competition 

NEMA stated that manufacturers who 

produce only magnetic ballasts would 

be at a disadvantage should DOE set a 

standard that requires the use of 

electronic ballasts. NEMA believed that 

magnetic ballast manufacturers would 

not be able to move to electronic ballast 

production because of the increased cost 

and complexity of electronic ballast 

designs and because of the different 

engineering specializations required. 

(NEMA, No. 34 at p. 16) OSI stated, 

however, that no manufacturers produce 

magnetic ballasts as their only product 

type, and many of those that offer 

magnetic ballasts also manufacture LED 

power supplies and drivers, which 

require the same or greater technology 

knowledge to develop and manufacture 

as electronic ballasts do. (OSI, No. 27 at 

p. 5) 

DOE agrees with NEMA that 

manufacturers with no experience 

producing electronic ballasts would face 

a steeper learning curve than those with 

experience. DOE doubts that 

competition will be significantly 

affected, however. Electronic ballasts 

are widely used throughout the 

industry, particularly at lower wattages. 

Additionally, as suggested by OSI, DOE 

has not identified any manufacturers 

that produce only magnetic metal halide 

ballasts. 

4. Manufacturer Interviews 

DOE interviewed manufacturers 

representing more than 65 percent of 

metal halide lamp fixture sales and 90 

percent of metal halide ballast sales. 

These NOPR interviews were in 

addition to the preliminary interviews 

DOE conducted as part of the 

engineering analysis. The information 

gathered during these interviews 

enabled DOE to tailor the GRIM to 

reflect the unique financial 

characteristics of the ballast and fixture 

industries. All interviews provided 

information that DOE used to evaluate 

the impacts of potential new and 

amended energy conservation standards 

on manufacturer cash flows, 

manufacturing capacities, and 

employment levels. Appendix 13A of 

the NOPR TSD contains the interview 

guides DOE used to conduct the MIA 

interviews. 

During the manufacturer interviews, 

DOE asked manufacturers to describe 

their major concerns about this 

rulemaking. The following sections 

describe the most significant issues 

identified by manufacturers. DOE also 

included additional concerns in chapter 

13 of the NOPR TSD. 

a. Ability To Recoup Investments 

Several manufacturers worried that 

new and amended energy conservation 

standards would force them to invest 

while their market was shrinking. The 

increasing market penetration of 

emerging technologies could strand 

these investments, particularly as metal 

halide lamp fixture standards hasten the 

switch to emerging technologies by 

narrowing the difference between MHLF 

and emerging technology purchase 

prices. If the standard threatens to 

accelerate the ongoing migration to new 

technology, manufacturers would be 

more likely to abandon their metal 

halide product lines. 

To address the emerging technologies 

issues discussed by manufacturers, DOE 

included several shipment scenarios in 

both the NIA and the GRIM. See chapter 

10 and chapter 13 of the NOPR TSD for 

a discussion of the shipment scenarios 

used in the respective analyses. DOE is 

seeking comment on whether 

manufacturers’ ability to recoup 

investment, combined with the 

opportunity cost of investment would 

encourage manufacturers to exit the 

metal halide lamp fixture market. 

b. Efficiency Metric Used 

Some manufacturers disagreed over 

which metric should be used to regulate 

efficiency for metal halide lamp 

fixtures. Manufacturers agreed that 


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43See Bureau of Economic Analysis, Regional 

Multipliers: A User Handbook for the Regional 

Input-Output Modeling System (RIMS II), 

Washington, DC., U.S. Department of Commerce, 

1992. 

44Roop, J. M., M. J. Scott, and R. W. Schultz, 

ImSET 3.1: Impact of Sector Energy Technologies 

(PNNL–18412 Pacific Northwest National 

Laboratory) (2009). Available at www.pnl.gov/main/ 

publications/external/technical_reports/PNNL18412.pdf. 

45Stewart, R.L., J.B. Stone, and M.L. Streitwieser, 

‘‘U.S. Benchmark Input-Output Accounts, 2002,’’ 

Survey of Current Business (Oct. 2007). 

46Scott, M., J.M. Roop, R.W. Schultz, D.M. 

Anderson, K.A. Cort, ‘‘The Impact of DOE Building 

Technology Energy Efficiency Programs on U.S. 

Employment, Income, and Investment.’’ Energy 

Economics (Sep. 2008). 

ballast efficiency is the most 

straightforward metric to use and the 

simplest for compliance purposes, but 

they noted that it ignores opportunities 

for energy savings from lamps and the 

fixtures themselves. At the same time, 

some manufacturers did not favor a 

lamp and ballast metric because a lamp 

and ballast metric could confer a 

competitive advantage to those 

manufacturers who produce both metal 

halide lamps and ballasts. Lastly, 

several manufacturers opposed the use 

of a fixture efficiency metric. 

In today’s notice, DOE proposes a 

ballast efficiency metric for the reasons 

described in section III.B. DOE notes 

that it is concurrently conducting a 

rulemaking for HID lamps, including 

metal halide lamps, which will examine 

the lamp efficiency component of the 

metal halide system. 

c. Maintenance of 150 W Exemption 

Nearly all manufacturers said that 

DOE should maintain its exemption for 

150 W only fixtures rated for wet (e.g., 

outdoor) locations and containing 

ballasts rated to operate in air 

temperatures higher than 50 °C. 

Manufacturers stated that it is costprohibitive to meet EISA 2007 standard 

levels with magnetic ballasts, and 

electronic ballasts are currently less 

reliable for outdoor applications. 

Furthermore, manufacturers 

acknowledged that this exemption 

created energy savings by pushing 

customers of the more-expensive 175 W 

ballasts to the less-expensive 150 W 

magnetic ballasts. Manufacturers 

contended that customers would revert 

back to the 175 W equipment if the 

exemption were not maintained because 

of the significant price increase caused 

by bringing the 150 W ballast into 

compliance. This cost increase would 

cause customers to revert to 175 W, they 

said, thereby negating any potential 

energy savings that could have been 

achieved by regulating 150 W products. 

DOE, however, is proposing not to 

maintain the 150 W exemption in 

today’s notice for the reasons detailed in 

section III.A.1. 

J. 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 not considered here—are any 

changes in the number of employees 

working for manufacturers of the 

equipment that is the subject of this 

rulemaking, their suppliers, and related 

service firms. Indirect employment 

impacts—the subject of this section—are 

changes in employment within the 

larger economy that occur due to the 

shift in expenditures and capital 

investment caused by the purchase and 

operation of more-efficient equipment. 

The MIA addresses the direct 

employment impacts that concern metal 

halide lamp fixture manufacturers in 

section VI.B.2. 

The indirect employment impacts of 

standards consist of the net jobs created 

or eliminated in the national economy, 

outside of the manufacturing sector 

being regulated, because of: (1) Reduced 

spending on energy by end-users; (2) 

reduced spending on new energy 

supplies by the utility industry; (3) 

increased spending on new equipment 

to which the new standards apply; and 

(4) the effects of those three factors 

throughout the economy. DOE expects 

the net monetary savings from standards 

to be redirected to other forms of 

economic activity, and expects these 

shifts in spending and economic activity 

to affect the demand for labor in the 

short term, as explained as follows. 

One method for assessing the possible 

effects of such shifts in economic 

activity on the demand for labor is to 

compare sector employment statistics 

developed by the Labor Department’s 

Bureau of Labor Statistics (BLS). (Data 

on industry employment, hours, labor 

compensation, value of production, and 

the implicit price deflator for output for 

these industries are available upon 

request by calling the Division of 

Industry Productivity Studies (202–691– 

5618) or by sending a request by email 

to dipsweb@bls.gov. These data are also 

available at www.bls.gov/news.release/

prin1.nr0.htm. The BLS regularly 

publishes its estimates of the number of 

jobs per million dollars of economic 

activity in different sectors of the 

economy, as well as the jobs created 

elsewhere in the economy by this same 

economic activity. Data from the BLS 

indicate that expenditures in the utility 

sector generally create fewer jobs (both 

directly and indirectly) than 

expenditures in other sectors of the 

economy. There are many reasons for 

these differences, including wage 

differences and the fact that the utility 

sector is more capital-intensive and less 

labor-intensive than other sectors.43

Energy conservation standards reduce 

customer utility bills. Because reduced 

customer expenditures for energy likely 

lead to increased expenditures in other 

sectors of the economy, the general 

effect of efficiency standards is to shift 

economic activity from a less laborintensive sector (i.e., the utility sector) 

to more labor-intensive sectors (e.g., the 

retail and manufacturing sectors). Thus, 

based on the BLS data alone, the 

Department believes that net national 

employment will increase due to shifts 

in economic activity resulting from new 

and amended standards for metal halide 

lamp fixtures. 

In developing today’s proposed 

standards, DOE estimated indirect 

national employment impacts using an 

input/output model of the U.S. economy 

called Impact of Sector Energy 

Technologies (ImSET), version 3.1.1. 

ImSET is a spreadsheet model of the 

U.S. economy that focuses on 187 

sectors most relevant to industrial, 

commercial, and residential building 

energy use.44 ImSET is a specialpurpose version of the ‘‘U.S. Benchmark 

National Input-Output’’ (I–O) model, 

designed to estimate the national 

employment and income effects of 

energy-saving technologies. The ImSET 

software includes a computer-based I–O 

model with structural coefficients to 

characterize economic flows among the 

187 sectors. ImSET’s national economic 

I–O structure is based on a 2002 U.S. 

benchmark table,45 specially aggregated 

to the 187 sectors. DOE estimated 

changes in expenditures using the NIA 

spreadsheet. Using ImSET, DOE 

estimated the net national, indirect 

employment impacts on employment by 

sector of potential new efficiency 

standards for metal halide ballasts. For 

more details on the employment impact 

analysis, see chapter 14 of the NOPR 

TSD. 

DOE notes that ImSET is not a general 

equilibrium projection model, and 

understands the uncertainties involved 

in projecting employment impacts, 

especially changes in the later years of 

the analysis.46 Because ImSET does not 

incorporate price changes, the 

employment effects predicted by ImSET 

may over-estimate actual job impacts 

over the long run for this rule. Because 

ImSET predicts small job impacts 

resulting from this rule, regardless of 

these uncertainties, the actual job 

impacts are likely to be negligible in the 


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51512 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

overall economy. DOE may consider the 

use of other modeling approaches for 

examining long-run employment 

impacts. 

DOE also notes that the employment 

impacts estimated with ImSET for the 

entire economy differ from the 

employment impacts in the lighting 

manufacturing sector estimated in 

NOPR TSD chapter 13 using the GRIM. 

The methodologies used and the sectors 

analyzed in the ImSET and GRIM 

models are different. 

K. Utility Impact Analysis 

The utility impact analysis estimates 

several important effects on the utility 

industry of the adoption of new or 

amended standards. For this analysis, 

DOE used the NEMS–BT model to 

generate forecasts of electricity 

consumption, electricity generation by 

plant type, and electric generating 

capacity by plant type, that would result 

from each considered TSL. DOE 

obtained the energy savings inputs 

associated with efficiency 

improvements to considered products 

from the NIA. DOE conducts the utility 

impact analysis as a scenario that 

departs from the latest AEO Reference 

Case. In the analysis for today’s rule, the 

estimated impacts of standards are the 

differences between values forecasted 

by NEMS–BT and the values in the 

AEO2013 Reference Case. Chapter 15 of 

the NOPR TSD describes the utility 

impact analysis. 

L. Emissions Analysis 

In the emissions analysis, DOE 

estimated the reduction in power sector 

emissions of CO2, NOX, SO2, and Hg 

from potential energy conservation 

standards for metal halide lamp fixtures. 

In addition to estimating impacts of 

standards on power sector emissions, 

DOE estimated emissions impacts in 

production activities that provide the 

energy inputs to power plants. These are 

referred to as ‘‘upstream’’ emissions. In 

accordance with the FFC Statement of 

Policy (76 FR 51281 (August 18, 2011)), 

this FFC analysis includes impacts on 

emissions of methane (CH4) and nitrous 

oxide (N2O), both of which are 

recognized as greenhouse gases. 

To estimate impacts on the 

environment, DOE conducted the 

emissions analysis using emissions 

factors that were derived from data in 

AEO2013, supplemented by data from 

other sources. DOE developed separate 

emissions factors for power sector 

emissions and upstream emissions. The 

method that DOE used to derive 

emissions factors is described in chapter 

16 of the NOPR TSD. 

EIA prepares the Annual Energy 

Outlook using NEMS. Each annual 

version of NEMS incorporates the 

projected impacts of existing air quality 

regulations on emissions. AEO2013 

generally represents current legislation 

and environmental regulations, 

including recent government actions, for 

which implementing regulations were 

available as of December 31, 2012. 

SO2 emissions from affected 

electricity-generating units (EGUs) are 

subject to nationwide and regional 

emissions cap-and-trade programs. Title 

IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs 

in the 48 contiguous states and the 

District of Columbia (DC). SO2

emissions from 28 eastern states and DC 

were also limited under the Clean Air 

Interstate Rule (CAIR; 70 FR 25162 (May 

12, 2005)), which created an allowancebased trading program. CAIR was 

remanded to the U.S. Environmental 

Protection Agency (EPA) by the U.S. 

Court of Appeals for the District of 

Columbia Circuit but it remained in 

effect. See North Carolina v. EPA, 550 

F.3d 1176 (D.C. Cir. 2008); North 

Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008). On July 6, 2011 EPA issued a 

replacement for CAIR, the Cross-State 

Air Pollution Rule (CSAPR). 76 FR 

48208 (Aug. 8, 2011). On August 21, 

2012, the D.C. Circuit issued a decision 

to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, 696 F.3d 7, 38 

(D.C. Cir. 2012). The court ordered EPA 

to continue administering CAIR. The 

AEO2013 emissions factors used for 

today’s NOPR assume that CAIR 

remains a binding regulation through 

2040. 

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, any excess 

SO2 emissions allowances resulting 

from the lower electricity demand 

caused by the imposition of an 

efficiency standard could be used to 

permit offsetting increases in SO2

emissions by any regulated EGU. In past 

rulemakings, DOE recognized that there 

was uncertainty about the effects of 

efficiency standards on SO2 emissions 

covered by the existing cap-and-trade 

system, but it concluded that negligible 

reductions in power sector SO2

emissions would occur as a result of 

standards. 

Beginning in 2015, however, SO2

emissions will fall as a result of the 

Mercury and Air Toxics Standards 

(MATS) for power plants, which were 

announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012). In the 

final MATS rule, EPA established a 

standard for hydrogen chloride as a 

surrogate for acid gas hazardous air 

pollutants (HAP), and also established a 

standard for SO2 (a non-HAP acid gas) 

as an alternative equivalent surrogate 

standard for acid gas HAP. The same 

controls are used to reduce HAP and 

non-HAP acid gas; thus, SO2 emissions 

will be reduced as a result of the control 

technologies installed on coal-fired 

power plants to comply with the MATS 

requirements for acid gas. AEO2013 

assumes that, in order to continue 

operating, coal plants must have either 

flue gas desulfurization or dry sorbent 

injection systems installed by 2015. 

Both technologies, which are used to 

reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS 

shows a reduction in SO2 emissions 

when electricity demand decreases (e.g., 

as a result of energy efficiency 

standards). Emissions will be far below 

the cap that would be established by 

CSAPR, so it is unlikely that excess SO2

emissions allowances resulting from the 

lower electricity demand would be 

needed or used to permit offsetting 

increases in SO2 emissions by any 

regulated EGU. Therefore, DOE believes 

that efficiency standards will reduce 

SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX

emissions in 28 eastern States and the 

District of Columbia. Energy 

conservation standards are expected to 

have little effect on NOX emissions in 

those States covered by CSAPR because 

excess NOX emissions allowances 

resulting from the lower electricity 

demand could be used to permit 

offsetting increases in NOX emissions. 

However, standards would be expected 

to reduce NOX emissions in the States 

not affected by the caps, so DOE 

estimated NOX emissions reductions 

from the standards considered in 

today’s NOPR for these States. 

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. DOE 

estimated mercury emissions reduction 

using NEMS–BT based on AEO2013, 

which incorporates the MATS. 

M. Monetizing Carbon Dioxide and 

Other Emissions Impacts 

As part of the development of this 

proposed rule, DOE considered the 

estimated monetary benefits likely to 

result from the reduced emissions of 

CO2 and NOX that are expected to result 

from each of the TSLs considered. In 

order to make this calculation, similar to 

the calculation of the NPV of customer 

benefit, DOE considered the reduced 

emissions expected to result over the 


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47National Research Council. Hidden Costs of 

Energy: Unpriced Consequences of Energy 

Production and Use. National Academies Press: 

Washington, DC (2009). 

48See Average Fuel Economy Standards 

Passenger Cars and Light Trucks Model Year 2011, 

74 FR 14196 (March 30, 2009) (Final Rule); Final 

Environmental Impact Statement Corporate Average 

Fuel Economy Standards, Passenger Cars and Light 

Trucks, Model Years 2011–2015 at 3–90 (Oct. 2008) 

(Available at: www.nhtsa.gov/fuel-economy). 49See Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015, 73 FR 24352 (May 2, 2008) (Proposed 

Rule); Draft Environmental Impact Statement 

Corporate Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015 at 3–58 (June 2008) (Available at: 

www.nhtsa.gov/fuel-economy). 

lifetime of products shipped in the 

projection period for each TSL. This 

section summarizes the basis for the 

monetary values used for each of these 

emissions and presents the values 

considered in this rulemaking. 

For today’s NOPR, DOE is relying on 

a set of values for the social cost of 

carbon (SCC) that was developed by an 

interagency process. A summary of the 

basis for these values is provided below, 

and a more detailed description of the 

methodologies used is provided as an 

appendix to chapter 17 of the NOPR 

TSD. 

1. Social Cost of Carbon 

The SCC is an estimate of the 

monetized damages associated with an 

incremental increase in carbon 

emissions in a given year. It is intended 

to include (but is not limited to) changes 

in net agricultural productivity, human 

health, property damages from 

increased flood risk, and the value of 

ecosystem services. Estimates of the 

SCC are provided in dollars per metric 

ton of carbon dioxide. A domestic SCC 

value is meant to reflect the value of 

damages in the United States resulting 

from a unit change in carbon dioxide 

emissions, while a global SCC value is 

meant to reflect the value of damages 

worldwide. 

Under section 1(b) of E.O. 12866, 

agencies must, to the extent permitted 

by law, ‘‘assess both the costs and the 

benefits of the intended regulation and, 

recognizing that some costs and benefits 

are difficult to quantify, propose or 

adopt a regulation only upon a reasoned 

determination that the benefits of the 

intended regulation justify its costs.’’ 

The purpose of the SCC estimates 

presented here is to allow agencies to 

incorporate the monetized social 

benefits of reducing CO2 emissions into 

cost-benefit analyses of regulatory 

actions that have small, or ‘‘marginal,’’ 

impacts on cumulative global emissions. 

The estimates are presented with an 

acknowledgement of the many 

uncertainties involved and with a clear 

understanding that they should be 

updated over time to reflect increasing 

knowledge of the science and 

economics of climate impacts. 

As part of the interagency process that 

developed these SCC estimates, 

technical experts from numerous 

agencies met on a regular basis to 

consider public comments, explore the 

technical literature in relevant fields, 

and discuss key model inputs and 

assumptions. The main objective of this 

process was to develop a range of SCC 

values using a defensible set of input 

assumptions grounded in the existing 

scientific and economic literatures. In 

this way, key uncertainties and model 

differences transparently and 

consistently inform the range of SCC 

estimates used in the rulemaking 

process. 

a. Monetizing Carbon Dioxide Emissions 

When attempting to assess the 

incremental economic impacts of CO2

emissions, the analyst faces a number of 

serious challenges. A recent report from 

the National Research Council 47 points 

out that any assessment will suffer from 

uncertainty, speculation, and lack of 

information about (1) future emissions 

of GHGs, (2) the effects of past and 

future emissions on the climate system, 

(3) the impact of changes in climate on 

the physical and biological 

environment, and (4) the translation of 

these environmental impacts into 

economic damages. As a result, any 

effort to quantify and monetize the 

harms associated with climate change 

will raise serious questions of science, 

economics, and ethics and should be 

viewed as provisional. 

Despite the serious limits of both 

quantification and monetization, SCC 

estimates can be useful in estimating the 

social benefits of reducing CO2

emissions. Most Federal regulatory 

actions can be expected to have 

marginal impacts on global emissions. 

For such policies, the agency can 

estimate the benefits from reduced 

emissions in any future year by 

multiplying the change in emissions in 

that year by the SCC value appropriate 

for that year. The net present value of 

the benefits can then be calculated by 

multiplying each of these future benefits 

by an appropriate discount factor and 

summing across all affected years. This 

approach assumes that the marginal 

damages from increased emissions are 

constant for small departures from the 

baseline emissions path, an 

approximation that is reasonable for 

policies that have effects on emissions 

that are small relative to cumulative 

global CO2 emissions. For policies that 

have a large (non-marginal) impact on 

global cumulative emissions, there is a 

separate question of whether the SCC is 

an appropriate tool for calculating the 

benefits of reduced emissions. This 

concern is not applicable to this notice, 

however. 

It is important to emphasize that the 

interagency process is committed to 

updating these estimates as the science 

and economic understanding of climate 

change and its impacts on society 

improves over time. In the meantime, 

the interagency group will continue to 

explore the issues raised by this analysis 

and consider public comments as part of 

the ongoing interagency process. 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

Past economic analyses for Federal 

regulations used a wide range of values 

to estimate the benefits associated with 

reducing CO2 emissions. The model 

year 2011 Corporate Average Fuel 

Economy final rule used both a 

‘‘domestic’’ SCC value of $2 per metric 

ton of CO2 and a ‘‘global’’ SCC value of 

$33 per metric ton of CO2 for 2007 

emission reductions (in 2007$), 

increasing both values at 2.4 percent per 

year. It also included a sensitivity 

analysis at $80 per metric ton of CO2.48

The proposed rule for Model Years 

2011–2015 assumed a domestic SCC 

value of $7 per metric ton of CO2 (in 

2006$) for 2011 emission reductions 

(with a range of $0–$14 for sensitivity 

analysis), also increasing at 2.4 percent 

per year.49 A regulation for packaged 

terminal air conditioners and packaged 

terminal heat pumps finalized by DOE 

in 2008 used a domestic SCC range of 

$0 to $20 per metric ton CO2 for 2007 

emission reductions (in 2007$). 73 FR 

58772, 58814 (Oct. 7, 2008) In addition, 

EPA’s 2008 Advance Notice of Proposed 

Rulemaking on Regulating Greenhouse 

Gas Emissions Under the Clean Air Act 

identified what it described as ‘‘very 

preliminary’’ SCC estimates subject to 

revision. 73 FR 44354 (July 30, 2008). 

EPA’s global mean values were $68 and 

$40 per metric ton CO2 for discount 

rates of approximately 2 percent and 3 

percent, respectively (in 2006$ for 2007 

emissions). 

In 2009, an interagency process was 

initiated to offer a preliminary 

assessment of how best to quantify the 

benefits from reducing CO2 emissions. 

To ensure consistency in how benefits 

are evaluated across agencies, the 

Administration sought to develop a 

transparent and defensible method, 

specifically designed for the rulemaking 

process, to quantify avoided climate 

change damages from reduced CO2


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50Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866, Technical 

Model Update for the Social Cost of Carbon (SCC). 

Interagency Working Group on Social Cost of 

Carbon, United States Government, May 2013. 

51Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United 

States Government, 2010. 

emissions. The interagency group did 

not undertake any original analysis. 

Instead, it combined SCC estimates from 

the existing literature to use as interim 

values until a more comprehensive 

analysis could be conducted. The 

outcome of the preliminary assessment 

by the interagency group was a set of 

five interim values: global SCC 

estimates for 2007 (in 2006$) of $55, 

$33, $19, $10, and $5 per ton of CO2. 

These interim values represent the first 

sustained interagency effort within the 

U.S. government to develop an SCC for 

use in regulatory analysis. The results of 

this preliminary effort were presented in 

several proposed and final rules. 

c. Current Approach and Key 

Assumptions 

After the release of the interim values, 

the interagency group reconvened on a 

regular basis to generate improved SCC 

estimates. The group considered public 

comments and further explored the 

technical literature in relevant fields. 

The interagency group relied on three 

integrated assessment models 

commonly used to estimate the SCC: the 

FUND, DICE, and PAGE models. These 

models are frequently cited in the peerreviewed literature and were used in the 

last assessment of the Intergovernmental 

Panel on Climate Change. Each model 

was given equal weight in the SCC 

values that were developed. The SCC 

values used for today’s notice were 

generated using the most recent versions 

of the three integrated assessment 

models that have been published in the 

peer-reviewed literature.50

Each model takes a slightly different 

approach to model how changes in 

emissions result in changes in economic 

damages. A key objective of the 

interagency process was to enable a 

consistent exploration of the three 

models while respecting the different 

approaches to quantifying damages 

taken by the key modelers in the field. 

An extensive review of the literature 

was conducted to select three sets of 

input parameters for these models: 

climate sensitivity, socio-economic and 

emissions trajectories, and discount 

rates. A probability distribution for 

climate sensitivity was specified as an 

input into all three models. In addition, 

the interagency group used a range of 

scenarios for the socio-economic 

parameters and a range of values for the 

discount rate. All other model features 

were left unchanged, relying on the 

model developers’ best estimates and 

judgments. 

The interagency group selected four 

sets of SCC values for use in regulatory 

analyses.51 Three values are based on 

the average SCC from three integrated 

assessment models, at discount rates of 

2.5, 3, and 5 percent. The fourth value, 

which represents the 95th percentile 

SCC estimate across all three models at 

a 3-percent discount rate, is included to 

represent higher-than-expected impacts 

from temperature change further out in 

the tails of the SCC distribution. The 

values estimated for 2010 grow in real 

terms over time, as depicted in Table 

V.8. 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 preference is 

given to consideration of the global 

benefits of reducing CO2 emissions. 

TABLE V.8—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050 

[In 2007 dollars per metric ton CO2] 

Discount rate 

5% Avg. 3% Avg. 2.5% Avg. 3% 95th 

2010 ................................................................................................................................. 4.7 21.4 35.1 64.9 

2015 ................................................................................................................................. 5.7 23.8 38.4 72.8 

2020 ................................................................................................................................. 6.8 26.3 41.7 80.7 

2025 ................................................................................................................................. 8.2 29.6 45.9 90.4 

2030 ................................................................................................................................. 9.7 32.8 50.0 100.0 

2035 ................................................................................................................................. 11.2 36.0 54.2 109.7 

2040 ................................................................................................................................. 12.7 39.2 58.4 119.3 

2045 ................................................................................................................................. 14.2 42.1 61.7 127.8 

2050 ................................................................................................................................. 15.7 44.9 65.0 136.2 

Table V.9 shows the updated sets of 

SCC estimates in five year increments 

from 2010 to 2050. Appendix 17B of the 

NOPR TSD provides the full set of 

values, as well as the 2013 draft report 

from the interagency group. The central 

value that emerges is the average SCC 

across models at the 3 percent discount 

rate. However, for purposes of capturing 

the uncertainties involved in regulatory 

impact analysis, the interagency group 

emphasizes the importance of including 

all four sets of SCC values. 

TABLE V.9—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050 

[In 2007 dollars per metric ton CO2] 

Year 

Discount rate % 

5 3 2.5 3 

Average Average Average 

95th Percentile 

2010 ................................................................................................................................. 11 33 52 90 

2015 ................................................................................................................................. 12 38 58 109 

2020 ................................................................................................................................. 12 43 65 129 


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52The interagency report presents SCC values 

through 2050. DOE derived values after 2050 using 

the 3-percent per year escalation rate used by the 

interagency group. 

53For 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. 

54OMB, Circular A–4: Regulatory Analysis (Sept. 

17, 2003). 

55See section V.C.3 for more information on the 

chosen representative wattages. 

TABLE V.9—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050—Continued 

[In 2007 dollars per metric ton CO2] 

Year 

Discount rate % 

5 3 2.5 3 

Average Average Average 

95th Percentile 

2025 ................................................................................................................................. 14 48 70 144 

2030 ................................................................................................................................. 16 52 76 159 

2035 ................................................................................................................................. 19 57 81 176 

2040 ................................................................................................................................. 21 62 87 192 

2045 ................................................................................................................................. 24 66 92 206 

2050 ................................................................................................................................. 27 71 98 221 

It is important to recognize that a 

number of key uncertainties remain, and 

that current SCC estimates should be 

treated as provisional and revisable 

since they will evolve with improved 

scientific and economic understanding. 

The interagency group also recognized 

that the existing models are imperfect 

and incomplete. The National Research 

Council report mentioned above points 

out that there is tension between the 

goal of producing quantified estimates 

of the economic damages from an 

incremental ton of CO2 emissions and 

the limits of existing efforts to model 

these effects. There are a number of 

concerns and problems that should be 

addressed by the research community, 

including research programs housed in 

many of the Federal agencies 

participating in the interagency process 

to estimate the SCC. The interagency 

group intends to periodically review 

and reconsider those estimates to reflect 

increasing knowledge of the science and 

economics of climate impacts, as well as 

improvements in modeling. 

In summary, in considering the 

potential global benefits resulting from 

reduced CO2 emissions, DOE used the 

values from the 2013 interagency report, 

adjusted to 2012$ using the Gross 

Domestic Product price deflator. For 

each of the four cases specified, the 

values used for emissions in 2015 were 

$12.9, $40.8, $62.2, and $117 per metric 

ton avoided (values expressed in 

2012$).52 DOE derived values after 2050 

using the growth rate for the 2040–2050 

period in the interagency update. 

DOE multiplied the CO2 emissions 

reduction estimated for each year by the 

SCC value for that year in each of the 

four cases. To calculate a present value 

of the stream of monetary values, DOE 

discounted the values in each of the 

four cases using the specific discount 

rate that had been used to obtain the 

SCC values in each case. 

2. Valuation of Other Emissions 

Reductions 

DOE investigated the potential 

monetary benefit of reduced NOX

emissions from the TSLs it considered. 

As noted above, DOE has taken into 

account how new or amended energy 

conservation standards would reduce 

NOX emissions in those 22 states that 

are not affected by the CSAPR. DOE 

estimated the monetized value of NOX

emissions reductions resulting from 

each of the TSLs considered for today’s 

NOPR based on estimates found in the 

relevant scientific literature. Available 

estimates suggest a very wide range of 

monetary values per ton of NOX from 

stationary sources, ranging from $468 to 

$4,809 per ton in 2012$).53 In 

accordance with OMB guidance,54 DOE 

calculated the monetary benefits using 

each of the economic values for NOX

and real discount rates of 3 percent and 

7 percent. 

DOE did not monetize Hg emission 

reductions because it is currently 

evaluating estimates of the value of Hg 

emissions. 

VI. Analytical Results 

A. Trial Standard Levels 

DOE analyzed the benefits and 

burdens of a number of TSLs for the 

metal halide lamp fixtures that are the 

subject of today’s proposed rule. Table 

VI.1 presents the trial standard levels 

and the corresponding equipment class 

ELs for representative equipment 

classes.55 See the engineering analysis 

in section V.C.9 of this NOPR for a more 

detailed discussion of the efficiency 

levels. 

In the following section, DOE presents 

the analytical results for the TSLs of the 

equipment classes that DOE analyzed 

directly. DOE scaled the ELs for these 

representative equipment classes to 

create ELs for other equipment classes 

that were not directly analyzed as set 

forth in chapter 5 of the NOPR TSD. For 

more details on the representative 

equipment classes, please see section 

V.C.2. 

TABLE VI.1—TRIAL STANDARD LEVELS

Rep. wattage TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

70 W Indoor ....................................................................................................... EL1 EL2 EL2 EL2 EL4 

70 W Outdoor .................................................................................................... EL1 EL2 EL2 EL3 EL4 

150 W Indoor ..................................................................................................... EL1 EL2 EL4 EL4 EL4 

150 W Outdoor .................................................................................................. EL1 EL2 EL4 EL4 EL4 

250 W Indoor ..................................................................................................... EL1 EL2 EL2 EL2 EL4 

250 W Outdoor .................................................................................................. EL1 EL2 EL2 EL2 EL4 

400 W Indoor ..................................................................................................... EL1 EL2 EL2 EL2 EL4 


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56The nomenclature 70 W indoor fixture refers to 

the ≥50 W and ≤100 W indoor equipment class. 70 

W is the representative wattage for the equipment 

class as discussed in section V.C.3. A similar 

shorthand naming convention is used for other 

equipment classes. 

TABLE VI.1—TRIAL STANDARD LEVELS—Continued 

Rep. wattage TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

400 W Outdoor .................................................................................................. EL1 EL2 EL2 EL2 EL4 

1000 W Indoor ................................................................................................... EL1+DS * EL2+DS EL2+DS EL2+DS EL2+DS 

1000 W Outdoor ................................................................................................ EL1+DS EL2+DS EL2+DS EL2+DS EL2+DS 

* DS is a design standard that bans the use of probe-start ballasts in new metal halide lamp fixtures. 

TSL1 represents EL1 for each 

equipment class with a positive NPV at 

EL1. TSL 1 would set energy 

conservation standards at EL1 for the 

indoor and outdoor fixtures at 70 W,56

150 W, 250 W, 400 W, and 1000 W. 

Standards included in TSL 1 typically 

can be satisfied by magnetic ballasts 

with mid-grade steel and copper 

windings. These ballasts are 

commercially available for the ballasts 

in indoor and outdoor 70 W, 250 W, and 

1000 W fixtures, with the rest being 

modeled. TSL 1 includes a design 

standard for indoor and outdoor 1000 W 

fixtures that prohibits the sale of probestart ballasts in new fixtures. 

TSL 2 represents the max tech 

magnetic ballast EL for each equipment 

class. TSL 2 would set energy 

conservation standards at EL2 for the 

indoor and outdoor fixtures at 70 W, 

150 W, 250 W, 400 W, and 1000 W. EL2 

is the max tech EL for the indoor and 

outdoor 1000 W fixtures. Standards 

included in TSL 2 typically can be 

satisfied by fixtures that contain 

magnetic ballasts with high-grade core 

steel and copper windings. These 

ballasts are modeled, except for the 

1000 W ballasts, which are 

commercially available. TSL 2 includes 

a design standard for the indoor and 

outdoor 1000 W fixtures that prohibits 

the sale of probe-start ballasts in new 

fixtures. TSL 2 sets the same standards 

for indoor and outdoor representative 

equipment classes at the same wattage. 

TSL 3 represents the maximum 

energy savings achievable with 

maximum positive NPV with the 

requirement that the same efficiency 

levels for fixtures operating indoors and 

outdoors be analyzed. TSL 3 would set 

energy conservation standards at EL2 for 

indoor and outdoor fixtures at 70 W, 

250 W, 400 W, and 1000 W, and EL4 for 

indoor and outdoor fixtures at 150 W. 

EL4 is the max tech EL for indoor and 

outdoor fixtures at 150 W, and EL2 is 

the max tech EL for indoor and outdoor 

fixtures at 1000 W. Standards included 

in TSL 3 typically can be satisfied by 

fixtures that contain magnetic ballasts 

with high-grade core steel and copper 

windings, except for the 150 W fixtures, 

which require max tech electronic 

ballasts with high-grade electronic 

components. The 150 W and 1000 W 

ballasts are commercially available, 

while the rest are modeled. TSL 3 

includes a design standard for indoor 

and outdoor 1000 W fixtures that 

prohibits the sale of probe-start ballasts 

in new fixtures. TSL 3 sets the same 

standards for indoor and outdoor 

representative equipment classes at the 

same wattage. 

TSL 4 represents the maximum 

energy savings achievable with a 

positive NPV for each equipment class, 

considering indoor and outdoor fixtures 

separately. TSL4 would set energy 

conservation standards at EL2 for indoor 

and outdoor 250 W, 400 W, and 1000 W 

fixtures and indoor 70 W fixtures, EL3 

for outdoor 70 W fixtures, and EL4 for 

indoor and outdoor 150 W fixtures. EL4 

is the max tech EL for indoor and 

outdoor fixtures at 150 W, and EL2 is 

the max tech EL for indoor and outdoor 

fixtures at 1000 W. Standards included 

in TSL 4 typically can be satisfied by 

fixtures that contain magnetic ballasts 

with high-grade core steel and copper 

windings, except for 70 W outdoor 

fixtures, which require standard-grade 

electronic ballasts, and 150 W fixtures, 

which require max tech electronic 

ballasts with high-grade electronic 

components. The ballasts for indoor and 

outdoor 150 W and 1000 W fixtures and 

outdoor 70 W fixtures are commercially 

available, and the rest are modeled. TSL 

4 includes a design standard for indoor 

and outdoor 1000 W fixtures that 

prohibits the sale of probe-start ballasts 

in new fixtures. 

TSL 5 represents all of the max tech 

efficiency levels, which would set 

energy conservation standards at EL4 for 

indoor and outdoor 70, 150, 250, and 

400 W fixtures, and EL2 for indoor and 

outdoor 1000 W fixtures. Standards 

included in TSL 5 require fixtures to 

contain the max tech electronic ballasts 

with high-grade electronic components 

for indoor and outdoor 70, 150, 250, and 

400 W fixtures. High-grade core steel 

and copper windings are typically used 

in the ballasts included in 1000 W 

fixtures. Commercially available ballasts 

meet TSL 5 for all equipment classes. 

TSL 5 would require high-frequency 

electronic ballasts for 400 W indoor and 

outdoor fixtures, which have limited 

compatibility with CMH technology. 

See section V.C.8 for additional 

detail.TSL 5 includes a design standard 

for indoor and outdoor 1000 W fixtures 

that prohibits the sale of probe-start 

ballasts in new fixtures. TSL 5 sets the 

same standards for indoor and outdoor 

representative equipment classes at the 

same wattage. 

DOE requests comment on these 

proposed trial standard levels. 

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Individual 

Customers 

a. Life-Cycle Cost and Payback Period 

Customers affected by new or 

amended standards usually experience 

higher purchase prices and lower 

operating costs. Generally, these effects 

on individual customers are best 

summarized by changes in LCCs and 

PBP. DOE calculated the LCC and PBP 

values for the potential standard levels 

considered in this rulemaking to 

provide key inputs for each TSL. These 

values are reported by equipment class 

in Table VI.2 through Table VI.13. Each 

table includes the average total LCC and 

the average LCC savings, as well as the 

fraction of equipment customers for 

which the LCC will either decrease (net 

benefit) or increase (net cost) relative to 

the baseline case. The last column in 

each table contains the median PBPs for 

the customer purchasing a design 

compliant with the TSL. 

The results for each TSL are presented 

relative to the energy use in the baseline 

case (no new or amended standards), 

based on energy consumption under 

conditions of actual equipment use. As 

discussed in section IV.D.2, the 

presumption PBP is based on test values 

under conditions prescribed by the DOE 

test procedures, as required by EPCA. 

(42 U.S.C. 6295(o)(2)(B)(iii)) 


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TABLE VI.2—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (INDOOR, MAGNETIC BASELINE): LCC AND

PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 537.80 1,379.32 1,917.12 .................... .................... .................... ....................

1 ......................................... 1 ............... 539.03 1,345.26 1,884.28 32.84 0.0 100.0 0.5 

2, 3, 4 ................................. 2 ............... 552.28 1,326.43 1,878.71 38.41 0.0 100.0 4.2 

3 ............... 555.25 1,379.56 1,934.80 ¥17.68 24 76 3.3 

5 ......................................... 4 ............... 568.68 1,374.61 1,943.29 ¥26.16 28 72 5.4 

TABLE VI.3 EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (INDOOR, ELECTRONIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

1, 2, 3, 4 ............................. Baseline/3 555.25 1,379.56 1,934.80 .................... .................... .................... ....................

5 ......................................... 4 568.68 1,374.61 1,943.29 ¥8.48 96 4 32.3 

TABLE VI.4—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR, MAGNETIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 527.98 1,844.61 2,372.59 .................... .................... .................... ....................

1 ......................................... 1 ............... 529.16 1,803.94 2,333.09 39.50 0.0 100.0 0.6 

2, 3 ..................................... 2 ............... 541.86 1,784.29 2,326.15 46.44 0.0 100.0 4.4 

4 ......................................... 3 ............... 580.46 1,722.54 2,303.00 69.59 42 58 12.8 

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 63.77 43 57 14.6 

TABLE VI.5—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR, ELECTRONIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

1, 2, 3, 4 ............................. Baseline/3 580.46 1,722.54 2,303.00 .................... .................... .................... ....................

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 ¥5.82 84 16 44.7 

TABLE VI.6—EQUIPMENT CLASS 2—150 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 657.04 2,110.32 2,767.36 .................... .................... .................... ....................

1 ......................................... 1 ............... 673.27 2,075.60 2,748.87 18.50 1 99 7.2 

2 ......................................... 2 ............... 681.07 2,046.61 2,727.68 39.68 0 100 5.8 

3 ............... 676.72 2,063.23 2,739.95 27.41 15 85 2.4 

3,4,5 ................................... 4 .............. 696.00 2,061.22 2,757.23 10.14 23 77 4.7 


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51518 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.7—EQUIPMENT CLASS 2—150 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 641.19 2,681.81 3,322.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 656.74 2,645.59 3,302.33 20.66 0 100 8.3 

2 ......................................... 2 ............... 664.20 2,614.09 3,278.30 44.70 0 100 6.6 

3 ............... 695.81 2,499.35 3,195.16 127.84 16 84 7.9 

3, 4, 5 ................................. 4 ............... 714.28 2,496.20 3,210.48 112.51 26 74 10.5 

TABLE VI.8—EQUIPMENT CLASS 3—250 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 710.86 2,485.37 3,196.24 .................... .................... .................... ....................

1 ......................................... 1 ............... 734.37 2,455.32 3,189.69 6.55 36 64 12.4 

2, 3, 4 ................................. 2 ............... 749.99 2,433.12 3,183.11 13.12 31 69 11.8 

3 ............... 790.69 2,485.61 3,276.30 ¥80.07 52 48 14.4 

5 ......................................... 4 ............... 783.45 2,472.23 3,255.68 ¥59.44 44 56 11.5 

TABLE VI.9—EQUIPMENT CLASS 3—250 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 690.34 3,132.65 3,822.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 712.86 3,103.40 3,816.26 6.73 20 80 14.8 

2, 3, 4 ................................. 2 ............... 727.82 3,081.42 3,809.24 13.75 15 85 14.0 

3 ............... 802.58 2,996.28 3,798.86 24.13 65 35 28.0 

5 ......................................... 4 ............... 795.64 2,981.26 3,776.91 46.08 54 46 21.4 

TABLE VI.10—EQUIPMENT CLASS 4—400 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 784.44 3,453.98 4,238.41 .................... .................... .................... ....................

1 ......................................... 1 ............... 823.04 3,406.28 4,229.31 9.10 40 60 12.8 

2, 3, 4 ................................. 2 ............... 841.82 3,368.36 4,210.18 28.23 18 82 10.5 

3 ............... 921.01 3,389.35 4,310.36 ¥71.95 49 51 13.8 

5 ......................................... 4 ............... 962.37 3,375.11 4,337.48 ¥99.07 61 39 16.2 

TABLE VI.11—EQUIPMENT CLASS 4—400 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 760.80 4,173.10 4,933.90 .................... .................... .................... ....................

1 ......................................... 1 ............... 797.78 4,126.96 4,924.74 9.16 22 78 15.4 

2, 3, 4 ................................. 2 ............... 815.77 4,087.66 4,903.43 30.47 7 93 12.3 

3 ............... 927.40 3,958.53 4,885.93 47.97 56 44 21.3 

5 ......................................... 4 ............... 967.02 3,940.38 4,907.40 26.49 63 37 24.4 


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TABLE VI.12—EQUIPMENT CLASS 5—1000 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 1,143.88 11,657.30 12,801.18 .................... .................... .................... ....................

1 ............... 1,185.86 11,619.06 12,804.91 ¥3.73 62 38 16.3 

1 ......................................... 1 + DS * ... 1,207.74 11,122.24 12,329.98 471.20 0.0 100.0 1.8 

2 ............... 1,199.97 11,570.62 12,770.60 30.58 12 88 9.7 

2, 3, 4, 5 ............................. 2 + DS* .... 1,221.85 11,077.12 12,298.97 502.21 0.0 100.0 2.0 

* DS = Design standard requiring that all fixtures sold shall not contain a probe-start ballast. 

TABLE VI.13—EQUIPMENT CLASS 5—1000 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Baseline ... 1,101.52 9,854.56 10,956.08 .................... .................... .................... ....................

1 ............... 1,141.74 9,823.86 10,965.59 ¥9.52 67 33 24.9 

1 ......................................... 1 + DS * ... 1,162.70 9,408.20 10,570.89 385.18 0.0 100.0 2.7 

2 ............... 1,155.26 9,783.72 10,938.98 17.10 18 82 14.5 

2, 3, 4, 5 ............................. 2 + DS * ... 1,176.22 9,370.84 10,547.05 409.02 0.0 100.0 3.0 

* DS = Design standard requiring that all fixtures sold shall not contain a probe-start ballast. 

b. Customer Subgroup Analysis 

Using the LCC spreadsheet model, 

DOE determined the effect of the trial 

standard levels on the following 

customer sub-groups: utilities, owners 

of transportation facilities, and 

warehouse owners. DOE adjusted 

particular inputs to the LCC model to 

reflect conditions faced by the identified 

subgroups. For utilities, DOE assumed 

that maintenance costs would be higher 

than average maintenance costs because 

utilities have to maintain more 

equipment than the other subgroups do. 

DOE assumed that owners of 

transportation facilities face higher 

annual operating hours than the average 

used in the main LCC analysis. For 

warehouse owners, DOE assumed lower 

annual operating hours than average 

used in the main LCC analysis. 

Table VI.14 through Table VI.25 show 

the LCC effects and PBPs for identified 

sub-groups that purchase metal halide 

lamp fixtures. In general, the average 

LCC savings for the identified subgroups 

at the considered efficiency levels are 

not significantly different from the 

average for all customers. 

TABLE VI.14—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (INDOOR, MAGNETIC BASELINE): LCC 

SUBGROUP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 650.30 1,632.71 2,283.01 .................... .................... .................... ....................

1 ......................................... 1 ............... 651.53 1,598.65 2,250.17 32.84 0.0 100.0 0.5 

2, 3, 4 ................................. 2 ............... 664.78 1,579.82 2,244.60 38.41 0.0 100.0 4.2 

3 ............... 667.75 1,663.46 2,331.20 ¥48.19 35 65 3.5 

5 ......................................... 4 ............... 681.18 1,658.51 2,339.68 ¥56.67 36 64 5.8 

Subgroup: Transportation Facility Owners 

Baseline ... 537.80 1,428.88 1,966.68 .................... .................... .................... ....................

1 ......................................... 1 ............... 539.03 1,392.23 1,931.26 35.41 0.0 100.0 0.5 

2, 3, 4 ................................. 2 ............... 552.28 1,371.90 1,924.18 42.49 0.0 100.0 3.9 

3 ............... 555.25 1,413.15 1,968.39 ¥1.72 26 74 3.0 

5 ......................................... 4 ............... 568.68 1,407.13 1,975.80 ¥9.13 29 71 5.0 

Subgroup: Warehouse Owners 

Baseline ... 537.80 1,372.08 1,909.88 .................... .................... .................... ....................

1 ......................................... 1 ............... 539.03 1,338.45 1,877.47 32.40 0.0 100.0 0.4 


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TABLE VI.14—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (INDOOR, MAGNETIC BASELINE): LCC 

SUBGROUP RESULTS—Continued 

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

2, 3, 4 ................................. 2 ............... 552.28 1,319.92 1,872.20 37.68 0.0 100.0 3.4 

3 ............... 555.25 1,373.94 1,929.19 ¥19.31 14 86 1.9 

5 ......................................... 4 ............... 568.68 1,369.17 1,937.85 ¥27.97 15 85 3.2 

TABLE VI.15—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (INDOOR, ELECTRONIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

1, 2, 3, 4 ............................. Baseline/3 667.75 1,663.46 2,331.20 .................... .................... .................... ....................

5 ......................................... 4 ............... 681.18 1,658.51 2,339.68 ¥8.48 96 4 32.4 

Subgroup: Transportation Facility Owners 

1, 2, 3, 4 ............................. Baseline/3 555.25 1,413.15 1,968.39 .................... .................... .................... ....................

5 ......................................... 4 ............... 568.68 1,407.13 1,975.80 ¥7.41 95 5 31.3 

Subgroup: Warehouse Owners 

1, 2, 3, 4 ............................. Baseline/3 555.25 1,373.94 1,929.19 .................... .................... .................... ....................

5 ......................................... 4 ............... 568.68 1,369.17 1,937.85 ¥8.66 98 2 21.9 

TABLE VI.16—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR, MAGNETIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 640.48 2,205.61 2,846.10 .................... .................... .................... ....................

1 ......................................... 1 ............... 641.66 2,164.94 2,806.60 39.50 0.0 100.0 0.6 

2, 3 ..................................... 2 ............... 654.36 2,145.30 2,799.66 46.44 0.0 100.0 4.4 

4 ......................................... 3 ............... 692.96 2,090.08 2,783.04 63.06 46 54 16.9 

5 ......................................... 4 ............... 705.83 2,083.03 2,788.86 57.23 48 52 18.7 

Sugroup: Transportation Facility Owners 

Baseline ... 527.98 1,844.61 2,372.59 .................... .................... .................... ....................

1 ......................................... 1 ............... 529.16 1,803.94 2,333.09 39.50 0.0 100.0 0.6 

2, 3 ..................................... 2 ............... 541.86 1,784.29 2,326.15 46.44 0.0 100.0 4.4 

4 ......................................... 3 ............... 580.46 1,722.54 2,303.00 69.59 46 54 16.9 

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 63.77 48 52 18.7 

Subgroup: Warehouse Owners 

Baseline ... 527.98 1,844.61 2,372.59 

1 ......................................... 1 ............... 529.16 1,803.94 2,333.09 39.50 0.0 100.0 0.6 

2, 3 ..................................... 2 ............... 541.86 1,784.29 2,326.15 46.44 0.0 100.0 4.4 

4 ......................................... 3 ............... 580.46 1,722.54 2,303.00 69.59 38 62 12.4 

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 63.77 41 59 14.2 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51521 

TABLE VI.17—EQUIPMENT CLASS 1—70 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR, ELECTRONIC BASELINE): LCC 

AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

1, 2, 3, 4 ............................. Baseline/3 692.96 2,090.08 2,783.04 .................... .................... .................... ....................

5 ......................................... 4 ............... 705.83 2,083.03 2,788.86 ¥5.82 85 15 44.3 

Subgroup: Transportation Facility Owners 

1, 2, 3, 4 ............................. Baseline/3 580.46 1,722.54 2,303.00 .................... .................... .................... ....................

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 ¥5.82 95 5 31.0 

Subgroup: Warehouse Owners 

1, 2, 3, 4 ............................. Baseline/3 580.46 1,722.54 2,303.00 .................... .................... .................... ....................

5 ......................................... 4 ............... 593.33 1,715.50 2,308.82 ¥5.82 85 15 44.3 

TABLE VI.18—EQUIPMENT CLASS 2—150 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 792.04 2,416.48 3,208.52 .................... .................... .................... ....................

1 ......................................... 1 ............... 808.27 2,381.76 3,190.03 18.50 1 99 7.2 

2 ......................................... 2 ............... 816.07 2,352.77 3,168.84 39.68 0 100 5.8 

3 ............... 811.72 2,404.29 3,216.01 ¥7.48 29 71 2.7 

3, 4, 5 ................................. 4 ............... 831.00 2,402.28 3,233.28 ¥24.76 34 66 5.2 

Subgroup: Transportation Facility Owners 

Baseline ... 657.04 2,225.70 2,882.74 .................... .................... .................... ....................

1 ......................................... 1 ............... 673.27 2,187.50 2,860.77 21.97 1 99 6.8 

2 ......................................... 2 ............... 681.07 2,155.69 2,836.76 45.98 0 100 5.4 

3 ............... 676.72 2,173.66 2,850.38 32.36 12 88 2.2 

3, 4, 5 ................................. 4 ............... 696.00 2,171.29 2,867.29 15.45 20 80 4.4 

Subgroup: Warehouse Owners 

Baseline ... 657.04 2,098.07 2,755.11 .................... .................... .................... ....................

1 ......................................... 1 ............... 673.27 2,063.78 2,737.05 18.06 0 100 5.8 

2 ......................................... 2 ............... 681.07 2,035.14 2,716.20 38.91 0 100 4.7 

3 ............... 676.72 2,053.01 2,729.73 25.37 8 92 1.3 

3, 4, 5 ................................. 4 ............... 696.00 2,051.17 2,747.17 7.93 12 88 2.6 

TABLE VI.19—EQUIPMENT CLASS 2—150 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 776.19 3,115.02 3,891.20 .................... .................... .................... ....................

1 ......................................... 1 ............... 791.74 3,078.80 3,870.54 20.66 0 100 8.3 

2 ......................................... 2 ............... 799.20 3,047.30 3,846.51 44.70 0 100 6.5 

3 ............... 830.81 2,940.40 3,771.21 120.00 33 67 9.2 

3, 4, 5 ................................. 4 ............... 849.28 2,937.25 3,786.53 104.67 38 62 12.2 


sroberts on DSK5SPTVN1PROD with PROPOSALS
51522 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.19—EQUIPMENT CLASS 2—150 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS— 

Continued 

Trial standard level Efficiency 

level 

Life-cycle cost 

2012$ 

Life-cycle cost savings 

Median 

payback 

period 

years Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Transportation Facility Owners 

Baseline ... 641.19 2,681.81 3,322.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 656.74 2,645.59 3,302.33 20.66 0 100 8.3 

2 ......................................... 2 ............... 664.20 2,614.09 3,278.30 44.70 0 100 6.5 

3 ............... 695.81 2,499.35 3,195.16 127.84 33 67 9.2 

3, 4, 5 ................................. 4 ............... 714.28 2,496.20 3,210.48 112.51 38 62 12.2 

Subgroup: Warehouse Owners 

Baseline ... 641.19 2,681.81 3,322.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 656.74 2,645.59 3,302.33 20.66 0 100 8.3 

2 ......................................... 2 ............... 664.20 2,614.09 3,278.30 44.70 0 100 6.5 

3 ............... 695.81 2,499.35 3,195.16 127.84 16 84 7.7 

3, 4, 5 ................................. 4 ............... 714.28 2,496.20 3,210.48 112.51 25 75 10.3 

TABLE VI.20—EQUIPMENT CLASS 3—250 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

ears 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 845.86 2,706.30 3,552.16 .................... .................... .................... ....................

1 ......................................... 1 ............... 869.37 2,676.24 3,545.61 6.55 36 64 12.4 

2, 3, 4 ................................. 2 ............... 884.99 2,654.05 3,539.04 13.12 30 70 11.9 

3 ............... 925.69 2,741.43 3,667.13 ¥114.96 57 43 16.9 

5 ......................................... 4 ............... 918.45 2,728.05 3,646.50 ¥94.34 49 51 13.0 

Subgroup: Transportation Facility Owners 

Baseline ... 710.86 2,918.78 3,629.64 .................... .................... .................... ....................

1 ......................................... 1 ............... 734.37 2,885.59 3,619.96 9.69 29 71 11.8 

2, 3, 4 ................................. 2 ............... 749.99 2,861.10 3,611.09 18.56 24 76 11.2 

3 ............... 790.69 2,918.08 3,708.78 ¥79.13 50 50 14.3 

5 ......................................... 4 ............... 783.45 2,903.52 3,686.97 ¥57.32 43 57 11.1 

Subgroup: Warehouse Owners 

Baseline ... 710.86 2,466.57 3,177.44 .................... .................... .................... ....................

1 ......................................... 1 ............... 734.37 2,436.94 3,171.31 6.13 17 83 10.1 

2, 3, 4 ................................. 2 ............... 749.99 2,415.04 3,165.03 12.40 15 85 9.6 

3 ............... 790.69 2,468.82 3,259.52 ¥82.08 26 74 6.7 

5 ......................................... 4 ............... 783.45 2,455.53 3,238.98 ¥61.54 22 78 5.6 

TABLE VI.21—EQUIPMENT CLASS 3—250 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 825.34 3,472.93 4,298.27 .................... .................... .................... ....................

1 ......................................... 1 ............... 847.86 3,443.68 4,291.54 6.73 20 80 14.8 

2, 3, 4 ................................. 2 ............... 862.82 3,421.70 4,284.52 13.75 16 84 14.1 

3 ............... 937.58 3,344.40 4,281.98 16.29 72 28 39.8 

5 ......................................... 4 ............... 930.64 3,329.38 4,260.03 38.25 61 39 28.2 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51523 

TABLE VI.21—EQUIPMENT CLASS 3—250 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS— 

Continued 

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Transportation Facility Owners 

Baseline ... 690.34 3,132.65 3,822.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 712.86 3,103.40 3,816.26 6.73 20 80 14.8 

2, 3, 4 ................................. 2 ............... 727.82 3,081.42 3,809.24 13.75 16 84 14.1 

3 ............... 802.58 2,996.28 3,798.86 24.13 72 28 39.8 

5 ......................................... 4 ............... 795.64 2,981.26 3,776.91 46.08 61 39 28.2 

Subgroup: Warehouse Owners 

Baseline ... 690.34 3,132.65 3,822.99 .................... .................... .................... ....................

1 ......................................... 1 ............... 712.86 3,103.40 3,816.26 6.73 20 80 14.8 

2, 3, 4 ................................. 2 ............... 727.82 3,081.42 3,809.24 13.75 16 84 14.1 

3 ............... 802.58 2,996.28 3,798.86 24.13 64 36 27.1 

5 ......................................... 4 ............... 795.64 2,981.26 3,776.91 46.08 54 46 20.7 

TABLE VI.22—EQUIPMENT CLASS 4—400 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 934.44 3,649.31 4,583.74 .................... .................... .................... ....................

1 ......................................... 1 ............... 973.04 3,601.60 4,574.64 9.10 40 60 12.9 

2, 3, 4 ................................. 2 ............... 991.82 3,563.69 4,555.51 28.23 18 82 10.5 

3 ............... 1,071.01 3,623.45 4,694.47 ¥110.72 56 44 15.5 

5 ......................................... 4 ............... 1,112.37 3,609.21 4,721.58 ¥137.84 66 34 18.2 

Subgroup: Transportation Facility Owners 

Baseline ... 784.44 3,880.58 4,665.01 .................... .................... .................... ....................

1 ......................................... 1 ............... 823.04 3,827.87 4,650.91 14.10 34 66 12.2 

2, 3, 4 ................................. 2 ............... 841.82 3,786.15 4,627.97 37.04 14 86 10.0 

3 ............... 921.01 3,808.34 4,729.36 ¥64.34 48 52 13.4 

5 ......................................... 4 ............... 962.37 3,792.38 4,754.75 ¥89.74 58 42 15.9 

Subgroup: Warehouse Owners 

Baseline ... 784.44 3,423.90 4,208.33 .................... .................... .................... ....................

1 ......................................... 1 ............... 823.04 3,376.86 4,199.90 8.43 20 80 10.4 

2, 3, 4 ................................. 2 ............... 841.82 3,339.44 4,181.25 27.08 9 91 8.5 

3 ............... 921.01 3,362.34 4,283.36 ¥75.02 25 75 7.5 

5 ......................................... 4 ............... 962.37 3,348.56 4,310.93 ¥102.59 30 70 8.9 

TABLE VI.23—EQUIPMENT CLASS 4—400 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 910.80 4,462.71 5,373.51 .................... .................... .................... ....................

1 ......................................... 1 ............... 947.78 4,416.57 5,364.35 9.16 23 77 15.4 

2, 3, 4 ................................. 2 ............... 965.77 4,377.27 5,343.04 30.47 7 93 12.4 

3 ............... 1,077.40 4,256.85 5,334.25 39.26 61 39 24.5 

5 ......................................... 4 ............... 1,117.02 4,238.70 5,355.73 17.79 68 32 27.7 


sroberts on DSK5SPTVN1PROD with PROPOSALS
51524 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.23—EQUIPMENT CLASS 4—400 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS— 

Continued 

Trial standard level Efficiency 

level 

Life-cycle cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Transportation Facility Owners 

Baseline ... 760.80 4,173.10 4,933.90 .................... .................... .................... ....................

1 ......................................... 1 ............... 797.78 4,126.96 4,924.74 9.16 23 77 15.4 

2, 3, 4 ................................. 2 ............... 815.77 4,087.66 4,903.43 30.47 7 93 12.4 

3 ............... 927.40 3,958.53 4,885.93 47.97 61 39 24.5 

5 ......................................... 4 ............... 967.02 3,940.38 4,907.40 26.49 68 32 27.7 

Subgroup: Warehouse Owners 

Baseline ... 760.80 4,173.10 4,933.90 .................... .................... .................... ....................

1 ......................................... 1 ............... 797.78 4,126.96 4,924.74 9.16 23 77 15.4 

2, 3, 4 ................................. 2 ............... 815.77 4,087.66 4,903.43 30.47 7 93 12.4 

3 ............... 927.40 3,958.53 4,885.93 47.97 55 45 21.0 

5 ......................................... 4 ............... 967.02 3,940.38 4,907.40 26.49 62 38 24.1 

TABLE VI.24—EQUIPMENT CLASS 5—1000 WATT METAL HALIDE LAMP FIXTURES (INDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-Cycle Cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 1,353.88 12,420.47 13,774.35 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,417.74 11,885.42 13,303.15 471.20 0.0 100.0 1.8 

2, 3, 4, 5 ............................. 2 + DS* .... 1,431.85 11,840.29 13,272.15 502.21 0.0 100.0 2.0 

Subgroup: Transportation Facility Owners 

Baseline ... 1,143.88 13,479.99 14,623.87 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,207.74 12,835.48 14,043.22 580.65 0.0 100.0 1.5 

2, 3, 4, 5 ............................. 2 + DS* .... 1,221.85 12,780.37 14,002.23 621.64 0.0 100.0 1.7 

Subgroup: Warehouse Owners 

Baseline ... 1,143.88 11,657.30 12,801.18 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,207.74 11,122.24 12,329.98 471.20 0.0 100.0 1.4 

2, 3, 4, 5 ............................. 2 + DS* .... 1,221.85 11,077.12 12,298.97 502.21 0.0 100.0 1.6 

* DS = Design standard requiring all fixtures sold shall not contain a probe-start ballast. 

TABLE VI.25—EQUIPMENT CLASS 5—1000 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS

Trial standard level Efficiency 

level 

Life-Cycle Cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Utilities 

Baseline ... 1,311.52 10,528.44 11,839.96 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,372.70 10,082.08 11,454.77 385.18 0.0 100.0 2.6 

2, 3, 4, 5 ............................. 2 + DS* .... 1,386.22 10,044.72 11,430.93 409.02 0.0 100.0 3.0 

Subgroup: Transportation Facility Owners 

Baseline ... 1,101.52 9,854.56 10,956.08 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,162.70 9,408.20 10,570.89 385.18 0.0 100.0 2.6 

2, 3, 4, 5 ............................. 2 + DS* .... 1,176.22 9,370.84 10,547.05 409.02 0.0 100.0 3.0 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51525 

TABLE VI.25—EQUIPMENT CLASS 5—1000 WATT METAL HALIDE LAMP FIXTURES (OUTDOOR): LCC AND PBP RESULTS— 

Continued 

Trial standard level Efficiency 

level 

Life-Cycle Cost 2012$ Life-cycle cost savings 

Median 

payback 

period 

years 

Installed 

cost 

Discounted 

operating 

cost 

LCC 

Average 

savings 

2012$ 

Percent of customers that 

experience 

Net cost Net benefit 

Subgroup: Warehouse Owners 

Baseline ... 1,101.52 9,854.56 10,956.08 .................... .................... .................... ....................

1 ......................................... 1 + DS* .... 1,162.70 9,408.20 10,570.89 385.18 0.0 100.0 2.6 

2, 3, 4, 5 ............................. 2 + DS* .... 1,176.22 9,370.84 10,547.05 409.02 0.0 100.0 3.0 

* DS = Design standard requiring that all fixtures sold shall not contain a probe-start ballast. 

Rebuttable Presumption Payback 

As discussed in section IV.D.2, EPCA 

provides a rebuttable presumption that 

an energy conservation standard is 

economically justified if the increased 

purchase cost for equipment that meets 

the standard is less than three times the 

value of the first-year energy savings 

resulting from the standard. DOE’s LCC 

and PBP analysis generates values for 

calculating the PBP for customers 

affected by potential energy 

conservation standards. This includes 

the 3-year PBP contemplated under the 

rebuttable presumption test discussed in 

section IV.D.2. DOE, however, routinely 

conducts an economic analysis that 

considers the full range of impacts— 

including those on consumers, 

manufacturers, the nation, and the 

environment—as required under 42 

U.S.C. 6295(o)(2)(B)(i). 

For this proposed rule, DOE 

calculated a rebuttable presumption 

PBP for each TSL. DOE used discrete 

values rather than distributions for 

inputs and, as required by EPCA, based 

the calculations on using the applicable 

DOE test procedures for metal halide 

lamp fixtures. DOE then calculated a 

single rebuttable presumption payback 

value, rather than a distribution of PBPs, 

for each TSL. Table VI.26 shows the 

rebuttable presumption PBPs that are 

less than 3 years. 

While DOE examined the rebuttablepresumption criterion, it also conducted 

a more detailed analysis of the 

economic impacts of these levels to 

determine whether the proposed 

standard levels are economically 

justified pursuant to 42 U.S.C. 

6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE to 

evaluate the economic justification for a 

potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). 

TABLE VI.26—FIXTURE EFFICIENCY LEVELS WITH A REBUTTABLE PAYBACK PERIOD OF LESS THAN THREE YEARS

Equipment class Efficiency level 

Median 

payback 

period 

years 

70 W (indoor, magnetic baseline) .................................................................................................................. 1 ....................... 0.5 

70 W (outdoor, magnetic baseline) ................................................................................................................ 1 ....................... 0.5 

1000 W (indoor) .............................................................................................................................................. 1 + DS* ............. 1.7 

2 + DS* ............. 1.9 

1000 W (outdoor) ............................................................................................................................................ 1 + DS* ............. 2.4 

2 + DS* ............. 2.7 

* DS = Design standard requiring that all fixtures shall not contain a probe-start ballast. 

2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate 

the impact of new and amended energy 

conservation standards on 

manufacturers of metal halide lamp 

fixtures and metal halide ballasts. The 

section below describes the expected 

impacts on manufacturers at each TSL. 

Chapter 13 of the NOPR TSD explains 

the analysis in further detail. 

a. Industry Cash-Flow Analysis Results 

The tables below depict the financial 

impacts (represented by changes in 

INPV) of new and amended energy 

standards on manufacturers as well as 

the conversion costs that DOE estimates 

manufacturers would incur at each TSL. 

DOE breaks out the impacts on 

manufacturers of ballasts and fixtures 

separately. Within each industry, DOE 

presents the results for all equipment 

classes in one group because most 

equipment classes are generally made 

by the same manufacturers. To evaluate 

the range of cash flow impacts on the 

ballast and fixture industries, DOE 

modeled four different scenarios using 

different assumptions for markups and 

shipments that correspond to the range 

of anticipated market responses to new 

and amended standards. Each scenario 

results in a unique set of cash flows and 

corresponding industry values at each 

TSL. 

Two of these market response 

scenarios are presented below, 

corresponding to the outer bounds of a 

range of market responses that DOE 

anticipates could occur in the standards 

case. In the following discussion, the 

INPV results refer to the difference in 

industry value between the base case 

and the standards case that result from 

the sum of discounted cash flows from 

the base year (2013) through the end of 

the analysis period. The results also 

discuss the difference in cash flow 

between the base case and the standards 

case in 2015. This figure represents the 

size of the required conversion costs 

relative to the cash flow generated by 

the industry in the absence of new and 

amended energy conservation 

standards. 


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Cash-Flow Analysis Results by TSL for 

Metal Halide Ballasts 

To assess the upper (less severe) end 

of the range of potential impacts on 

metal halide ballast manufacturers, DOE 

modeled a flat markup scenario. The flat 

markup scenario assumes that in the 

standards case, manufacturers would be 

able to pass along all the higher 

production costs required for more 

efficient products to their customers. 

Specifically, the industry would be able 

to maintain its average base case gross 

margin, as a percentage of revenue, 

despite the higher product costs in the 

standards case. In general, the larger the 

product price increases, the less likely 

manufacturers are to achieve the cash 

flow from operations calculated in this 

scenario because it is less likely that 

manufacturers would be able to fully 

markup these larger cost increases. 

DOE also used the high-shipment 

scenario to assess the upper bound of 

impacts. Under the high-shipment 

scenario, base case shipments of metal 

halide lamp fixtures decrease at a 

slower rate over the analysis period 

compared to the low-shipment scenario. 

Of all the scenario combinations 

analyzed in the MIA, the flat markup 

and high-shipment scenario provides 

the best conditions for cash flow 

generation—the annual shipment 

volume and the ability to preserve gross 

margins are greatest. Thus, this scenario 

set yields the greatest modeled industry 

profitability. 

To assess the lower (more severe) end 

of the range of potential impacts on the 

metal halide ballast industry, DOE 

modeled the ‘preservation of operating 

profit’ markup scenario. The scenario 

represents the lower end of the range of 

potential impacts on manufacturers 

because no additional operating profit is 

earned on the higher production costs, 

eroding profit margins as a percentage of 

total revenue. 

DOE also used the low-shipment 

scenario to assess the lower bound of 

impacts. Under the low-shipment 

scenario, metal halide lamp fixture 

shipments decrease at a faster rate over 

the analysis period compared to the 

high-shipment scenario. Of all the 

scenarios analyzed in the MIA, this 

combination of scenarios (‘preservation 

of operating profit’ markup and lowshipment) most restricts manufacturers’ 

ability to pass on costs to customers and 

assumes the lowest level of shipments. 

Thus, this scenario set estimates the 

largest manufacturer impacts. 

TABLE VI.27—MANUFACTURER IMPACT ANALYSIS FOR METAL HALIDE BALLASTS—FLAT MARKUP AND HIGH-SHIPMENT

SCENARIO

Units Base 

case 

Trial standard level 

1 2 3 4 5 

INPV .......................................... (2012$ millions) ........................ 123 123 126 127 127 159 

Change in INPV ........................ (2012$ millions) ........................ ................ 0.8 3 .3 4 .5 4 .7 36 .5 

(%) ............................................ ................ 0.7% 2 .7 3 .7 3 .8 29 .8 

Product Conversion Costs ........ (2012$ millions) ........................ ................ 9 12 13 14 20 

Capital Conversion Costs ......... (2012$ millions) ........................ ................ 10 17 16 14 7 

Total Conversion Costs ..... (2012$ millions) ........................ ................ 19 30 29 28 26 

TABLE VI.28—MANUFACTURER IMPACT ANALYSIS FOR METAL HALIDE BALLASTS—PRESERVATION OF OPERATING PROFIT

MARKUP AND LOW-SHIPMENT SCENARIO

Units Base 

case 

Trial standard level 

1 2 3 4 5 

INPV ............................................. (2012$ millions) ............................ 103 86 77 77 79 79 

Change in INPV ............................ (2012$ millions) ............................ ................ (17.1) (26.8) (25.9) (24.8) (24.1) 

(%) ................................................ ................ ¥16.6% ¥25.9 ¥25.0 ¥24.0 ¥23.3 

Product Conversion Costs ............ (2012$ millions) ............................ ................ 9 12 13 14 20 

Capital Conversion Costs ............. (2012$ millions) ............................ ................ 10 17 16 14 7 

Total Conversion Costs ......... (2012$ millions) ............................ ................ 19 30 29 28 26 

TSL 1 is EL1 for all ten equipment 

classes (the 70 W indoor and outdoor, 

150 W indoor and outdoor, 250 W 

indoor and outdoor, 400 W indoor and 

outdoor, and 1000 W indoor and 

outdoor fixtures). At TSL 1, DOE 

estimates impacts on INPV range from 

$0.8 million to ¥$17.1 million, or a 

change in INPV of 0.7 percent to ¥16.6 

percent. At TSL 1, industry free cash 

flow (operating cash flow minus capital 

expenditures) under the low-shipment 

scenario is estimated to decrease by 

approximately 68 percent to $3.4 

million, compared to the base case value 

of $10.7 million in 2015. Under the 

high-shipment scenario, industry free 

cash flow is estimated to decrease by 

approximately 69 percent to $3.3 

million, compared to the base case value 

of $10.6 million in 2015. 

Impacts on INPV are slightly positive 

to moderately negative at TSL 1. TSL 1 

requires the use of more efficient 

magnetic ballasts for the 70 W indoor 

and outdoor, 150 W indoor and outdoor, 

250 W indoor and outdoor, 400 W 

indoor and outdoor, and 1000 W indoor 

and outdoor equipment classes. DOE 

projects that in 2016 100 percent of 70 

W indoor shipments, 5 percent of 150 W 

indoor shipments, 14 percent of 250 W 

indoor shipments, 23 percent of 400 W 

indoor shipments, 10 percent of 1000 W 

indoor shipments, 30 percent of 70 W 

outdoor shipments, zero percent of 150 

W outdoor shipments, 10 percent of 250 

W outdoor shipments, 10 percent of 400 

W outdoor, and 6 percent of 1000 W 

outdoor shipments would meet TSL 1 or 

higher in the base case. 

Conversion costs are expected to be 

moderate at TSL 1. DOE expects ballast 

manufacturers to incur $9 million in 

product conversion costs for model 

redesigns and testing and $10 million in 

capital conversion costs for equipment 


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such as stamping dies to process more 

efficient steel cores. 

At TSL 1, under the flat markup 

scenario the shipment-weighted average 

MPC increases by 25 percent relative to 

the base case MPC. Manufacturers are 

able to fully pass on this cost increase 

to customers under this scenario. 

Additionally, under the high-shipment 

scenario, shipments are 191 percent 

higher than shipments under the lowshipment scenario in the last year of the 

analysis period. Thus, manufacturers 

generate the most revenue under this 

combination (flat markup and highshipment) of scenarios. The moderate 

price increase applied to a large 

quantity of shipments mitigates the 

impact of the $19 million in conversion 

costs estimated at TSL 1, resulting in 

slightly positive impacts at TSL 1 under 

the flat markup and high-shipment 

scenarios. 

Under the ‘preservation of operating 

profit’ markup scenario, manufacturers 

earn the same operating profit as would 

be earned in the base case in 2017, but 

manufacturers do not earn additional 

profit from their investments. The 22 

percent MPC increase is outweighed by 

a lower average markup of 1.44 in the 

‘preservation of operating profit’ 

markup scenario (compared to the flat 

markup scenario markup of 1.47) and 

$19 million in conversion costs, 

resulting in greater negative impacts at 

TSL 1 under this scenario. On a 

percentage basis, the low-shipment 

scenario exacerbates these impacts 

relative to the high-shipment scenario 

because the base case INPV against 

which the absolute change in INPV is 

compared is 16 percent lower in the low 

shipment scenario compared to the high 

shipment scenario. 

TSL 2 is EL2 for all ten equipment 

classes (the 70 W indoor and outdoor, 

150 W indoor and outdoor, 250 W 

indoor and outdoor, 400 W indoor and 

outdoor, and 1000 W indoor and 

outdoor fixtures). At TSL 2, DOE 

estimates impacts on INPV to range 

from $3.3 million to ¥$26.8 million, or 

a change in INPV of 2.7 percent to 

¥25.9 percent. At this proposed level, 

industry free cash flow under the lowshipment scenario is estimated to 

decrease by approximately 106 percent 

to ¥$0.7 million, compared to the base 

case value of $10.7 million in 2015. 

Under the high-shipment scenario, 

industry free cash flow is estimated to 

decrease by approximately 108 percent 

to ¥$0.8 million, compared to the base 

case value of $10.6 million in 2015. 

TSL 2 is the highest efficiency level 

the engineering analysis assumes 

manufacturers can meet with magnetic 

ballasts for all equipment classes. DOE 

projects that in 2016, 100 percent of 70 

W indoor shipments, 5 percent of 150 W 

indoor shipments, 10 percent of 250 W 

indoor, 15 percent of 400 W indoor, 5 

percent of 1000 W indoor shipments, 

and 3 percent of 1000 W outdoor 

shipments would meet TSL 2 or higher 

in the base case. No shipments from the 

70 W outdoor, 150 W outdoor, 250 W 

outdoor, and 400 W outdoor equipment 

classes would meet TSL 2 or higher in 

the base case. At TSL 2, product 

conversion costs rise to $12 million and 

capital conversion costs rise to $17 

million as manufacturers need to 

purchase additional equipment and 

tooling to upgrade magnetic production 

lines. 

At TSL 2, under the flat markup 

scenario the shipment-weighted average 

MPC increases 40 percent over the base 

case MPC. In this scenario INPV impacts 

are slightly positive because 

manufacturers’ ability to pass on the 

higher equipment costs to customers 

outweighs the $30 million in conversion 

costs. Under the ‘preservation of 

operating profit’ markup scenario, the 

35 percent MPC increase is outweighed 

by a lower average markup of 1.42 and 

$30 million in conversion costs, 

resulting in moderately negative INPV 

impacts at TSL 2. 

TSL 3 includes, for the first time, EL4 

for two equipment classes (the 150 W 

indoor and outdoor fixtures) and EL2 for 

the other eight equipment classes (the 

70 W indoor and outdoor, 250 W indoor 

and outdoor, 400 W indoor and outdoor, 

and 1000 W indoor and outdoor 

fixtures). At TSL 3, DOE estimates 

impacts on INPV to range from $4.5 

million to ¥$25.9 million, or a change 

in INPV of 3.7 percent to ¥25.0 percent. 

At this proposed level, industry free 

cash flow under the low-shipment 

scenario is estimated to decrease by 

approximately 102 percent to ¥$0.2 

million, compared to the base case value 

of $10.7 million in 2015. Under the 

high-shipment scenario, industry free 

cash flow is estimated to decrease by 

approximately 104 percent to ¥$0.4 

million, compared to the base case value 

of $10.6 million in 2015. 

The technology changes from TSL 2 to 

TSL 3 are that manufacturers must use 

max tech level electronic ballasts for the 

150 W indoor and outdoor equipment 

classes at TSL 3. This has a negligible 

effect on total conversion costs, which 

slightly decreases to $29 million. DOE 

projects that no 150 W indoor or 

outdoor shipments would meet TSL 3 or 

higher in 2016 in the base case. DOE 

expects product conversion costs to 

increase slightly to $13 million and 

capital conversion costs to decrease 

slightly to $16 million. 

At TSL 3, under the flat markup 

scenario the shipment-weighted average 

MPC increases 40 percent over the base 

case MPC. In this scenario the 

additional revenues earned from passing 

on these higher MPC costs outweigh the 

$29 million in conversion costs and 

higher working capital requirements, 

resulting in slightly positive INPV 

impacts. Under the ‘preservation of 

operating profit’ markup scenario, the 

35 percent MPC increase is outweighed 

by a lower average markup of 1.42 and 

$29 million in conversion costs, 

resulting in INPV results remaining 

moderately negative at TSL 3. 

TSL 4 is EL4 for two equipment 

classes (the 150 W indoor and outdoor 

fixtures), EL3 for one equipment class 

(the 70 W outdoor fixtures), and EL2 for 

the remaining seven equipment classes 

(the 70 W indoor fixtures, 250 W indoor 

and outdoor fixtures, 400 W indoor and 

outdoor fixtures, and 1000 W indoor 

and outdoor fixtures). At TSL 4, DOE 

estimates impacts on INPV to range 

from $4.7 million to ¥$24.8 million, or 

a change in INPV of 3.8 percent to 

¥24.0 percent. At this proposed level, 

industry free cash flow under the lowshipment scenario is estimated to 

decrease by approximately 97 percent to 

$0.3 million, compared to the base case 

value of $10.7 million in 2015. Under 

the high-shipment scenario, industry 

free cash flow is estimated to decrease 

by approximately 98 percent to $0.2 

million, compared to the base case value 

of $10.6 million in 2015. 

The technology changes from TSL 3 to 

TSL 4 are that manufacturers must use 

electronic ballasts for the 70 W outdoor 

equipment class at TSL 4. DOE projects 

that no 70 W outdoor shipments would 

meet TSL 4 or higher in 2016 in the base 

case. Total conversion costs decrease 

from $29 million at TSL 3 to $28 million 

at TSL 4, because of the flexibility of 

electronic ballast production within the 

lighting manufacturing industry. 

At TSL 4, under the flat markup 

scenario the shipment-weighted average 

MPC increases 39 percent over the base 

case MPC. In this scenario the 

additional revenues earned from passing 

on these higher MPC costs outweigh the 

$28 million in conversion costs, 

resulting in slightly positive impacts on 

INPV. Under the ‘preservation of 

operating profit’ markup scenario, the 

34 percent MPC increase is outweighed 

by a lower average markup of 1.42 and 

$28 million in conversion costs, 

resulting in INPV results remaining 

moderately negative at TSL 4. 

TSL 5 is EL4 for eight equipment 

classes (the 70 W indoor and outdoor 

fixtures, 150 W indoor and outdoor 

fixtures, 250 W indoor and outdoor 


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fixtures, and 400 W indoor and outdoor 

fixtures) and EL2 for two equipment 

classes (the 1000 W indoor and outdoor 

fixtures). At TSL 5, DOE estimates 

impacts on INPV to range from $36.5 

million to ¥$24.1 million, or a change 

in INPV of 29.8 percent to ¥23.3 

percent. At this proposed level, industry 

free cash flow under the low-shipment 

scenario is estimated to decrease by 

approximately 83 percent to $1.8 

million, compared to the base case value 

of $10.7 million in 2015. Under the 

high-shipment scenario, industry free 

cash flow is estimated to decrease by 

approximately 84 percent to $1.7 

million, compared to the base case value 

of $10.6 million in 2015. 

At TSL 5, the stringency of standards 

increases to max tech ballasts for the 70 

W indoor and outdoor, 250 W indoor 

and outdoor, and 400 W outdoor 

equipment classes compared to TSL 4. 

DOE projects that 1 percent of 70 W 

indoor shipments would meet TSL 5 or 

higher in 2016 in the base case. No 

shipments from the 70 W outdoor, 250 

W indoor or outdoor, and 400 W indoor 

or outdoor equipment classes would 

meet TSL 5 or higher in the base case. 

As a result, product conversion costs 

increase to $20 million because of the 

need to redesign and test additional 

models, and capital conversion costs 

decrease to $7 million due to the 

flexibility of electronic ballast 

production. 

At TSL 5, under the flat markup 

scenario the shipment-weighted average 

MPC increases 76 percent over the base 

case MPC. In this scenario the 

additional revenues earned from passing 

on these higher MPC costs outweigh the 

decreased conversion costs of $26 

million, resulting in a significantly 

positive impact on INPV. Under the 

‘preservation of operating profit’ 

markup scenario, the 67 percent MPC 

increase is outweighed by a lower 

average markup of 1.39 and $26 million 

in conversion costs, resulting in INPV 

results remaining moderately negative at 

TSL 5. 

Cash Flow Analysis Results by TSL for 

Metal Halide Lamp Fixtures 

DOE incorporated the same scenarios 

to represent the upper and lower 

bounds of industry impacts for metal 

halide lamp fixtures as for metal halide 

ballasts: The flat markup scenario with 

the high-shipment scenario and the 

‘preservation of operating profit’ 

markup scenario with the low-shipment 

scenario. Note that the TSLs below 

represent the same sets of efficiency 

levels as discussed above in the 

description of impacts on ballast 

manufacturers. 

TABLE VI.29—MANUFACTURER IMPACT ANALYSIS FOR METAL HALIDE LAMP FIXTURES—FLAT MARKUP AND HIGHSHIPMENT SCENARIO

Units Base 

case 

Trial standard level 

1 2 3 4 5 

INPV .......................................... (2012$ millions) ........................ 630 667 694 695 703 741 

Change in INPV ........................ (2012$ millions) ........................ ................ 37.0 63 .9 64 .8 73 .6 111 .3 

(%) ................................................... 5.9% 10.2 10 .3 11 .7 17 .7 

Product Conversion Costs ........ (2012$ millions) ........................ ................ 3 3 9 13 62 

Capital Conversion Costs ......... (2012$ millions) ........................ ................ 0 0 6 10 75 

Total Conversion Costs ..... (2012$ millions) ........................ ................ 3 3 15 23 137 

TABLE VI.30—MANUFACTURER IMPACT ANALYSIS FOR METAL HALIDE LAMP FIXTURES—PRESERVATION OF OPERATING

PROFIT MARKUP AND LOW-SHIPMENT SCENARIO

Units Base 

case 

Trial standard level 

1 2 3 4 5 

INPV ............................................. (2012$ millions) ............................ 540 534 532 523 516 423 

Change in INPV ............................ (2012$ millions) ............................ ................ (6.1) (8.1) (17.3) (23.8) (116.9) 

(%) ....................................................... ¥1.1% ¥1.5 ¥3.2 ¥4.4 ¥21.6 

Product Conversion Costs ............ (2012$ millions) ............................ ................ 3 3 9 13 62 

Capital Conversion Costs ............. (2012$ millions) ............................ ................ 0 0 6 10 75 

Total Conversion Costs ......... (2012$ millions) ............................ ................ 3 3 15 23 137 

At TSL 1, DOE estimates impacts on 

INPV to range from $37.0 million to 

¥$6.1 million, or a change in INPV of 

5.9 percent to -1.1 percent. At TSL 1, 

industry free cash flow under the lowshipment scenario is estimated to 

decrease by approximately 2 percent to 

$58.7 million, compared to the base case 

value of $59.8 million in 2015. Under 

the high-shipment scenario, industry 

free cash flow is estimated to decrease 

by approximately 2 percent to $58.0 

million, compared to the base case value 

of $59.1 million in 2015. 

DOE expects minimal conversion 

costs for fixture manufacturers at TSL 1. 

Fixture manufacturers would incur $3 

million in product conversion costs for 

the testing of redesigned ballasts. 

Because the stack height of magnetic 

ballasts is not expected to change in 

response to the standards, fixture 

manufacturers would not incur any 

capital conversion costs at magnetic 

ballast levels such as TSL 1. 

At TSL 1, under the flat markup 

scenario the shipment-weighted average 

MPC increases by 12 percent from the 

base case MPC. In this scenario 

manufacturers maximize revenue since 

they are able to fully pass on this cost 

increase to customers. The moderate 

price increase applied to a large 

quantity of shipments outweighs the 

impact of the $3 million in conversion 

costs for TSL 1, resulting in positive 

impacts at TSL 1 under the flat markup 

and high-shipment scenarios. 

Under the ‘preservation of operating 

profit’ markup scenario, the 10 percent 

MPC increase is outweighed by a lower 

average markup of 1.56 (compared to 

the flat manufacturer markup of 1.58) 

and $3 million in conversion costs, 


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resulting in slightly negative impacts at 

TSL 1. These impacts increase on a 

percentage basis under the lowshipment scenario relative to the highshipment scenario because the base case 

INPV against which changes are 

compared is 14 percent lower. 

At TSL 2, DOE estimates impacts on 

INPV to range from $63.9 million to 

¥$8.1 million, or a change in INPV of 

10.2 percent to ¥1.5 percent. At this 

proposed level, industry free cash flow 

under the low-shipment scenario is 

estimated to decrease by approximately 

2 percent to $58.7 million, compared to 

the base case value of $59.8 million in 

2015. Under the high-shipment 

scenario, industry free cash flow is 

estimated to decrease by approximately 

2 percent to $58.0 million, compared to 

the base case value of $59.1 million in 

2015. 

At TSL 2, DOE expects conversion 

costs to remain low at $3 million for the 

testing of redesigned ballasts and 

catalog updates. Under the flat markup 

scenario the shipment-weighted average 

MPC increases 19 percent over the base 

case MPC. In this scenario the INPV 

impacts are positive because the ability 

to pass on the higher equipment costs to 

customers outweighs the $3 million in 

estimated conversion costs. Under the 

‘preservation of operating profit’ 

markup scenario, the 15 percent MPC 

increase is outweighed by a lower 

average markup of 1.53 and $3 million 

in conversion costs, resulting in slightly 

negative INPV impacts at TSL 2. 

At TSL 3, DOE estimates impacts on 

INPV to range from $64.8 million to 

¥$17.3 million, or a change in INPV of 

10.3 percent to ¥3.2 percent. At this 

proposed level, industry free cash flow 

under the low-shipment scenario is 

estimated to decrease by approximately 

9 percent to $54.2 million, compared to 

the base case value of $59.8 million in 

2015. Under the high-shipment 

scenario, industry free cash flow is 

estimated to decrease by approximately 

9 percent to $53.5 million, compared to 

the base case value of $59.1 million in 

2015. DOE expects product conversion 

costs to increase to $9 million because 

of the additional cost of redesigning 

fixtures for thermal protection to 

accommodate 150 W indoor and 

outdoor electronic ballasts. 

Manufacturers would also incur an 

estimated $6 million in capital costs for 

150 W indoor fixture changes. 

At TSL 3, the electronic fixture cost 

increases for the 150 W indoor and 

outdoor equipment classes because of 

fixture adders for thermal protection 

and voltage transient protection. Under 

the flat markup scenario, the shipmentweighted average MPC increases 21 

percent over the base case MPC. This 

increase in revenue outweighs the 

increase of $15 million in conversion 

costs, resulting in positive impacts at 

TSL 3. Under the ‘preservation of 

operating profit’ markup scenario, the 

17 percent MPC increase is outweighed 

by a lower average markup of 1.53 and 

$15 million in conversion costs, 

resulting in slightly negative INPV 

impacts at TSL 3. 

At TSL 4, DOE estimates impacts on 

INPV to range from $73.6 million to 

¥$23.8 million, or a change in INPV of 

11.7 percent to ¥4.4 percent. At this 

proposed level, industry free cash flow 

under the low-shipment scenario is 

estimated to decrease by approximately 

14 percent to $51.4 million, compared 

to the base case value of $59.8 million 

in 2015. Under the high-shipment 

scenario, industry free cash flow is 

estimated to decrease by approximately 

14 percent to $50.7 million, compared 

to the base case value of $59.1 million 

in 2015. 

The technology changes from TSL 3 to 

TSL 4 are that manufacturers must use 

electronic ballasts to meet the required 

efficiencies for the 70 W outdoor fixture 

class at TSL 4. This increases the 

product conversion costs from $9 

million at TSL 3 to $13 million at TSL 

4 and increases the capital conversion 

costs from $6 million at TSL 3 to $10 

million at TSL 4. 

At TSL 4, under the flat markup 

scenario the shipment-weighted average 

MPC increases 26 percent over the base 

case MPC. In this scenario the 

additional revenue results in slightly 

more positive impacts on INPV at TSL 

4 compared to TSL 3. Under the 

‘preservation of operating profit’ 

markup scenario the 21 percent MPC 

increase is outweighed by a lower 

average markup of 1.52 and $23 million 

in conversion costs, resulting in slightly 

more negative INPV impacts at TSL 4 

compared to TSL 3. 

At TSL 5, DOE estimates impacts on 

INPV to range from $111.3 million to 

-$116.9 million, or a change in INPV of 

17.7 percent to -21.6 percent. At this 

proposed level, industry free cash flow 

under the low-shipment scenario is 

estimated to decrease by approximately 

89 percent to $6.5 million, compared to 

the base case value of $59.8 million in 

2015. Under the high-shipment 

scenario, industry free cash flow is 

estimated to decrease by approximately 

90 percent to $5.8 million, compared to 

the base case value of $59.1 million in 

2015. 

At TSL 5, product conversion costs 

significantly increase to $62 million as 

manufacturers must redesign all 

equipment classes to accommodate the 

most efficient electronic ballasts. Capital 

conversion costs also significantly 

increase to $75 million because of the 

need for additional equipment and 

tooling, such as new castings, to 

incorporate thermal protection in all 

equipment classes. 

At TSL 5, DOE estimates impacts on 

INPV to range from $111.3 million to 

-$116.9 million, or a change in INPV of 

17.7 percent to -21.6 percent. At this 

proposed level, industry free cash flow 

under the low-shipment scenario is 

estimated to decrease by approximately 

89 percent to $6.5 million, compared to 

the base case value of $59.8 million in 

2015. Under the high-shipment 

scenario, industry free cash flow is 

estimated to decrease by approximately 

90 percent to $5.8 million, compared to 

the base case value of $59.1 million in 

2015. 

At TSL 5, product conversion costs 

significantly increase to $62 million as 

manufacturers must redesign all 

equipment classes to accommodate the 

most efficient electronic ballasts. Capital 

conversion costs also significantly 

increase to $75 million because of the 

need for additional equipment and 

tooling, such as new castings, to 

incorporate thermal protection in all 

equipment classes. 

At TSL 5, under the flat markup 

scenario the shipment-weighted average 

MPC increases 57 percent over the base 

case MPC. In this scenario the revenue 

increase from TSL 4 to TSL 5 outweighs 

the increase in conversion costs of $137 

million, resulting in greater positive 

impacts on INPV at TSL 5 compared to 

TSL 4. Under the ‘preservation of 

operating profit’ markup scenario, the 

46 percent MPC increase is outweighed 

by a lower average markup of 1.47 and 

$137 million in conversion costs, 

resulting in significantly more negative 

INPV impacts at TSL 5 compared to TSL 

4. 

b. Impacts on Employment 

DOE quantitatively assessed the 

impacts of potential new and amended 

energy conservation standards on direct 

employment. DOE used the GRIM to 

estimate the domestic labor 

expenditures and number of domestic 

production workers in the base case and 

at each TSL from 2013 to 2045. DOE 

used statistical data from the U.S. 

Census Bureau’s 2009 Annual Survey of 

Manufacturers (ASM), the results of the 

engineering analysis, and interviews 

with manufacturers to determine the 

inputs necessary to calculate industrywide labor expenditures and domestic 

employment levels. Labor expenditures 

involved with the manufacture of the 

product are a function of the labor 


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intensity of the product, the sales 

volume, and an assumption that wages 

remain fixed in real terms over time. 

In the GRIM, DOE used the labor 

content of each product and the 

manufacturing production costs to 

estimate the annual labor expenditures 

in the industry. DOE used Census data 

and interviews with manufacturers to 

estimate the portion of the total labor 

expenditures that is attributable to 

domestic labor. 

The production worker estimates in 

this section cover only workers up to 

the line-supervisor level who are 

directly involved in fabricating and 

assembling a product within an OEM 

facility. Workers performing services 

that are closely associated with 

production operations, such as material 

handing with a forklift, are also 

included as production labor. DOE’s 

estimates account for only production 

workers who manufacture the specific 

products covered by this rulemaking. 

For example, a worker on a fluorescent 

lamp ballast line would not be included 

with the estimate of the number of metal 

halide ballast or fixture workers. 

The employment impacts shown in 

the tables below represent the potential 

production employment that could 

result following new and amended 

energy conservation standards. The 

upper bound of the results estimates the 

maximum change in the number of 

production workers that could occur 

after compliance with new and 

amended energy conservation standards 

when assuming that manufacturers 

continue to produce the same scope of 

covered equipment in the same 

production facilities. It also assumes 

that domestic production does not shift 

to lower-labor-cost countries. Because 

there is a real risk of manufacturers 

evaluating sourcing decisions in 

response to new and amended energy 

conservation standards, the lower 

bound of the employment results 

includes the estimated total number of 

U.S. production workers in the industry 

who could lose their jobs if all existing 

production were moved outside of the 

U.S. While the results present a range of 

employment impacts following 2016, 

the sections below also include 

qualitative discussions of the likelihood 

of negative employment impacts at the 

various TSLs. Finally, the employment 

impacts shown are independent of the 

employment impacts from the broader 

U.S. economy, which are documented 

in chapter 14 of the NOPR TSD. 

Employment Impacts for Metal Halide 

Ballasts 

Based on 2009 ASM data and 

interviews with manufacturers, DOE 

estimates that less than 40 domestic 

production workers would be involved 

in manufacturing metal halide ballasts 

in 2016, as the vast majority of metal 

halide ballasts are manufactured abroad. 

DOE’s view is that manufacturers could 

face moderate positive impacts on 

domestic employment levels because 

increasing equipment costs at each TSL 

would result in higher labor 

expenditures per unit, causing 

manufacturers to hire more workers to 

meet demand for metal halide ballasts, 

assuming that production remains in 

domestic facilities. Many 

manufacturers, however, do not expect 

a significant change in total 

employment at their facilities. Although 

manufacturers are concerned that higher 

prices for metal halide ballasts will 

drive customers to alternate 

technologies, most manufacturers offer 

these alternate technologies and can 

shift their employees from metal halide 

ballast production to production of 

other technologies in their facilities. 

Most manufacturers believe that 

domestic employment will only be 

significantly adversely affected if 

customers shift to foreign imports, 

causing the total lighting market share 

of the major domestic manufacturers to 

decrease. 

Employment Impacts for Metal Halide 

Lamp Fixtures 

Using 2009 ASM data and interviews 

with manufacturers, DOE estimates that 

approximately 60 percent of the metal 

halide lamp fixtures sold in the United 

States are manufactured domestically. 

With this assumption, DOE estimates 

that in the absence of new and amended 

energy conservation standards, there 

would be between 519 and 525 

domestic production workers involved 

in manufacturing metal halide lamp 

fixtures in 2016. The tables below show 

the range of the impacts of potential 

new and amended energy conservation 

standards on U.S. production workers in 

the metal halide lamp fixture industry. 

TABLE VI.31—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC METAL HALIDE LAMP FIXTURE PRODUCTION

WORKERS IN 2016 

[Flat markup and high-shipment scenario] 

Base case Trial standard level 

1 2 3 4 5 

Total Number of Domestic Production 

Workers in 2016 (without changes in 

production locations) ............................ 525 588 626 625 630 684 

Potential Changes in Domestic Production Workers in 2016 * .......................... ........................ 63–(525) 101–(525) 100–(525) 105–(525) 159–(525) 

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers 


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TABLE VI.32—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC METAL HALIDE LAMP FIXTURE PRODUCTION

WORKERS IN 2016 

[Preservation of operating profit markup and low-shipment scenario] 

Base case Trial standard level 

1 2 3 4 5 

Total Number of Domestic Production 

Workers in 2016 (without changes in 

production locations) ............................ 519 581 619 618 623 676 

Potential Changes in Domestic Production Workers in 2016 * .......................... ........................ 62–(519) 100–(519) 99–(519) 104–(519) 157–(519) 

At the upper end of the range, all 

examined TSLs show slight to moderate 

positive impacts on domestic 

employment levels. The increasing 

equipment cost at each higher TSL 

would result in higher labor 

expenditures per unit, causing 

manufacturers to hire more workers to 

meet demand levels of metal halide 

fixtures, assuming that production 

remains in domestic facilities. Many 

manufacturers, however, do not expect 

a significant change in total 

employment at their facilities. Although 

manufacturers are concerned that higher 

prices for metal halide lamp fixtures 

will drive customers to alternate 

technologies, most manufacturers offer 

these alternate technologies and can 

shift their employees from metal halide 

lamp fixture production to production 

of other technologies in their facilities. 

As with ballast manufacturers, most 

fixture manufacturers believe that 

domestic employment will only be 

significantly adversely affected if 

customers shift to foreign imports, 

causing the total lighting market share 

of the major domestic manufacturers to 

decrease. Because of the potentially 

high cost of shipping fixtures from 

overseas, many manufacturers believe 

that this shift is unlikely to occur. This 

is particularly true for the significant 

portion of the market served by small 

manufacturers, for whom the per-unit 

shipping costs of sourcing products 

would be even greater because of the 

lower volumes that they sell. 

Based on the above, DOE does not 

expect the proposed energy 

conservation standards for metal halide 

lamp fixtures, at TSL 3, to have a 

significant negative impact on direct 

domestic employment levels. DOE notes 

that domestic employment levels could 

be negatively affected in the event that 

small fixture businesses choose to exit 

the market due to standards. However, 

discussions with small manufacturers 

indicated that most small businesses 

will be able to adapt to new and 

amended regulations. The impacts on 

small businesses are discussed in 

section VII.B. 

c. Impacts on Manufacturing Capacity 

Both ballast and fixture manufacturers 

stated that they do not anticipate any 

capacity constraints at efficiency levels 

that can be met with magnetic ballasts, 

which are the efficiency levels being 

proposed for eight of the 10 equipment 

classes in today’s NOPR, the two 

exceptions are the 150W indoor and 

outdoor equipment classes. If the 

production of higher-efficiency 

magnetic ballasts decreases the 

throughput on production lines, 

manufacturers stated that they would be 

able to add shifts on existing lines and 

maintain capacity. 

At efficiency levels that require 

electronic ballasts, however, 

manufacturers are concerned about the 

current worldwide shortage of electrical 

components. The components most 

affected by this shortage are highefficiency parts, for which demand 

would increase even further following 

new and amended energy conservation 

standards. The increased demand could 

exacerbate the component shortage, 

thereby impacting manufacturing 

capacity in the near term, according to 

manufacturers. The only equipment 

classes requiring electronic ballasts that 

are being proposed in today’s NOPR are 

the 150W indoor and outdoor 

equipment classes. DOE does not 

anticipate a significant increase in 

demand for electric components due to 

today’s proposed energy conservation 

standards. While DOE recognizes that 

the premium component shortage is 

currently a significant issue for 

manufacturers, DOE views it as a 

relatively short-term phenomenon to 

which component suppliers will 

ultimately adjust. According to several 

manufacturers, suppliers have the 

ability to ramp up production to meet 

ballast component demand by the 

compliance date of potential new 

standards, but those suppliers have 

hesitated to invest in additional 

capacity due to economic uncertainty 

and skepticism about the sustainability 

of demand. The state of the 

macroeconomic environment through 

2016 will likely affect the duration of 

the premium component shortage. 

Potential mandatory standards, 

however, could create more certainty for 

suppliers about the eventual demand for 

these components. Additionally, the 

premium components at issue are not 

new technologies; rather, they have 

simply not historically been demanded 

in large quantities by ballast 

manufacturers. 

d. Impacts on Subgroups of 

Manufacturers 

Using average cost assumptions to 

develop an industry cash-flow estimate 

may not be adequate for assessing 

differential impacts among 

manufacturer subgroups. Small 

manufacturers, niche equipment 

manufacturers, and manufacturers 

exhibiting cost structures substantially 

different from the industry average 

could be affected disproportionately. 

DOE analyzed the impacts to small 

businesses in section VII.B and did not 

identify any other adversely impacted 

subgroups for metal halide ballasts or 

fixtures for this rulemaking based on the 

results of the industry characterization. 

e. Cumulative Regulatory Burden 

While any one regulation may not 

impose a significant burden on 

manufacturers, the combined effects of 

recent or impending regulations may 

have serious consequences for some 

manufacturers, groups of manufacturers, 

or an entire industry. Assessing the 

impact of a single regulation may 

overlook this cumulative regulatory 

burden. In addition to energy 

conservation standards, other 

regulations can significantly affect 

manufacturers’ financial operations. 

Multiple regulations affecting the same 

manufacturer can strain profits and lead 

companies to abandon product lines or 

markets with lower expected future 


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51532 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

returns than competing products. For 

these reasons, DOE conducts an analysis 

of cumulative regulatory burden as part 

of its rulemakings pertaining to 

appliance efficiency. 

During previous stages of this 

rulemaking, DOE identified a number of 

requirements, in addition to new and 

amended energy conservation standards 

for metal halide lamp fixtures, that 

manufacturers will face for products 

and equipment they manufacture 

approximately 3 years prior to and 3 

years after the compliance date of the 

new and amended standards. The 

following section briefly addresses 

comments DOE received with respect to 

cumulative regulatory burden and 

summarizes other key related concerns 

that manufacturers raised during 

interviews. 

Several manufacturers expressed 

concern about the overall volume of 

DOE energy conservation standards 

with which they must comply. Most 

metal halide lamp fixture manufacturers 

also make a full range of lighting 

products and share engineering and 

other resources with these other internal 

manufacturing divisions for different 

products (including certification testing 

for regulatory compliance). 

Manufacturers worried that today’s 

proposed standards could punish 

compliant manufacturers while 

potentially driving others to 

noncompliance, creating an unfair 

playing field. NEMA referenced general 

service fluorescent lamps, incandescent 

reflector lamps, fluorescent lamp 

ballasts, and high-intensity discharge 

lamps as other products subject to DOE 

regulation. (NEMA, No. 34 at p. 17) 

NEMA and Philips also raised concerns 

about other regulatory actions, 

including ENERGY STAR standards 

utilizing separate metrics from DOE’s 

standards and potential outdoor lighting 

legislation. (NEMA, Public Meeting 

Transcript, No. 33 at p. 16; Philips, 

Public Meeting Transcript, No. 33 at p. 

132; NEMA, No. 34 at p. 17) Other 

regulations noted by manufacturers 

during interviews include California 

Title 20 and Title 24. 

DOE discusses these and other 

requirements in chapter 13 of the NOPR 

TSD. DOE takes into account the cost of 

compliance with other published 

Federal energy conservation standards 

in weighing the benefits and burdens of 

today’s proposed rulemaking. DOE does 

not describe the quantitative impacts of 

standards that have not yet been 

finalized because any impacts would be 

speculative. DOE also notes that certain 

standards, such as ENERGY STAR, are 

optional for manufacturers. 

3. National Impact Analysis 

a. Significance of Energy Savings 

For each TSL, DOE projected energy 

savings for metal halide lamp fixtures 

purchased in the 30-year period that 

begins in the year 2016, ending in the 

year 2045. The savings are measured 

over the entire lifetime of equipment 

purchased in the 30-year period. DOE 

quantified the energy savings 

attributable to each TSL as the 

difference in energy consumption 

between each standards case and the 

base case. Table VI.33 presents the 

estimated primary energy savings for 

each TSL for the low- and highshipment scenarios, which represent the 

minimum and maximum energy savings 

resulting from all the scenarios 

analyzed. Table VI.34 presents the 

estimated FFC energy savings for each 

considered TSL. Chapter 11 of the 

NOPR TSD describes these estimates in 

more detail. 

TABLE VI.33—CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2045 

Trial standard level Equipment class 

National Primary Energy Savings 

quads 

Low-shipments 

scenario 

High-shipments 

scenario 

1 ............................................................................ 70 W ..................................................................... 0.01 0.01 

150 W ................................................................... 0.03 0.05 

250 W ................................................................... 0.02 0.03 

400 W ................................................................... 0.10 0.13 

1000 W ................................................................. 0.27 0.37 

Total ............................................................... ............................................................................... 0.44 0.58 

2 ............................................................................ 70 W ..................................................................... 0.05 0.06 

150 W ................................................................... 0.06 0.09 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.20 0.27 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.66 0.89 

3 ............................................................................ 70 W ..................................................................... 0.05 0.06 

150 W ................................................................... 0.19 0.26 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.20 0.27 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.79 1.06 

4 ............................................................................ 70 W ..................................................................... 0.15 0.19 

150 W ................................................................... 0.19 0.26 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.20 0.27 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.89 1.20 

5 ............................................................................ 70 W ..................................................................... 0.18 0.24 

150 W ................................................................... 0.19 0.26 

250 W ................................................................... 0.35 0.49 

400 W ................................................................... 0.77 1.08 


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57EPCA requires DOE to review its standards at 

least once every 6 years, and requires, for certain 

products, a 3 year period after any new standard is 

promulgated before compliance is required, except 

that in no case may any new standards be required 

within 6 years of the compliance date of the 

previous standards. While adding a 6-year review 

to the 3-year compliance period adds up to 9 years, 

DOE notes that it may undertake reviews at any 

time within the 6 year period and that the 3-year 

compliance date may yield to the 6-year backstop. 

TABLE VI.33—CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2045—Continued 

Trial standard level Equipment class 

National Primary Energy Savings 

quads 

Low-shipments 

scenario 

High-shipments 

scenario 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 1.80 2.49 

TABLE VI.34—CUMULATIVE NATIONAL FULL-FUEL-CYCLE ENERGY SAVINGS FOR METAL HALIDE LAMP FIXTURE TRIAL

STANDARD LEVELS FOR UNITS SOLD IN 2016–2045 

Trial standard level Equipment class 

National FFC energy savings 

quads 

Low-shipments 

scenario 

High-shipments 

scenario 

1 ............................................................................ 70 W ..................................................................... 0.01 0.01 

150 W ................................................................... 0.03 0.05 

250 W ................................................................... 0.02 0.03 

400 W ................................................................... 0.10 0.13 

1000 W ................................................................. 0.28 0.38 

Total ............................................................... ............................................................................... 0.45 0.59 

2 ............................................................................ 70 W ..................................................................... 0.05 0.06 

150 W ................................................................... 0.06 0.09 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.21 0.28 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.67 0.90 

3 ............................................................................ 70 W ..................................................................... 0.05 0.06 

150 W ................................................................... 0.19 0.27 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.21 0.28 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.80 1.08 

4 ............................................................................ 70 W ..................................................................... 0.16 0.20 

150 W ................................................................... 0.19 0.27 

250 W ................................................................... 0.04 0.06 

400 W ................................................................... 0.21 0.28 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 0.91 1.22 

5 ............................................................................ 70 W ..................................................................... 0.19 0.24 

150 W ................................................................... 0.19 0.27 

250 W ................................................................... 0.36 0.50 

400 W ................................................................... 0.78 1.10 

1000 W ................................................................. 0.31 0.42 

Total ............................................................... ............................................................................... 1.83 2.53 

Circular A–4 requires agencies to 

present analytical results, including 

separate schedules of the monetized 

benefits and costs that show the type 

and timing of benefits and costs. 

Circular A–4 also directs agencies to 

consider the variability of key elements 

underlying the estimates of benefits and 

costs. For this rulemaking, DOE 

undertook a sensitivity analysis using 

nine rather than 30 years of fixture 

shipments. The choice of a 9-year 

period is a proxy for the timeline in 

EPCA for the review of certain energy 

conservation standards and potential 

revision of and compliance with such 

revised standards.57 We would note that 

the review timeframe established in 

EPCA generally does not overlap with 

the equipment lifetime, equipment 

manufacturing cycles or other factors 

specific to metal halide lamp fixtures. 

Thus, this information is presented for 

informational purposes only and is not 

indicative of any change in DOE’s 

analytical methodology. The NES 

results based on a 9-year analytical 

period are presented in Table VI.35. The 

impacts are counted over the lifetime of 

fixtures purchased in 2016–2024. 


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58OMB Circular A–4, section E (Sept. 17, 2003). 

Available at: www.whitehouse.gov/omb/circulars_

a004_a-4. 

TABLE VI.35—CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2024 

Trial standard level Equipment class 

National primary energy savings 

quads 

Low-shipments 

scenario 

High-shipments 

scenario 

1 ............................................................................ 70 W ..................................................................... 0.01 0.01 

150 W ................................................................... 0.02 0.02 

250 W ................................................................... 0.01 0.01 

400 W ................................................................... 0.06 0.07 

1000 W ................................................................. 0.15 0.16 

Total ............................................................... ............................................................................... 0.25 0.28 

2 ............................................................................ 70 W ..................................................................... 0.03 0.03 

150 W ................................................................... 0.03 0.03 

250 W ................................................................... 0.02 0.03 

400 W ................................................................... 0.11 0.12 

1000 W ................................................................. 0.16 0.18 

Total ............................................................... ............................................................................... 0.36 0.40 

3 ............................................................................ 70 W ..................................................................... 0.03 0.03 

150 W ................................................................... 0.09 0.10 

250 W ................................................................... 0.02 0.03 

400 W ................................................................... 0.11 0.12 

1000 W ................................................................. 0.16 0.18 

Total ............................................................... ............................................................................... 0.42 0.46 

4 ............................................................................ 70 W ..................................................................... 0.09 0.10 

150 W ................................................................... 0.09 0.10 

250 W ................................................................... 0.02 0.03 

400 W ................................................................... 0.11 0.12 

1000 W ................................................................. 0.16 0.18 

Total ............................................................... ............................................................................... 0.48 0.53 

5 ............................................................................ 70 W ..................................................................... 0.11 0.12 

150 W ................................................................... 0.09 0.10 

250 W ................................................................... 0.17 0.19 

400 W ................................................................... 0.36 0.40 

1000 W ................................................................. 0.16 0.18 

Total ............................................................... ............................................................................... 0.89 0.99 

b. Net Present Value of Customer Costs 

and Benefits 

DOE estimated the cumulative NPV of 

the total costs and savings for customers 

that would result from the TSLs 

considered for metal halide lamp 

fixtures. In accordance with OMB’s 

guidelines on regulatory analysis,58

DOE calculated the NPV using both a 7- 

percent and a 3-percent real discount 

rate. The 7-percent rate is an estimate of 

the average before-tax rate of return on 

private capital in the U.S. economy, and 

reflects the returns on real estate and 

small business capital as well as 

corporate capital. This discount rate 

approximates the opportunity cost of 

capital in the private sector (OMB 

analysis has found the average rate of 

return on capital to be near this rate). 

The 3-percent rate reflects the potential 

effects of standards on private 

consumption (e.g., through higher prices 

for products and reduced purchases of 

energy). This rate represents the rate at 

which society discounts future 

consumption flows to their present 

value. It can be approximated by the 

real rate of return on long-term 

government debt (i.e., yield on United 

States Treasury notes), which has 

averaged about 3 percent for the past 30 

years. 

Table VI.36 shows the customer NPV 

results for each TSL DOE considered for 

metal halide lamp fixtures, using both 7- 

percent and 3-percent discount rates. In 

each case, the impacts cover the lifetime 

of equipment purchased in 2016–2045. 

See chapter 11 of the NOPR TSD for 

more detailed NPV results. 


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TABLE VI.36—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2045 

Trial standard level Equipment class 

Net present value 

billion 2012$ 

Low-shipments scenario High-shipments scenario 

7-percent discount 

rate 

3-percent discount 

rate 

7-percent discount 

rate 

3-percent discount 

rate 

1 ........................................ 70 W ................................. 0.039 0.068 0.042 0.073 

150 W ............................... 0.036 0.094 0.044 0.124 

250 W ............................... 0.009 0.065 0.012 0.084 

400 W ............................... 0.009 0.109 0.014 0.140 

1000 W ............................. 0.596 1.292 0.728 1.680 

Total ........................... ........................................... 0.688 1.629 0.840 2.100 

2 ........................................ 70 W ................................. 0.054 0.124 0.060 0.144 

150 W ............................... 0.083 0.205 0.104 0.274 

250 W ............................... 0.028 0.146 0.038 0.194 

400 W ............................... 0.108 0.383 0.140 0.507 

1000 W ............................. 0.636 1.393 0.779 1.815 

Total ........................... ........................................... 0.909 2.251 1.121 2.933 

3 ........................................ 70 W ................................. 0.054 0.124 0.060 0.144 

150 W ............................... 0.125 0.408 0.162 0.558 

250 W ............................... 0.028 0.146 0.038 0.194 

400 W ............................... 0.108 0.383 0.140 0.507 

1000 W ............................. 0.636 1.393 0.779 1.815 

Total ........................... ........................................... 0.951 2.454 1.179 3.217 

4 ........................................ 70 W ................................. 0.029 0.330 0.034 0.406 

150 W ............................... 0.125 0.408 0.162 0.558 

250 W ............................... 0.028 0.146 0.038 0.194 

400 W ............................... 0.108 0.383 0.140 0.507 

1000 W ............................. 0.636 1.393 0.779 1.815 

Total ........................... ........................................... 0.927 2.660 1.153 3.479 

5 ........................................ 70 W ................................. ¥0.015 0.278 ¥0.018 0.344 

150 W ............................... 0.125 0.408 0.162 0.558 

250 W ............................... ¥0.055 0.287 ¥0.050 0.430 

400 W ............................... ¥0.344 0.134 ¥0.394 0.256 

1000 W ............................. 0.636 1.393 0.779 1.815 

Total ........................... ........................................... 0.347 2.500 0.478 3.401 

The NPV results based on the aforementioned 9-year analytical period are 

presented in Table VI.37. The impacts 

are counted over the lifetime of fixtures 

purchased in 2016–2024. As mentioned 

previously, this information is 

presented for informational purposes 

only and is not indicative of any change 

in DOE’s analytical methodology or 

decision criteria. 

TABLE VI.37—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2024 

Trial standard level Equipment class 

Net present value 

billion 2012$ 

Low-shipments scenario High-shipments scenario 

7-percent discount 

rate 

3-percent discount 

rate 

7-percent discount 

rate 

3-percent discount 

rate 

1 ........................................ 70 W ................................. 0.039 0.068 0.042 0.073 

150 W ............................... 0.023 0.053 0.025 0.058 

250 W ............................... 0.004 0.037 0.004 0.041 

400 W ............................... 0.001 0.062 0.001 0.069 

1000 W ............................. 0.419 0.779 0.457 0.856 

Total ........................... ........................................... 0.485 0.999 0.530 1.097 

2 ........................................ 70 W ................................. 0.047 0.099 0.051 0.107 

150 W ............................... 0.053 0.113 0.059 0.124 

250 W ............................... 0.013 0.078 0.015 0.086 

400 W ............................... 0.061 0.206 0.068 0.227 


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51536 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.37—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2024—Continued 

Trial standard level Equipment class 

Net present value 

billion 2012$ 

Low-shipments scenario High-shipments scenario 

7-percent discount 

rate 

3-percent discount 

rate 

7-percent discount 

rate 

3-percent discount 

rate 

1000 W ............................. 0.445 0.834 0.486 0.916 

Total ........................... ........................................... 0.620 1.329 0.678 1.461 

3 ........................................ 70 W ................................. 0.047 0.099 0.051 0.107 

150 W ............................... 0.075 0.209 0.082 0.231 

250 W ............................... 0.013 0.078 0.015 0.086 

400 W ............................... 0.061 0.206 0.068 0.227 

1000 W ............................. 0.445 0.834 0.486 0.916 

Total ........................... ........................................... 0.642 1.426 0.702 1.567 

4 ........................................ 70 W ................................. 0.024 0.216 0.025 0.236 

150 W ............................... 0.075 0.209 0.082 0.231 

250 W ............................... 0.013 0.078 0.015 0.086 

400 W ............................... 0.061 0.206 0.068 0.227 

1000 W ............................. 0.445 0.834 0.486 0.916 

Total ........................... ........................................... 0.618 1.542 0.676 1.696 

5 ........................................ 70 W ................................. ¥0.010 0.178 ¥0.012 0.194 

150 W ............................... 0.075 0.209 0.082 0.231 

250 W ............................... ¥0.063 0.099 ¥0.068 0.110 

400 W ............................... ¥0.280 ¥0.027 ¥0.305 ¥0.027 

1000 W ............................. 0.445 0.834 0.486 0.916 

Total ........................... ........................................... 0.166 1.292 0.183 1.424 

Finally, DOE evaluated the NPV 

results for both indoor and outdoor 

fixtures for each equipment class. Table 

VI.38 gives the NPV associated with 

each equipment class broken down into 

indoor and outdoor fixture 

environments. 

TABLE VI.38—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2045 

[Low shipments, by fixture environment] 

Trial standard level Equipment class 

Net present value 

billion 2012$ 

Indoor fixtures Outdoor fixtures 

7-percent discount 

rate 

3-percent discount 

rate 

7-percent discount 

rate 

3-percent discount 

rate 

1 ........................................ 70 W ................................. 0.000 0.000 0.039 0.068 

150 W ............................... 0.011 0.028 0.025 0.066 

250 W ............................... 0.005 0.024 0.004 0.041 

400 W ............................... 0.007 0.037 0.002 0.072 

1000 W ............................. 0.183 0.378 0.413 0.914 

Total ........................... ...................................... 0.205 0.468 0.483 1.161 

2 ........................................ 70 W ................................. 0.000 0.000 0.054 0.124 

150 W ............................... 0.025 0.059 0.058 0.146 

250 W ............................... 0.012 0.048 0.017 0.098 

400 W ............................... 0.036 0.115 0.072 0.268 

1000 W ............................. 0.197 0.411 0.439 0.981 

Total ........................... ........................................... 0.269 0.633 0.640 1.618 

3 ........................................ 70 W ................................. 0.000 0.000 0.054 0.124 

150 W ............................... 0.019 0.012 0.106 0.396 

250 W ............................... 0.012 0.048 0.017 0.098 

400 W ............................... 0.036 0.115 0.072 0.268 

1000 W ............................. 0.197 0.411 0.439 0.981 

Total ........................... ........................................... 0.263 0.586 0.688 1.868 

4 ........................................ 70 W ................................. 0.000 0.000 0.029 0.330 

150 W ............................... 0.019 0.012 0.106 0.396 


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TABLE VI.38—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR METAL HALIDE LAMP FIXTURE TRIAL STANDARD

LEVELS FOR UNITS SOLD IN 2016–2045—Continued 

[Low shipments, by fixture environment] 

Trial standard level Equipment class 

Net present value 

billion 2012$ 

Indoor fixtures Outdoor fixtures 

7-percent discount 

rate 

3-percent discount 

rate 

7-percent discount 

rate 

3-percent discount 

rate 

250 W ............................... 0.012 0.048 0.017 0.098 

400 W ............................... 0.036 0.115 0.072 0.268 

1000 W ............................. 0.197 0.411 0.439 0.981 

Total ........................... ...................................... 0.263 0.586 0.664 2.074 

5 ........................................ 70 W ................................. ¥0.012 ¥0.018 ¥0.003 0.296 

150 W ............................... 0.019 0.012 0.106 0.396 

250 W ............................... ¥0.042 ¥0.120 ¥0.012 0.407 

400 W ............................... ¥0.148 ¥0.284 ¥0.196 0.418 

1000 W ............................. 0.197 0.411 0.439 0.981 

Total ........................... ........................................... 0.013 0.002 0.334 2.499 

c. Impacts on Employment 

DOE estimated the indirect 

employment impacts of potential 

standards on the economy in general, 

assuming that energy conservation 

standards for metal halide lamp fixtures 

will reduce energy bills for fixture users 

and the resulting net savings will be 

redirected to other forms of economic 

activity. DOE used an input/output 

model of the U.S. economy to estimate 

these effects, including the demand for 

labor as described in section V.H. 

The input/output model results 

suggest that today’s proposed standards 

are likely to increase the net labor 

demand. The gains, however, would 

most likely be small relative to total 

national employment, and neither the 

BLS data nor the input/output model 

DOE uses includes the quality or wage 

level of the jobs. As shown in Table 

VI.39, DOE estimates that net indirect 

employment impacts from proposed 

fixture standards are small relative to 

the national economy. 

TABLE VI.39—NET CHANGE IN JOBS FROM INDIRECT EMPLOYMENT EFFECTS UNDER FIXTURE TSLS

Analysis period year Trial standard level 

Net national change in jobs 

Low shipments 

scenario, roll-up 

High shipments 

scenario, roll-up 

2017 ...................................................................... 1 ............................................................................ 10 8 

2 ............................................................................ ¥30 ¥36 

3 ............................................................................ 76 73 

4 ............................................................................ 170 168 

5 ............................................................................ 352 346 

2020 ...................................................................... 1 ............................................................................ 376 392 

2 ............................................................................ 511 530 

3 ............................................................................ 791 827 

4 ............................................................................ 1,091 1,142 

5 ............................................................................ 2,336 2,445 

4. Impact on Utility or Performance of 

Equipment 

As presented in section V.B of this 

notice, DOE concluded that none of the 

TSLs that were analyzed would reduce 

the utility or performance of the 

products under consideration in this 

rulemaking. Furthermore, 

manufacturers of these products 

currently offer ballasts that meet or 

exceed the proposed standards. (42 

U.S.C. 6295(o)(2)(B)(i)(IV)) 

5. Impact of Any Lessening of 

Competition 

DOE also considered any lessening of 

competition that is likely to result from 

new and amended energy conservation 

standards. The Attorney General 

determines the impact, if any, of any 

lessening of competition likely to result 

from a proposed standard, and transmits 

such determination to the Secretary, 

together with an analysis of the nature 

and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) 

To assist the Attorney General in 

making such determination, DOE has 

provided DOJ with copies of this notice 

and the TSD for review. DOE will 

consider DOJ’s comments on the 

proposed rule in preparing the final 

rule, and DOE will publish and respond 

to DOJ’s comments in that document. 

6. Need of the Nation To Conserve 

Energy 

An improvement in the energy 

efficiency of the products subject to 

today’s rule is likely to improve the 

security of the nation’s energy system by 

reducing overall demand for energy. 

Reduced electricity demand may also 

improve the reliability of the electricity 

system. Reductions in national electric 

generating capacity estimated for each 

considered TSL are reported in chapter 

14 of the NOPR TSD. 

Energy savings from new and 

amended energy conservation standards 

for fixtures could produce 


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51538 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

environmental benefits in the form of 

reduced emissions of air pollutants and 

GHGs associated with electricity 

production. Table VI.40 and Table VI.41 

provide DOE’s estimate of cumulative 

emissions reductions projected to result 

from the TSLs considered in this 

rulemaking, for the low and high 

shipment scenarios, respectively. The 

tables include both power sector 

emissions and upstream emissions. The 

upstream emissions were calculated 

using the multipliers discussed in 

section V.L. DOE reports annual 

emissions reductions for each TSL in 

the emissions analysis in chapter 16 the 

NOPR TSD. 

TABLE VI.40—CUMULATIVE EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE LAMP FIXTURES

[Low Shipments Scenario] 

Trial standard level 

1 2 3 4 5 

Power Sector Emissions* 

CO2 (million metric tons) ............................................ 25 .90 38 .85 46 .04 52 .32 104 .72 

NOX (thousand tons) ................................................. 17 .39 26 .22 31 .20 35 .41 71 .71 

Hg (tons) .................................................................... 0 .06 0 .09 0 .11 0 .12 0 .24 

N2O (thousand tons) .................................................. 0 .48 0 .72 0 .86 0 .98 2 .00 

CH4 (thousand tons) .................................................. 2 .90 4 .37 5 .18 5 .89 11 .86 

SO2 (thousand tons) .................................................. 36 .23 54 .37 64 .42 73 .25 146 .53 

Upstream Emissions 

CO2 (million metric tons) ............................................ 1 .40 2 .11 2 .50 2 .84 5 .70 

NOX (thousand tons) ................................................. 19 .27 28 .98 34 .37 39 .08 78 .45 

Hg (tons) .................................................................... 0 .001 0 .001 0 .001 0 .002 0 .003 

N2O (thousand tons) .................................................. 0 .01 0 .02 0 .03 0 .03 0 .06 

CH4 (thousand tons) .................................................. 116 .89 175 .81 208 .58 237 .15 476 .16 

SO2 (thousand tons) .................................................. 0 .30 0 .45 0 .54 0 .61 1 .22 

Total Emissions 

CO2 (million metric tons) ............................................ 27 .30 40 .96 48 .53 55 .16 110 .43 

NOX (thousand tons) ................................................. 36 .66 55 .20 65 .57 74 .48 150 .16 

Hg (tons) .................................................................... 0 .06 0 .09 0 .11 0 .12 0 .24 

N2O (thousand tons) .................................................. 0 .49 0 .74 0 .89 1 .01 2 .06 

CH4 (thousand tons) .................................................. 119 .79 180 .18 213 .76 243 .04 488 .01 

SO2 (thousand tons) .................................................. 36 .53 54 .82 64 .95 73 .85 147 .75 

TABLE VI.41—CUMULATIVE EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE LAMP FIXTURES

[High shipments scenario] 

Trial standard level 

1 2 3 4 5 

Power Sector Emissions* 

CO2 (million metric tons) ............................................ 33 .93 51 .48 61 .61 69 .58 143 .59 

NOX (thousand tons) ................................................. 23 .50 35 .86 43 .14 48 .58 101 .88 

Hg (tons) .................................................................... 0 .08 0 .12 0 .14 0 .16 0 .34 

N2O (thousand tons) .................................................. 0 .66 1 .01 1 .22 1 .37 2 .90 

CH4 (thousand tons) .................................................. 3 .85 5 .87 7 .04 7 .95 16 .50 

SO2 (thousand tons) .................................................. 47 .41 71 .94 86 .07 97 .26 200 .46 

Upstream Emissions 

CO2 (million metric tons) ............................................ 1 .85 2 .81 3 .37 3 .81 7 .88 

NOX (thousand tons) ................................................. 25 .44 38 .69 46 .36 52 .37 108 .39 

Hg (tons) .................................................................... 0 .001 0 .002 0 .002 0 .002 0 .004 

N2O (thousand tons) .................................................. 0 .02 0 .03 0 .03 0 .04 0 .08 

CH4 (thousand tons) .................................................. 154 .45 234 .93 281 .50 317 .98 658 .29 

SO2 (thousand tons) .................................................. 0 .40 0 .60 0 .72 0 .82 1 .69 

Total Emissions 

CO2 (million metric tons) ............................................ 35 .78 54 .29 64 .98 73 .39 151 .47 

NOX (thousand tons) ................................................. 48 .94 74 .55 89 .50 100 .95 210 .26 

Hg (tons) .................................................................... 0 .08 0 .12 0 .15 0 .16 0 .34 

N2O (thousand tons) .................................................. 0 .68 1 .04 1 .25 1 .41 2 .98 

CH4 (thousand tons) .................................................. 158 .30 240 .80 288 .54 325 .92 674 .79 

SO2 (thousand tons) .................................................. 47 .80 72 .54 86 .79 98 .08 202 .14 


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As discussed in section V.L, DOE did 

not report SO2 emissions reductions 

from power plants because there is 

uncertainty about the effect of energy 

conservation standards on the overall 

level of SO2 emissions in the United 

States due to new emissions standards 

for power plants under the MATS rule. 

DOE also did not include NOX

emissions reductions from power plants 

in states subject to CAIRR because an 

energy conservation standard would not 

affect the overall level of NOX emissions 

in those states due to the emissions 

caps. 

As part the analysis for this proposed 

rule, DOE estimated monetary benefits 

likely to result from the reduced 

emissions of CO2 and NOX that DOE 

estimated for each of the TSLs 

considered. As discussed in section 

V.M.1, DOE used values for the SCC 

developed by an interagency process. 

The interagency group selected four sets 

of SCC values for use in regulatory 

analyses. Three sets are based on the 

average SCC from three integrated 

assessment models, at discount rates of 

2.5 percent, 3 percent, and 5 percent. 

The fourth set, which represents the 

95th-percentile SCC estimate across all 

three models at a 3-percent discount 

rate, is included to represent higherthan-expected impacts from temperature 

change further out in the tails of the 

SCC distribution. The four SCC values 

for CO2 emissions reductions in 2015, 

expressed in 2012$, are $12.9/ton, 

$40.8/ton, $62.2/ton, and $117.0/ton. 

These values for later years are higher 

due to increasing emissions-related 

costs as the magnitude of projected 

climate change increases. 

Table VI.42 and Table VI.43 present 

the global value of CO2 emissions 

reductions at each TSL for the low and 

high shipment scenarios, respectively. 

DOE calculated domestic values as a 

range from 7 percent to 23 percent of the 

global values, and these results are 

presented in chapter 17 of the NOPR 

TSD. 

TABLE VI.42—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE

LAMP FIXTURES

[Low Shipments Scenario] 

TSL 

SCC Scenario* 

5% discount 

rate, average 

3% discount 

rate, average 

2.5% discount 

rate, average 

3% discount 

rate, 95th 

percentile 

Million 2012$ 

Power Sector Emissions 

1 ....................................................................................................................... 180.6 824.4 1,309.4 2,521.8 

2 ....................................................................................................................... 268.6 1,230.7 1,956.1 3,766.3 

3 ....................................................................................................................... 316.6 1,453.6 2,311.6 4,449.4 

4 ....................................................................................................................... 360.3 1,653.5 2,629.2 5,061.5 

5 ....................................................................................................................... 709.1 3,276.7 5,218.2 10,037.1 

Upstream Emissions 

1 ....................................................................................................................... 9.6 44.2 70.3 135.5 

2 ....................................................................................................................... 14.3 66.2 105.3 202.8 

3 ....................................................................................................................... 16.9 78.3 124.6 239.9 

4 ....................................................................................................................... 19.3 89.1 141.8 273.0 

5 ....................................................................................................................... 38.0 177.1 282.3 543.0 

Total Emissions 

1 ....................................................................................................................... 190.2 868.7 1,379.7 2,657.2 

2 ....................................................................................................................... 283.0 1,296.9 2,061.5 3,969.1 

3 ....................................................................................................................... 333.5 1,531.9 2,436.2 4,689.3 

4 ....................................................................................................................... 379.5 1,742.6 2,771.0 5,334.5 

5 ....................................................................................................................... 747.2 3,453.8 5,500.6 10,580.1 

*For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 per metric ton (2012$). 

TABLE VI.43—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE

LAMP FIXTURES

[High shipments scenario] 

TSL 

SCC Scenario* 

5% discount 

rate, average 

3% discount 

rate, average 

2.5% discount 

rate, average 

3% discount 

rate, 95th 

percentile 

Million 2012$ 

Power Sector Emissions 

1 ....................................................................................................................... 226.5 1,052.4 1,678.3 3,225.1 

2 ....................................................................................................................... 340.4 1,587.8 2,534.4 4,868.3 

3 ....................................................................................................................... 404.3 1,891.8 3,021.8 5,802.1 


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51540 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.43—GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE

LAMP FIXTURES—Continued 

[High shipments scenario] 

TSL 

SCC Scenario* 

5% discount 

rate, average 

3% discount 

rate, average 

2.5% discount 

rate, average 

3% discount 

rate, 95th 

percentile 

4 ....................................................................................................................... 458.2 2,141.2 3,418.9 6,566.6 

5 ....................................................................................................................... 924.3 4,359.1 6,975.4 13,379.6 

Upstream Emissions 

1 ....................................................................................................................... 12.2 56.9 90.9 174.7 

2 ....................................................................................................................... 18.3 86.1 137.6 264.4 

3 ....................................................................................................................... 21.8 102.8 164.3 315.5 

4 ....................................................................................................................... 24.7 116.3 185.9 357.1 

5 ....................................................................................................................... 50.1 237.6 380.6 730.0 

Total Emissions 

1 ....................................................................................................................... 238.7 1,109.3 1,769.2 3,399.8 

2 ....................................................................................................................... 358.7 1,674.0 2,672.0 5,132.7 

3 ....................................................................................................................... 426.2 1,994.6 3,186.1 6,117.6 

4 ....................................................................................................................... 482.9 2,257.5 3,604.9 6,923.7 

5 ....................................................................................................................... 974.3 4,596.7 7,356.0 14,109.6 

*For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 per metric ton (2012$). 

DOE is well aware that scientific and 

economic knowledge about the 

contribution of CO2 and other GHG 

emissions to changes in the future 

global climate and the potential 

resulting damages to the world economy 

continues to evolve rapidly. Thus, any 

value placed in this rulemaking on 

reducing CO2 emissions is subject to 

change. DOE, together with other 

Federal agencies, will continue to 

review various methodologies for 

estimating the monetary value of 

reductions in CO2 and other GHG 

emissions. This ongoing review will 

consider the comments on this subject 

that are part of the public record for this 

and other rulemakings, as well as other 

methodological assumptions and issues. 

However, consistent with DOE’s legal 

obligations, and taking into account the 

uncertainty involved with this 

particular issue, DOE has included in 

this NOPR the most recent values and 

analyses resulting from the ongoing 

interagency review process. 

DOE also estimated a range for the 

cumulative monetary value of the 

economic benefits associated with NOX

and Hg emissions reductions 

anticipated to result from amended 

metal halide lamp fixture standards. 

Estimated monetary benefits for CO2

and NOX emission reductions are 

detailed in chapter 17 of the NOPR TSD. 

The NPV of the monetized benefits 

associated with emissions reductions 

can be viewed as a complement to the 

NPV of the customer savings calculated 

for each TSL considered in this 

proposed rulemaking. The dollar-perton values that DOE used are discussed 

in section V.M. Table VI.44 presents the 

present value of cumulative NOX

emissions reductions for each TSL 

calculated using the average dollar-perton values and 7-percent and 3-percent 

discount rates. 

TABLE VI.44—PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE LAMP

FIXTURES

TSL 

Low shipments scenario High 

shipments 

scenario 

3% discount 

rate 

7% discount 

rate 3% discount 

rate 

7% discount 

rate 

million 2012$ 

Power Sector Emissions 

1 ....................................................................................................................... 24.4 12.3 30.9 14.7 

2 ....................................................................................................................... 36.3 18.1 46.5 21.8 

3 ....................................................................................................................... 42.8 21.2 55.4 25.7 

4 ....................................................................................................................... 48.7 24.1 62.7 29.1 

5 ....................................................................................................................... 96.3 46.6 127.3 57.2 

Upstream Emissions 

1 ....................................................................................................................... 27.2 13.6 34.1 16.2 

2 ....................................................................................................................... 40.5 20.0 51.3 24.0 

3 ....................................................................................................................... 47.7 23.4 60.9 28.3 

4 ....................................................................................................................... 54.3 26.6 69.0 32.1 


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TABLE VI.44—PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR POTENTIAL STANDARDS FOR METAL HALIDE LAMP

FIXTURES—Continued 

TSL 

Low shipments scenario High 

shipments 

scenario 

3% discount 

rate 

7% discount 

rate 3% discount 

rate 

7% discount 

rate 

5 ....................................................................................................................... 106.9 51.4 139.1 63.0 

Total Emissions 

1 ....................................................................................................................... 51.6 25.9 65.0 30.9 

2 ....................................................................................................................... 76.8 38.1 97.8 45.8 

3 ....................................................................................................................... 90.6 44.6 116.3 53.9 

4 ....................................................................................................................... 103.0 50.8 131.7 61.2 

5 ....................................................................................................................... 203.2 98.1 266.4 120.3 

The NPV of the monetized benefits 

associated with emissions reductions 

can be viewed as a complement to the 

NPV of the customer savings calculated 

for each TSL considered in this 

rulemaking. Table VI.45 and Table VI.46 

present the NPV values that result from 

adding the estimates of the potential 

economic benefits resulting from 

reduced CO2 and NOX emissions in each 

of four valuation scenarios to the NPV 

of customer savings calculated for each 

TSL considered in this rulemaking, at 

both a 7-percent and a 3-percent 

discount rate, and for the low and high 

shipment scenarios, respectively. The 

CO2 values used in the columns of each 

table correspond to the four scenarios 

for the valuation of CO2 emission 

reductions discussed above. 

TABLE VI.45—METAL HALIDE LAMP FIXTURE TSLS: NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED WITH NET

PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS

[Low shipments scenario] 

TSL 

Customer NPV at 3% discount rate added with: 

SCC Value of 

$12.9/metric 

ton CO2

* and 

low value for 

NOX**

SCC Value of 

$40.8/metric 

ton CO2

* and 

medium value 

for NOX**

SCC Value of 

$62.2/metric 

ton CO2

* and 

medium value 

for NOX**

SCC Value of 

$117.0/metric 

ton CO2

* and 

high value for 

NOX**

billion 2012$ 

1 ....................................................................................................................... 1.828 2.549 3.060 4.380 

2 ....................................................................................................................... 2.547 3.624 4.389 6.360 

3 ....................................................................................................................... 2.803 4.076 4.981 7.308 

4 ....................................................................................................................... 3.058 4.506 5.534 8.182 

5 ....................................................................................................................... 3.284 6.157 8.204 13.451 

Customer NPV at 7% Discount Rate added with: 

billion 2012$ 

1 ....................................................................................................................... 0.883 1.583 2.094 3.393 

2 ....................................................................................................................... 1.199 2.244 3.008 4.947 

3 ....................................................................................................................... 1.293 2.528 3.432 5.722 

4 ....................................................................................................................... 1.315 2.720 3.749 6.354 

5 ....................................................................................................................... 1.112 3.899 5.946 11.106 

*These label values represent the global SCC in 2015, in 2012$. The present values have been calculated with scenario-consistent discount 

rates. ** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton of NOX emissions. High Value corresponds to $4,809 per ton of NOX emissions. 


sroberts on DSK5SPTVN1PROD with PROPOSALS
51542 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.46—METAL HALIDE LAMP FIXTURE TSLS: NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED WITH NET

PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS

[High shipments scenario] 

TSL 

Customer NPV at 3% discount rate added with: 

SCC Value of 

$12.9/metric 

ton CO2

* and 

low value for 

NOX**

SCC Value of 

$40.8/metric 

ton CO2

* and 

medium value 

for NOX**

SCC Value of 

$62.2/metric 

ton CO2

* and 

medium value 

for NOX**

SCC Value of 

$117.0/metric 

ton CO2

* and 

high value for 

NOX**

billion 2012$ 

1 ....................................................................................................................... 2.351 3.275 3.935 5.619 

2 ....................................................................................................................... 3.309 4.705 5.703 8.244 

3 ....................................................................................................................... 3.664 5.328 6.520 9.547 

4 ....................................................................................................................... 3.985 5.868 7.215 10.642 

5 ....................................................................................................................... 4.423 8.264 11.023 17.996 

Customer NPV at 7% Discount Rate added with: 

billion 2012$ 

1 ....................................................................................................................... 1.085 1.981 2.641 4.297 

2 ....................................................................................................................... 1.488 2.841 3.839 6.337 

3 ....................................................................................................................... 1.614 3.227 4.419 7.395 

4 ....................................................................................................................... 1.647 3.472 4.819 8.188 

5 ....................................................................................................................... 1.474 5.195 7.955 14.807 

*These label values represent the global SCC in 2015, in 2012$. The present values have been calculated with scenario-consistent discount 

rates. ** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton of NOX emissions. High Value corresponds to $4,809 per ton of NOX emissions. 

Although adding the value of 

customer savings to the values of 

emission reductions provides a valuable 

perspective, the following should be 

considered: (1) The national customer 

savings are domestic U.S. customer 

monetary savings found in market 

transactions, while the values of 

emissions reductions are based on 

estimates of marginal social costs, 

which, in the case of CO2, are based on 

a global value; and (2) the assessments 

of customer savings and emissionsrelated benefits are performed with 

different computer models, leading to 

different time frames for analysis. For 

fixtures, the present value of national 

customer savings is measured for the 

period in which units shipped in 2016– 

2045 continue to operate. The SCC 

values, on the other hand, reflect the 

present value of future climate-related 

impacts resulting from the emission of 

one metric ton of CO2 in each year. 

These impacts continue well beyond 

2100. 

C. Proposed Standards 

DOE is subject to the EPCA 

requirement that any new or amended 

energy conservation standard for any 

type (or class) of covered equipment be 

designed to achieve the maximum 

improvement in energy efficiency that 

the Secretary determines is 

technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A)) In determining whether a 

standard is economically justified, the 

Secretary must determine whether the 

benefits of the standard exceed its 

burdens to the greatest extent 

practicable, in light of the seven 

statutory factors discussed previously. 

(42 U.S.C. 6295(o)(2)(B)(i)) The new or 

amended standard must also result in a 

significant conservation of energy. (42 

U.S.C. 6295(o)(3)(B)) 

DOE considered the impacts of MHLF 

standards at each trial standard level, 

beginning with the max tech level, to 

determine whether that level met the 

evaluation criteria. If the max tech level 

was not justified, DOE then considered 

the next most efficient level and 

undertook the same evaluation until it 

reached the highest efficiency level that 

is both technologically feasible and 

economically justified and saves a 

significant amount of energy. 

DOE discusses the benefits and/or 

burdens of each trial standard level in 

the following sections based on the 

quantitative analytical results for each 

trial standard level (presented in section 

VI.A) such as national energy savings, 

net present value (discounted at 7 and 

3 percent), emissions reductions, 

industry net present value, life-cycle 

cost, and customers’ installed price 

increases. Beyond the quantitative 

results, DOE also considers other 

burdens and benefits that affect 

economic justification, including how 

technological feasibility, manufacturer 

costs, and impacts on competition may 

affect the economic results presented. 

To aid the reader as DOE discusses 

the benefits and burdens of each trial 

standard level, DOE has included the 

following tables (Table VI.47 and Table 

VI.48) that summarize DOE’s 

quantitative analysis for each TSL. In 

addition to the quantitative results 

presented in the tables, DOE also 

considers other burdens and benefits 

that affect economic justification. 

Section VI.B.1 presents the estimated 

impacts of each TSL for the LCC 

subgroup analysis. 


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TABLE VI.47—SUMMARY OF RESULTS FOR METAL HALIDE LAMP FIXTURES

[Low-shipments scenario] 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

National Energy Savings 

(quads).

0.45 ......................... 0.67 ......................... 0.80 ......................... 0.91 ......................... 1.83 

NPV of Customer Benefits (2012 billion) 

3% discount rate .................... 1.63 ......................... 2.25 ......................... 2.45 ......................... 2.66 ......................... 2.50 

7% discount rate .................... 0.69 ......................... 0.91 ......................... 0.95 ......................... 0.93 ......................... 0.35 

Industry Impacts* 

Ballast + Fixture Industry 

NPV (2012 $ million).

(Base Case Industry NPV of 

$643 million).

620 .......................... 609 .......................... 600 .......................... 595 .......................... 502 

Ballast + Fixture Industry 

NPV (change in 2012$ million).

(23.2) ...................... (34.9) ...................... (43.2) ...................... (48.6) ...................... (141.0) 

Ballast + Fixture Industry 

NPV (% change).

¥3.6% .................... ¥5.4% .................... ¥6.7% .................... ¥7.6% .................... ¥21.9% 

Cumulative Emissions Reduction 

CO2 (Mt) ................................ 27.30 ....................... 40.96 ....................... 48.53 ....................... 55.16 ....................... 110.43 

SO2 (kt) .................................. 36.53 ....................... 54.82 ....................... 64.95 ....................... 73.85 ....................... 147.75 

NOX (kt) ................................. 36.66 ....................... 55.20 ....................... 65.57 ....................... 74.48 ....................... 150.16 

Hg (t) ...................................... 0.06 ......................... 0.09 ......................... 0.11 ......................... 0.12 ......................... 0.24 

CH4 (kt) .................................. 119.79 ..................... 180.18 ..................... 213.76 ..................... 243.04 ..................... 488.01 

N2O (kt) .................................. 0.49 ......................... 0.74 ......................... 0.89 ......................... 1.01 ......................... 2.06 

Value of Cumulative Emissions Reduction 

CO2 (2012$ billion) ** ............. 0.2 to 2.7 ................ 0.3 to 4.0 ................ 0.3 to 4.7 ................ 0.4 to 5.3 ................ 0.7 to 10.6 

NOX—3% discount rate 

(2012$ million) **.

51.6 ......................... 76.8 ......................... 90.6 ......................... 103.0 ....................... 203.2 

NOX—7% discount rate 

(2012$ million) **.

25.9 ......................... 38.1 ......................... 44.6 ......................... 50.8 ......................... 98.1 

Mean LCC Savings (and Percent Customers Experiencing Net Benefit) *** (2012$) 

50to100W_Ind_OtherV ****† 

(magnetic baseline).

32.84 (100) ............. 38.41 (100) ............. 38.41 (100) ............. 38.41 (100) ............. ¥26.16 (72) 

50to100W_Outd_OtherV 

(magnetic baseline).

39.50 (100) ............. 46.44 (100) ............. 46.44 (100) ............. 69.59 (58) ............... 63.77 (57) 

50to100W_Ind_OtherV ..........

(electronic baseline) ..............

................................. ................................. ................................. ................................. ¥8.48 (4) 

50to100W_Outd_OtherV 

(electronic baseline).

................................. ................................. ................................. ................................. ¥5.82 (16) 

100to150W_Ind_OtherV‡ ...... 18.50 (99) ............... 39.68 (100) ............. 10.14 (77) ............... 10.14 (77) ............... 10.14 (77) 

100to150W_Outd_OtherV ..... 20.66 (100) ............. 44.70 (100) ............. 112.51 (74) ............. 112.51 (74) ............. 112.51 (74) 

150to250W_Ind_OtherV‡ ...... 6.55 (64) ................. 13.12 (69) ............... 13.12 (69) ............... 13.12 (69) ............... ¥59.44 (56) 

150to250W_Outd_OtherV ..... 6.73 (80) ................. 13.75 (85) ............... 13.75 (85) ............... 13.75 (85) ............... 46.08 (46) 

250to500W_Ind_OtherV ........ 9.10 (60) ................. 28.23 (82) ............... 28.23 (82) ............... 28.23 (82) ............... ¥99.07 (39) 

250to500W_Outd_OtherV ..... 9.16 (78) ................. 30.47 (93) ............... 30.47 (93) ............... 30.47 (93) ............... 26.49 (37) 

500to2000W_Ind_OtherV ...... 471.20 (100) ........... 502.21 (100) ........... 502.21 (100) ........... 502.21 (100) ........... 502.21 (100) 

500to2000W_Outd_OtherV ... 385.18 (100) ........... 409.02 (100) ........... 409.02 (100) ........... 409.02 (100) ........... 409.02 (100) 

Median PBP (years) 

50to100W_Ind_OtherV (magnetic baseline).0.5 ........................... 4.2 ........................... 4.2 ........................... 4.2 ........................... 5.4 

50to100W_Outd_OtherV 

(magnetic baseline).

0.6 ........................... 4.4 ........................... 4.4 ........................... 12.8 ......................... 14.6 

50to100W_Ind_OtherV (electronic baseline).................................. ................................. ................................. ................................. 32.3 

50to100W_Outd_OtherV 

(electronic baseline).

................................. ................................. ................................. ................................. 44.7 

100to150W_Ind_OtherV‡ ...... 7.2 ........................... 5.8 ........................... 4.7 ........................... 4.7 ........................... 4.7 

100to150W_Outd_OtherV ..... 8.3 ........................... 6.6 ........................... 10.5 ......................... 10.5 ......................... 10.5 

150to250W_Ind_OtherV‡ ...... 12.4 ......................... 11.8 ......................... 11.8 ......................... 11.8 ......................... 11.5 

150to250W_Outd_OtherV ..... 14.8 ......................... 14.0 ......................... 14.0 ......................... 14.0 ......................... 21.4 

250to500W_Ind_OtherV ........ 12.8 ......................... 10.5 ......................... 10.5 ......................... 10.5 ......................... 16.2 


sroberts on DSK5SPTVN1PROD with PROPOSALS
51544 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

TABLE VI.47—SUMMARY OF RESULTS FOR METAL HALIDE LAMP FIXTURES—Continued 

[Low-shipments scenario] 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

250to500W_Outd_OtherV ..... 15.4 ......................... 12.3 ......................... 12.3 ......................... 12.3 ......................... 24.4 

500to2000W_Ind_OtherV ...... 1.8 ........................... 2.0 ........................... 2.0 ........................... 2.0 ........................... 2.0 

500to2000W_Outd_OtherV ... 2.7 ........................... 3.0 ........................... 3.0 ........................... 3.0 ........................... 3.0 

Employment Impacts 

Direct Employment Impacts .. 41–(502) ................. 97–(502) ................. 96–(502) ................. 101–(502) ............... 152–(502) 

Indirect Domestic Jobs Õ ........ 376 .......................... 511 .......................... 791 .......................... 1,091 ....................... 2,336 

* INPV results are shown under the preservation of operating profit markup scenario. 

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of 

NOX reductions is based on estimates at $2,636/ton. 

*** For LCCs, a negative value means an increase in LCC by the amount indicated. 

  ‘‘Indoor’’ and ‘‘outdoor’’ as defined in section V.A.2. 

† Equipment class abbreviations in the form of 50to100W_Ind_OtherV refers to the equipment class of fixtures with (1) a rated lamp wattage of 

50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 480 V. See section V.A.2 for more detail on equipment 

class distinctions. 

‡ The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt 

lamps that are also rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A) and contain a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. The ≥150 W and ≤250 W equipment classes contain all other covered fixtures that are rated only for 150 watt lamps. 

Õ Changes in 2020. 

TABLE VI.48—SUMMARY OF RESULTS FOR METAL HALIDE LAMP FIXTURES

[High-shipments scenario] 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

National Energy Savings 

(quads).

0.59 ......................... 0.90 ......................... 1.08 ......................... 1.22 ......................... 2.53 

NPV of Customer Benefits (2012$ billion) 

3% discount rate .................... 2.10 ......................... 2.93 ......................... 3.22 ......................... 3.48 ......................... 3.40 

7% discount rate .................... 0.84 ......................... 1.12 ......................... 1.18 ......................... 1.15 ......................... 0.48 

Industry Impacts

Ballast + Fixture Industry 

NPV (2012$ million) (Base 

Case Industry NPV of $752 

million).

790 .......................... 820 .......................... 822 .......................... 831 .......................... 900 

Ballast + Fixture Industry 

NPV (change in 2012$ million).

37.8 ......................... 67.3 ......................... 69.2 ......................... 78.3 ......................... 147.9 

Ballast + Fixture Industry 

NPV (% change).

5.0% ........................ 8.9% ........................ 9.2% ........................ 10.4% ...................... 19.7% 

Cumulative Emissions Reduction 

CO2 (Mt) ................................ 35.78 ....................... 54.29 ....................... 64.98 ....................... 73.39 ....................... 151.47 

SO2 (kt) .................................. 47.80 ....................... 72.54 ....................... 86.79 ....................... 98.08 ....................... 202.14 

NOX (kt) ................................. 48.94 ....................... 74.55 ....................... 89.50 ....................... 100.95 ..................... 210.26 

Hg (t) ...................................... 0.08 ......................... 0.12 ......................... 0.15 ......................... 0.16 ......................... 0.34 

CH4 (kt) .................................. 158.30 ..................... 240.80 ..................... 288.54 ..................... 325.92 ..................... 674.79 

N2O (kt) .................................. 0.68 ......................... 1.04 ......................... 1.25 ......................... 1.41 ......................... 2.98 

Value of Cumulative Emissions Reduction 

CO2 (2012$ billion) **  ............. 0.2 to 3.4 ................ 0.4 to 5.1 ................ 0.4 to 6.1 ................ 0.5 to 6.9 ................ 1.0 to 14.1 

NOX—3% discount rate 

(2012$ million) **.

65.0 ......................... 97.8 ......................... 116.3 ....................... 131.7 ....................... 266.4 

NOX—7% discount rate 

(2012$ million) **.

30.9 ......................... 45.8 ......................... 53.9 ......................... 61.2 ......................... 120.3 

Mean LCC Savings (and Percent Customers Experiencing Net Benefit) ** (2012$) 

50to100W_Ind_OtherV **** † 

(magnetic baseline).

32.84 (100) ............. 38.41 (100) ............. 38.41 (100) ............. 38.41 (100) ............. ¥26.16 (72) 

50to100W_Outd_OtherV 

(magnetic baseline).

39.50 (100) ............. 46.44 (100) ............. 46.44 (100) ............. 69.59 (58) ............... 63.77 (57) 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51545 

TABLE VI.48—SUMMARY OF RESULTS FOR METAL HALIDE LAMP FIXTURES—Continued 

[High-shipments scenario] 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

50to100W_Ind_OtherV (electronic baseline).................................. ................................. ................................. ................................. ¥8.48 (4) 

50to100W_Outd_OtherV 

(electronic baseline).

................................. ................................. ................................. ................................. ¥5.82 (16) 

100to150W_Ind_OtherV‡ ...... 18.50 (99) ............... 39.68 (100) ............. 10.14 (77) ............... 10.14 (77) ............... 10.14 (77) 

100to150W_Outd_OtherV ..... 20.66 (100) ............. 44.70 (100) ............. 112.51 (74) ............. 112.51 (74) ............. 112.51 (74) 

150to250W_Ind_OtherV‡ ...... 6.55 (64) ................. 13.12 (69) ............... 13.12 (69) ............... 13.12 (69) ............... ¥59.44 (56) 

150to250W_Outd_OtherV ..... 6.73 (80) ................. 13.75 (85) ............... 13.75 (85) ............... 13.75 (85) ............... 46.08 (46) 

250to500W_Ind_OtherV ........ 9.10 (60) ................. 28.23 (82) ............... 28.23 (82) ............... 28.23 (82) ............... ¥99.07 (39) 

250to500W_Outd_OtherV ..... 9.16 (78) ................. 30.47 (93) ............... 30.47 (93) ............... 30.47 (93) ............... 26.49 (37) 

500to2000W_Ind_OtherV ...... 471.20 (100) ........... 502.21 (100) ........... 502.21 (100) ........... 502.21 (100) ........... 502.21 (100) 

500to2000W_Outd_OtherV ... 385.18 (100) ........... 409.02 (100) ........... 409.02 (100) ........... 409.02 (100) ........... 409.02 (100) 

Median PBP (years) 

50to100W_Ind_OtherV (magnetic baseline).0.5 ........................... 4.2 ........................... 4.2 ........................... 4.2 ........................... 5.4 

50to100W_Outd_OtherV 

(magnetic baseline).

0.6 ........................... 4.4 ........................... 4.4 ........................... 12.8 ......................... 14.6 

50to100W_Ind_OtherV (electronic baseline).................................. ................................. ................................. ................................. 32.3 

50to100W_Outd_OtherV 

(electronic baseline).

................................. ................................. ................................. ................................. 44.7 

100to150W_Ind_OtherV‡ ...... 7.2 ........................... 5.8 ........................... 4.7 ........................... 4.7 ........................... 4.7 

100to150W_Outd_OtherV ..... 8.3 ........................... 6.6 ........................... 10.5 ......................... 10.5 ......................... 10.5 

150to250W_Ind_OtherV‡ ...... 12.4 ......................... 11.8 ......................... 11.8 ......................... 11.8 ......................... 11.5 

150to250W_Outd_OtherV ..... 14.8 ......................... 14.0 ......................... 14.0 ......................... 14.0 ......................... 21.4 

250to500W_Ind_OtherV ........ 12.8 ......................... 10.5 ......................... 10.5 ......................... 10.5 ......................... 16.2 

250to500W_Outd_OtherV ..... 15.4 ......................... 12.3 ......................... 12.3 ......................... 12.3 ......................... 24.4 

500to2000W_Ind_OtherV ...... 1.8 ........................... 2.0 ........................... 2.0 ........................... 2.0 ........................... 2.0 

500to2000W_Outd_OtherV ... 2.7 ........................... 3.0 ........................... 3.0 ........................... 3.0 ........................... 3.0 

Employment Impacts 

Direct Employment Impacts .. 41–(508) ................. 98–(508) ................. 97–(508) ................. 102–(508) ............... 154–(508) 

Indirect Domestic Jobs √√ ..... 392 .......................... 530 .......................... 827 .......................... 1,142 ....................... 2,445 

* INPV results are shown under the -flat markup scenario. 

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. Economic value of 

NOX reductions is based on estimates at $2,636/ton. 

*** For LCCs, a negative value means an increase in LCC by the amount indicated. 

  ‘‘Indoor’’ and ‘‘outdoor’’ as defined in section V.A.2. 

† Equipment class abbreviations in the form of 50to100W_Ind_OtherV refers to the equipment class of fixtures with (1) a rated lamp wattage of 

50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 480 V. See section V.A.2 for more detail on equipment 

class distinctions. 

‡ The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt 

lamps that are also rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A) and contain a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. The ≥150 W and ≤250 W equipment classes contain all other covered fixtures that are rated only for 150 watt lamps. 

Õ Changes in 2020. 

As discussed in previous DOE 

standards rulemakings and the February 

2011 NODA (76 FR 9696, (Feb. 22, 

2011)), DOE also notes that the 

economics literature provides a wideranging discussion of how customers 

trade off upfront costs and energy 

savings in the absence of government 

intervention. Much of this economics 

literature attempts to explain why 

customers appear to undervalue energy 

efficiency improvements. 

This undervaluation suggests that 

regulation promoting energy efficiency 

can produce significant net private gains 

(as well as producing social gains by, for 

example, reducing pollution). There is 

evidence that customers undervalue 

future energy savings as a result of (1) 

a lack of information, (2) a lack of 

sufficient savings to warrant 

accelerating or altering purchases (e.g., 

an inefficient ventilation fan in a new 

building or the delayed replacement of 

a water pump), (3) inconsistent 

weighting of future energy cost savings 

relative to available returns on other 

investments, (4) computational or other 

difficulties associated with the 

evaluation of relevant tradeoffs, and (5) 

a divergence in incentives (e.g., renter 

versus owner; builder vs. purchaser). 

Other literature indicates that with lessthan-perfect foresight and a high degree 

of uncertainty about the future, it may 

be rational for customers to trade off 

these types of investments at a higherthan-expected rate between current 

consumption and uncertain future 

energy cost savings. Some studies 

suggest that this seeming 

undervaluation may be explained in 

certain circumstances by differences 

between tested and actual energy 

savings, or by uncertainty and 

irreversibility of energy investments. 

There may also be ‘‘hidden’’ welfare 

losses to customers if newer energy 

efficient products are imperfect 

substitutes for the less efficient products 

they replace, in terms of performance or 

other attributes that customers value. In 

the abstract, it may be difficult to say 

how a welfare gain from correcting 


sroberts on DSK5SPTVN1PROD with PROPOSALS
51546 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

59A good review of the literature related to this 

issue can be found in Gillingham, K., R. Newell, K. 

Palmer. (2009). ‘‘Energy Efficiency Economics and 

Policy,’’ Annual Review of Resource Economics, 1: 

597–619; and Tietenberg, T. (2009). ‘‘Energy 

Efficiency Policy: Pipe Dream or Pipeline to the 

Future?’’ Review of Environmental Economics and 

Policy. Vol. 3, No. 2: 304–320. 60A draft paper, ‘‘Notes on the Economics of 

Household Energy Consumption and Technology 

Choice,’’ proposes a broad theoretical framework on 

which an empirical model might be based and is 

posted on the DOE Web site along with this notice 

at www.eere.energy.gov/buildings/appliance_

standards. 

potential under-investment in energy 

conservation compares in magnitude to 

the potential welfare losses associated 

with no longer purchasing a machine or 

switching to an imperfect substitute, 

both of which still exist in this 

framework. 

The mix of evidence in the empirical 

economics literature suggests that if 

feasible, analysis of regulations 

mandating energy-efficiency 

improvements should explore the 

potential for both welfare gains and 

losses and move toward a fuller 

economic framework where all relevant 

changes can be quantified.59 While DOE 

is not prepared at present to provide a 

fuller quantifiable framework for this 

discussion, DOE seeks comments on 

how to assess these possibilities.60 In 

particular, DOE requests comment on 

whether there are features or attributes 

of the more energy efficient ballasts that 

manufacturers would produce to meet 

the standards in this proposed rule that 

might affect the welfare, positively or 

negatively, of consumers who purchase 

MHLFs. One example of such an effect 

might result from the use of electronic 

ballasts in outdoor applications, which 

DOE’s analysis models for compliance 

with TSL3 for 150 watt fixtures. In 

TSL4, electronic ballasts are also 

modeled for outdoor applications for 70 

watt fixtures. As discussed above, 

currently magnetic ballasts are generally 

favored over electronic ballasts for 

outdoor applications, but there are some 

commercially available fixtures using 

electronic ballasts that are designed for 

outdoor applications. DOE requests 

comment specifically on whether the 

more widespread use of electronic 

ballasts would involve any performance 

or reliability effects for either 70-watt or 

150-watt fixtures, and how any such 

effects should be weighed in the choice 

of standards for these two wattage 

categories for the final rule. 

1. Trial Standard Level 5 

DOE first considered the most 

efficient level, TSL 5, which would save 

an estimated total of 1.8 to 2.5 quads of 

energy for fixtures shipped in 2016– 

2045—a significant amount of energy. 

For the nation as a whole, TSL 5 would 

have a net savings of $0.35 billion–$0.48 

billion at a 7-percent discount rate, and 

$2.5 billion–$3.4 billion at a 3-percent 

discount rate. The emissions reductions 

at TSL 5 are estimated to be 110–151 

million metric tons (Mt) of CO2, 148– 

202 kt of SO2, 150–210 kt of NOX, and 

0.24–0.34 tons of Hg. As seen in section 

VI.B.1, for over half of the representative 

equipment classes, customers have 

available designs that result in positive 

mean LCC savings, ranging from 

$10.14–$502.21, at TSL 5. The 

equipment classes with positive mean 

LCC savings at TSL 5 are outdoor 70 W 

fixtures 56 (for the magnetic ballast 

baseline), indoor and outdoor 150 W 

fixtures, outdoor 250 W fixtures, 

outdoor 400 W fixtures, and indoor and 

outdoor 1000 W fixtures. However, 

DOE’s NPV analysis indicates (see Table 

VI.38) that most equipment classes 

experience a negative NPV at TSL 5. 

The equipment classes that have 

negative NPV at TSL 5 are indoor and 

outdoor 70 W, 250 W, and 400 W 

fixtures. The equipment classes with 

positive NPV at TSL 5 are indoor and 

outdoor 150 W and 1000 W fixtures. 

The projected change in industry value 

for metal halide ballast manufacturers 

would range from an increase of $36.5 

million to a decrease of $24.1 million, 

or a net gain of 29.8 percent to a net loss 

of 23.3 percent in INPV. The projected 

change in industry value for metal 

halide lamp fixture manufacturers 

would range from an increase of $111.3 

million to a decrease of $116.9 million, 

or a net gain of 17.7 percent to a net loss 

of 21.6 percent in INPV. 

DOE based TSL 5 on the most 

efficient commercially available 

equipment for each representative 

equipment class analyzed. This TSL 

corresponds to a commercially available 

low-frequency electronic ballast for 

indoor and outdoor 70 W, 150 W, 250 

W fixtures, a commercially available 

high-frequency electronic ballast for 

indoor and outdoor 400 W fixtures, and 

a commercially available magnetic 

ballast in 1000 W fixtures. DOE notes 

that there is limited compatibility 

between the high-frequency electronic 

ballasts required for indoor and outdoor 

400W fixtures and high efficiency CMH 

lamps. This could potentially limit 

energy savings opportunities through 

the use of CMH lamps. See section V.C.8 

for additional detail. TSL 5 also 

prohibits the use of probe-start ballasts 

in new 1000 W fixtures. 

After considering the analysis, the 

comments that DOE received on the 

preliminary analysis, and the benefits 

and burdens of TSL 5, the Secretary has 

reached the following tentative 

conclusion: The benefits of energy 

savings, emissions reductions (both in 

physical reductions and the monetized 

value of those reductions), and positive 

net economic savings to the nation are 

outweighed by negative NPV 

experienced in some equipment classes 

at both a 3-percent and 7-percent 

discount rate, the negative mean LCC 

savings experienced in some equipment 

classes, and the potential decrease in 

INPV for manufacturers. Consequently, 

the Secretary has tentatively concluded 

that trial standard level 5 is not 

economically justified. 

2. Trial Standard Level 4 

DOE then considered TSL 4, which 

would save an estimated total of 0.91 to 

1.2 quads of energy for fixtures shipped 

in 2016–2045—a significant amount of 

energy. For the nation as a whole, TSL 

4 would have a net savings of $0.93 

billion–$1.2 billion at a 7-percent 

discount rate, and $2.7 billion–$3.5 

billion at a 3-percent discount rate. The 

emissions reductions at TSL 4 are 

estimated to be 55–73 Mt of CO2, 74–98 

kt of SO2, 74–101 kt of NOX, and 0.12– 

0.16 tons of Hg. As seen in section 

VI.B.1, for all representative equipment 

classes, customers have available 

designs that result in positive mean LCC 

savings, ranging from $10.14–$502.21, 

at TSL 4. DOE’s NPV analysis indicates 

(see Table VI.38) that each equipment 

class has a positive NPV at TSL 4. The 

projected change in industry value for 

metal halide ballast manufacturers 

would range from an increase of $4.7 

million to a decrease of $24.8 million, 

or a net gain of 3.8 percent to a net loss 

of 24.0 percent in INPV. The projected 

change in industry value for metal 

halide lamp fixture manufacturers 

would range from an increase of $73.6 

million to a decrease of $23.8 million, 

or a net gain of 11.7 percent to a net loss 

of 4.4 percent in INPV. 

TSL 4 represents the maximum 

energy savings achievable with positive 

NPV for each representative equipment 

class, considering indoor and outdoor 

fixtures separately. This TSL 

corresponds to a modeled magnetic 

ballast in indoor 70 W fixtures, indoor 

and outdoor 250 W fixtures and indoor 

and outdoor 400 W fixtures; a 

commercially available low-frequency 

electronic ballast in outdoor 70 W 

fixtures and indoor and outdoor 150 W 

fixtures; and a commercially available 

magnetic ballast in indoor and outdoor 

1000 W fixtures. TSL 4 sets different 

standards for 70 W fixtures for the 

indoor versus outdoor equipment 

classes. TSL 4 also prohibits the use of 

probe-start ballasts in new 1000 W 

fixtures. 


sroberts on DSK5SPTVN1PROD with PROPOSALS
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51547 

61This wattage range contains those fixtures that 

are rated only for 150 watt lamps that are also rated 

for use in wet locations, as specified by the National 

Electrical Code 2002, section 410.4(A); and contain 

a ballast that is rated to operate at ambient air 

temperatures above 50 °C, as specified by UL 1029– 

2001. 

Setting different standards for the 

indoor versus outdoor fixtures of the 

same wattage has the potential for 

certification issues and lost energy 

savings. Indoor 70 W fixtures require 

EL2 magnetic ballasts while outdoor 70 

W fixtures require electronic ballasts. 

Because the indoor magnetic ballast can 

provide the features necessary for 

outdoor operation, there is potential for 

indoor fixtures to be used outdoors in 

applications where moisture is a smaller 

concern. For example, a parking garage 

or other semi-covered structure is less 

likely to sustain direct water contact. 

Additionally, the indoor EL2 

magnetically ballasted fixtures are less 

expensive than the outdoor EL3 

electronically ballasted fixtures. This 

creates an economic incentive for 

outdoor customers to use the indoor EL2 

fixtures. This substitution could 

decrease the expected energy savings, 

and could reduce the reliability and 

lifetime of the misapplied indoor 

fixtures. Furthermore, setting different 

standards for indoor versus outdoor 

equipment classes increases 

compliance, certification, and 

enforcement costs for manufacturers. 

Fixture manufacturers would use 

different ballasts for indoor and outdoor 

fixtures of the same wattage, 

complicating fixture-ballast matching 

and increasing the number of basic 

models. 

After considering the analysis, the 

comments that DOE received on the 

preliminary analysis, and the benefits 

and burdens of TSL 4, the Secretary has 

reached the following tentative 

conclusion: At TSL 4, the benefits of 

energy savings, emissions reductions 

(both in physical reductions and the 

monetized value of those reductions), 

and positive net economic savings to the 

nation would be outweighed by the 

potential for certification issues and lost 

energy savings resulting from setting 

different standards for the indoor versus 

outdoor fixtures of the same wattage, 

and the potential decrease in INPV for 

manufacturers. Consequently, the 

Secretary has tentatively concluded that 

trial standard level 4 is not 

economically justified. 

3. Trial Standard Level 3 

DOE then considered TSL 3, which 

would save an estimated total of 0.80 to 

1.1 quads of energy for fixtures shipped 

in 2016–2045—a significant amount of 

energy. For the nation as a whole, TSL 

3 would have a net savings of $0.95 

billion–$1.2 billion at a 7-percent 

discount rate, and $2.5 billion–$3.2 

billion at a 3-percent discount rate. The 

emissions reductions at TSL 3 are 

estimated to be 49–65 Mt of CO2, 

approximately 65–87 kt of SO2, 66–90 kt 

of NOX, and 0.11–0.15 tons of Hg. As 

seen in section VI.B.1, for all 

representative equipment classes, 

customers have available designs that 

result in positive mean LCC savings, 

ranging from $10.14–$502.21, at TSL 3. 

DOE’s NPV analysis indicates (see Table 

VI.38) that each equipment class has a 

positive NPV at TSL 3. The projected 

change in industry value for metal 

halide ballast manufacturers would 

range from an increase of $4.5 million 

to a decrease of $25.9 million, or a net 

gain of 3.7 percent to a net loss of 25.0 

percent in INPV. The projected change 

in industry value for metal halide lamp 

fixture manufacturers would range from 

an increase of $64.8 million to a 

decrease of $17.3 million, or a net gain 

of 10.3 percent to a net loss of 3.2 

percent in INPV. 

TSL 3 represents the maximum 

positive NPV (when comparing the total 

NPV associated with TSL 3 to all other 

TSLs) and sets the same efficiency 

levels for fixtures operating indoors and 

outdoors be analyzed. This TSL 

corresponds to a modeled magnetic 

ballast in 70 W, 250 W, and 400 W 

fixtures; a commercially available lowfrequency electronic ballast in 150 W 

fixtures; and a commercially available 

magnetic ballast in 1000 W fixtures. TSL 

3 also prohibits the use of probe-start 

ballasts in new 1000 W fixtures. 

Because the 150 W fixtures are subject 

to a more stringent standard (EL4, max 

tech) than other equipment classes 

(EL2), there is potential for customers to 

switch to the higher wattage fixtures to 

avoid the more stringent standards. This 

customer behavior could reduce the 

energy savings associated with TSL 3. 

After considering the analysis, the 

comments that DOE received on the 

preliminary analysis, and the benefits 

and burdens of TSL 3, the Secretary has 

reached the following tentative 

conclusion: TSL 3 offers the maximum 

improvement in efficiency that is 

technologically feasible and 

economically justified, and will result 

in significant conservation of energy. 

The benefits of energy savings, 

emissions reductions (both in physical 

reductions and the monetized value of 

those reductions), positive net economic 

savings (NPV) at discount rates of 3- 

percent and 7-percent at each 

representative equipment class would 

outweigh the potential reduction in 

INPV for manufacturers. Therefore, DOE 

today proposes to adopt energy 

conservation standards for metal halide 

lamp fixtures at TSL 3. DOE seeks 

comment on its proposal of adopting 

energy conservation standards for metal 

halide lamp fixtures at TSL 3. DOE will 

consider the comments and information 

received in determining the final energy 

conservation standards. 

D. Backsliding 

As discussed in section II.A, EPCA 

contains what is commonly known as 

an ‘‘anti-backsliding’’ provision, which 

mandates that the Secretary not 

prescribe any amended standard that 

either increases the maximum allowable 

energy use or decreases the minimum 

required energy efficiency of a covered 

product. (42 U.S.C. 6295(o)(1)) DOE is 

evaluating amended standards in terms 

of ballast efficiency, which is the same 

metric that is currently used in energy 

conservation standards. Therefore, DOE 

compared the existing standards to the 

proposed amendments to confirm that 

none of the proposals constituted 

backsliding. 

The existing standards for ballast 

efficiency for metal halide lamp 

fixtures, set by EISA 2007, mandated 

that ballasts rated at wattages ≥150 W 

and ≤500 W operate at a minimum of 88 

percent efficiency if pulse-start, 94 

percent if probe-start magnetic, 90 

percent if nonpulse-start electronic ≥150 

W and ≤250 W, and 92 percent if 

nonpulse-start electronic >250 W and 

≤500 W. These standards excluded 

fixtures with regulated-lag ballasts, 

fixtures that use 480 V electronic 

ballasts, and fixtures that (1) are only 

rated for use with 150 W lamps; (2) are 

rated for use in wet locations; and (3) 

contain a ballast that is rated to operate 

above 50 °C. This rulemaking is 

proposing to cover fixtures with ballasts 

rated at ≥50 W and ≤2000 W, retain the 

exemptions for fixtures with regulated 

lag ballasts or 480 V electronic ballasts, 

and remove the exemption for 150 W 

fixtures used in wet locations with 

ballasts rated that operate above 50 °C. 

As presented in the following table, 

DOE is not proposing any efficiency 

standards that would qualify as 

backsliding. In the ≥50 W and <150 W61

range, there are no existing federal 

efficiency standards. Thus, any standard 

set by DOE in this rulemaking would 

not be backsliding, as it would be 

prescribing a standard where there 

previously was not one. The 150 W 

ballasts currently exempt by EISA (those 

only rated for use with 150 W lamps, 

rated for wet locations, and rated to 

operate at temperatures greater than 50 

°C) are not covered by any existing 


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62This wattage range contains all covered fixtures 

that are rated only for 150 watt lamps that are not 

also rated for use in wet locations, as specified by 

the National Electrical Code 2002, section 410.4(A); 

and do not also contain a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as 

specified by UL 1029–2001. 

federal energy conservation standards, 

so amended standards set for such 

ballasts would likewise not be subject to 

backsliding. Similarly, in the >500 W 

and ≤2000 W range, there are no 

existing federal energy conservation 

standards, so standards proposed in this 

rulemaking would not backslide. Finally 

for the ≥150 W62 and ≤500 W range (not 

including the exempt 150 W fixtures), 

EISA currently prescribes standards. 

DOE is also proposing standards for 

fixtures in this wattage range. The 

proposed standard changes with 

wattage, but always requires ballasts in 

new fixtures to be at least 88 percent 

efficient (88 percent efficiency for pulsestart ballasts is the least stringent of the 

various EISA 2007 requirements). If the 

efficiency standard proposed by DOE is 

lower than the standard prescribed by 

EISA for any ballast types or wattages 

(e.g., 94 percent efficiency requirement 

for probe-start ballasts), then the EISA 

standard will take precedence and 

prevent any potential backsliding. 

On the basis of this section, the 

standards proposed in this NOPR are 

either higher than the existing 

standards, primarily because they set 

standards for previously unregulated 

fixtures, or if the EISA standards are 

higher than those proposed in this 

NOPR then the EISA standard is given 

precedence. As such, the proposed 

standards do not decrease the minimum 

required energy efficiency of the 

covered equipment and, therefore, do 

not violate the anti-backsliding 

provision in EPCA. 

TABLE VI.49—EXISTING FEDERAL EFFICIENCY STANDARDS AND PROPOSED EFFICIENCY STANDARDS

Rated lamp wattage Indoor/ 

outdoor ** * 

Test input 

voltage ‡

Existing 

standards 

(efficiency) 

Proposed efficiency standards/equations 

% 

≥50 W and ≤100 W ................................... Indoor ...... 480 V ....... N/A ............................ 99.4/(1+2.5*P∧(¥0.55)) †. 

≥50 W and ≤100 W ................................... Indoor ...... All others N/A ............................ 100/(1+2.5*P∧(¥0.55)). 

≥50 W and ≤100 W ................................... Outdoor .... 480 V ....... N/A ............................ 99.4/(1+2.5*P∧(¥0.55)). 

≥50 W and ≤100 W ................................... Outdoor .... All others N/A ............................ 100/(1+2.5*P∧(¥0.55)). 

>100 W and <150 W * ............................... Indoor ...... 480 V ....... N/A ............................ 99.4/(1+0.36*P∧(¥0.30)). 

>100 W and <150 W * ............................... Indoor ...... All others N/A ............................ 100/(1+0.36*P∧(¥0.30)). 

>100 W and <150 W * ............................... Outdoor .... 480 V ....... N/A ............................ 99.4/(1+0.36*P∧(¥0.30)). 

>100 W and <150 W * ............................... Outdoor .... All others N/A ............................ 100/(1+0.36*P∧(¥0.30)). 

≥150 W ** and ≤250 W .............................. Indoor ...... 480 V ....... Varies from 88% to 

94% depending on 

ballast type.

For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 6.0*10∧(¥2)*P + 

76.0. 

≥150 W ** and ≤250 W .............................. Indoor ...... All others Varies from 88% to 

94% depending on 

ballast type.

For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 7.0*10∧(¥2)*P + 

74.0. 

≥150 W ** and ≤250 W .............................. Outdoor .... 480 V ....... Varies from 88% to 

94% depending on 

ballast type.

For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 6.0*10∧(¥2)*P + 

76.0. 

≥150 W ** and ≤250 W .............................. Outdoor .... All others Varies from 88% to 

94% depending on 

ballast type.

For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 7.0*10∧(¥2)*P + 

74.0. 

>250 W and ≤500 W ................................. Indoor ...... 480 V ....... Varies from 88% to 

94% depending on 

ballast type.

91.0. 

>250 W and ≤500 W ................................. Indoor ...... All others Varies from 88% to 

94% depending on 

ballast type.

91.5. 

>250 W and ≤500 W ................................. Outdoor ... 480 V ....... Varies from 88% to 

94% depending on 

ballast type.

91.0. 

>250 W and ≤500 W ................................. Outdoor ... All others Varies from 88% to 

94% depending on 

ballast type.

91.5. 

>500 W and ≤2000 W ............................... Indoor ...... 480 V ....... N/A ............................ For >500 W to <1000 W: 0.994*(3.2*10∧(¥3)*P 

+ 89.9). 

For ≥1000 W to ≤2000 W: 92.5. 

>500 W and ≤2000 W ............................... Indoor ...... All others N/A ............................ For >500 W to <1000 W: 3.2*10∧(¥3)*P + 89.9. 

For ≥1000 W to ≤2000 W: 93.1. 

>500 W and ≤2000 W ............................... Outdoor .... 480 V ....... N/A ............................ For >500 W to <1000 W: 0.994*(3.2*10∧(¥3)*P 

+ 89.9). 

For ≥1000 W to ≤2000 W: 92.5. 

>500 W and ≤2000 W ............................... Outdoor .... All others N/A ............................ For >500 W to <1000 W: 3.2*10∧(¥3)*P + 89.9. 

For ≥1000 W to ≤2000 W: 93.1. 

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified 

by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, 

as specified by UL 1029–2001. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 

50 °C, as specified by UL 1029–2001. 

*** DOE’s proposed definitions for ‘‘indoor’’ and ‘‘outdoor’’ metal halide lamp fixtures are described in section V.A.2. 

† P is defined as the rated wattage of the lamp the fixture is designed to operate. 


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‡ Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 120 

V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these voltages would be 

tested at the highest voltage the ballast is designed to operate. 

VII. Procedural Issues and Regulatory 

Review 

A. Review Under Executive Orders 

12866 and 13563 

Section 1(b)(1) of E.O. 12866, 

‘‘Regulatory Planning and Review,’’ 58 

FR 51735 (Oct. 4, 1993), requires each 

agency to identify the problem that it 

intends to address, including, where 

applicable, the failures of private 

markets or public institutions that 

warrant new agency action, as well as to 

assess the significance of that problem. 

The problems addressed by today’s 

standards are as follows: 

(1) There is a lack of customer 

information and/or informationprocessing capability about energyefficiency opportunities in the 

commercial equipment market. 

(2) There is asymmetric information 

(one party to a transaction has more and 

better information than the other) and/ 

or high transaction costs (costs of 

gathering information and affecting 

exchanges of goods and services). 

(3) There are external benefits 

resulting from improved energy 

efficiency of metal halide lamp fixtures 

that are not captured by the users of 

such equipment. These benefits include 

externalities related to environmental 

protection and energy security that are 

not reflected in energy prices, such as 

reduced emissions of greenhouse gases. 

In addition, DOE has determined that 

today’s regulatory action is an 

‘‘economically significant regulatory 

action’’ under section 3(f)(1) of E.O. 

12866. Accordingly, section 6(a)(3) of 

the E.O. requires that DOE prepare a 

regulatory impact analysis (RIA) on 

today’s proposed rule and that the 

Office of Information and Regulatory 

Affairs (OIRA) in the Office of 

Management and Budget (OMB) review 

this proposed rule. DOE presented to 

OIRA for review the draft rule and other 

documents prepared for this 

rulemaking, including the RIA, and has 

included these documents in the 

rulemaking record. The assessments 

prepared pursuant to E.O. 12866 can be 

found in the technical support 

document for this rulemaking. 

DOE has also reviewed this regulation 

pursuant to E.O. 13563, issued on 

January 18, 2011 (76 FR 3281 (Jan. 21, 

2011)). E.O. 13563 is supplemental to 

and explicitly reaffirms the principles, 

structures, and definitions governing 

regulatory review established in E.O. 

12866. To the extent permitted by law, 

agencies are required by E.O. 13563 to: 

(1) Propose or adopt a regulation only 

upon a reasoned determination that its 

benefits justify its costs (recognizing 

that some benefits and costs are difficult 

to quantify); (2) tailor regulations to 

impose the least burden on society, 

consistent with obtaining regulatory 

objectives, taking into account, among 

other things, and to the extent 

practicable, the costs of cumulative 

regulations; (3) select, in choosing 

among alternative regulatory 

approaches, those approaches that 

maximize net benefits (including 

potential economic, environmental, 

public health and safety, and other 

advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify 

performance objectives, rather than 

specifying the behavior or manner of 

compliance that regulated entities must 

adopt; and (5) identify and assess 

available alternatives to direct 

regulation, including providing 

economic incentives to encourage the 

desired behavior, such as user fees or 

marketable permits, or providing 

information upon which choices can be 

made by the public. 

DOE emphasizes, as well, that E.O. 

13563 requires agencies to use the best 

available techniques to quantify 

anticipated present and future benefits 

and costs as accurately as possible. In its 

guidance, OIRA has emphasized that 

such techniques may include 

identifying changing future compliance 

costs that might result from 

technological innovation or anticipated 

behavioral changes. For the reasons 

stated in the preamble, DOE believes 

that today’s NOPR is consistent with 

these principles, including the 

requirements that, to the extent 

permitted by law, benefits justify costs 

and net benefits are maximized. 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis (IRFA) for any 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. As 

required by E. O. 13272, ‘‘Proper 

Consideration of Small Entities in 

Agency Rulemaking,’’ (67 FR 53461 

(Aug. 16, 2002)), DOE published 

procedures and policies on February 19, 

2003, to ensure that the potential 

impacts of its rules on small entities are 

properly considered during the 

rulemaking process. (68 FR 7990) DOE 

has made its procedures and policies 

available on the Office of the General 

Counsel’s Web site (http://energy.gov/

gc/office-general-counsel). DOE 

reviewed the potential standard levels 

considered in today’s NOPR under the 

provisions of the Regulatory Flexibility 

Act and the procedures and policies 

published on February 19, 2003. 

As a result of this review, DOE has 

prepared an IRFA for metal halide 

ballasts and metal halide lamp fixtures, 

a copy of which DOE will transmit to 

the Chief Counsel for Advocacy of the 

SBA for review under 5 U.S.C 605(b). As 

presented and discussed below, the 

IRFA describes potential impacts on 

small metal halide ballast and metal 

halide lamp fixture manufacturers and 

discusses alternatives that could 

minimize these impacts. 

A statement of the reasons for the 

proposed rule, and the objectives of and 

legal basis for the proposed rule, are set 

forth elsewhere in the preamble and not 

repeated here. 

1. Description and Estimated Number of 

Small Entities Regulated 

a. Methodology for Estimating the 

Number of Small Entities 

For manufacturers of metal halide 

ballasts and metal halide lamp fixtures, 

the SBA has set a size threshold which 

defines those entities classified as 

‘‘small businesses’’ for the purposes of 

the statute. DOE used the SBA’s small 

business size standards to determine 

whether any small entities would be 

subject to the requirements of the rule. 

(65 FR 30836, 30850 (May 15, 2000), as 

amended at 65 FR 53533, 53545 (Sept. 

5, 2000) and codified at 13 CFR part 

121). The size standards are listed by 

North American Industry Classification 

System (NAICS) code and industry 

description and are available at http:// 

www.sba.gov/sites/default/files/files/

Size_Standards_Table.pdf. Metal halide 

ballast manufacturing is classified under 

NAICS 335311, ‘‘Power, Distribution 

and Specialty Transformer 

Manufacturing.’’ The SBA sets a 

threshold of 750 employees or less for 

an entity to be considered as a small 

business for this category. Metal halide 

lamp fixture manufacturing is classified 

under NAICS 335122, ‘‘Commercial, 

Industrial, and Institutional Electric 

Lighting Fixture Manufacturing.’’ The 

SBA sets a threshold of 500 employees 


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or less for an entity to be considered as 

a small business for this category. 

To estimate the number of companies 

that could be small business 

manufacturers of equipment covered by 

this rulemaking, DOE conducted a 

market survey using all available public 

information to identify potential small 

manufacturers. DOE’s research involved 

industry trade association membership 

directories (including NEMA), 

individual company Web sites, and 

market research tools (e.g., Dun and 

Bradstreet reports and Hoovers reports) 

to create a list of every company that 

manufactures or sells metal halide 

ballasts or metal halide lamp fixtures 

covered by this rulemaking. DOE also 

asked stakeholders and industry 

representatives if they were aware of 

any other small manufacturers during 

manufacturer interviews and at previous 

DOE public meetings. DOE contacted 

companies on its list, as necessary, to 

determine whether they met the SBA’s 

definition of a small business 

manufacturer of covered equipment. 

DOE screened out companies that did 

not offer equipment covered by this 

rulemaking, did not meet the definition 

of a ‘‘small business,’’ or were foreign 

owned and operated. 

DOE initially identified at least 25 

potential manufacturers of metal halide 

ballasts sold in the U.S. DOE reviewed 

publicly available information on these 

25 potential manufacturers and 

determined that 13 were either large 

manufacturers, manufacturers that were 

foreign owned and operated, or did not 

manufacture ballasts covered by this 

rulemaking. DOE then attempted to 

contact the remaining 12 companies that 

were potential small business 

manufacturers. DOE was able to 

determine that five companies meet the 

SBA’s definition of a small business and 

likely manufacture ballasts covered by 

this rulemaking. 

For metal halide lamp fixtures sold in 

the U.S., DOE initially identified at least 

134 potential manufacturers. DOE 

reviewed publicly available information 

on these 134 potential manufacturers 

and determined that 66 were large 

manufacturers, manufacturers that were 

foreign owned and operated, or did not 

sell fixtures covered by this rulemaking. 

DOE then attempted to contact the 

remaining 68 companies that were 

potential small business manufacturers. 

Though many companies were 

unresponsive, DOE was able to 

determine that approximately 54 meet 

the SBA’s definition of a small business 

and likely manufacture fixtures covered 

by this rulemaking. 

NEMA stated that small 

manufacturers may be significantly 

burdened by energy conservation 

standards because they have limited 

resources at their disposal to redesign 

products. (NEMA, No. 34 at p. 16) DOE 

agrees that there is potential for small 

manufacturers to be disproportionately 

burdened by regulations and outlines its 

conclusions on the potential impacts of 

standards on small businesses in the 

sections that follow. 

b. Manufacturer Participation 

Before issuing this NOPR, DOE 

attempted to contact the small business 

manufacturers of metal halide ballasts 

and metal halide lamp fixtures it had 

identified. One small ballast 

manufacturer and two small fixture 

manufacturers consented to being 

interviewed. DOE also obtained 

information about small business 

impacts while interviewing large 

manufacturers. 

c. Metal Halide Ballast and Fixture 

Industry Structure 

Ballasts. Five major ballast 

manufacturers with limited domestic 

production supply the vast majority of 

the metal halide ballast market. None of 

the five major manufacturers is a small 

business. The remaining market share is 

held by a few smaller domestic 

companies, only one of which has 

significant market share. Nearly all 

metal halide ballast production occurs 

abroad. 

Fixtures. The majority of the metal 

halide lamp fixture market is supplied 

by six major manufacturers with 

sizeable domestic production. None of 

these major manufacturers is a small 

business. The remaining market share is 

held by several smaller domestic and 

foreign manufacturers. Most of the small 

domestic manufacturers produce 

fixtures in the U.S. Although none of 

the small businesses holds a significant 

market share individually, collectively 

these small businesses account for a 

third of the market. See chapter 3 of the 

NOPR TSD for further details on the 

metal halide ballast and metal halide 

lamp fixture markets. 

d. Comparison Between Large and Small 

Entities 

Ballasts. The five large ballast 

manufacturers typically offer a much 

wider range of designs of metal halide 

ballasts than small manufacturers do. 

Ballasts can vary by start method, input 

voltage, wattage, and design. Often large 

ballast manufacturers will offer several 

different ballast options for each lamp 

wattage. Small manufacturers generally 

specialize in manufacturing only a 

handful of different ballast types and do 

not have the volume to support as wide 

a range of products as large 

manufacturers do. Three of the five 

small ballast manufacturers specialize 

in high-efficiency electronic ballasts and 

do not offer any magnetic ballasts. Some 

small ballast manufacturers offer a wide 

variety of lighting products, but others 

focus exclusively on metal halide 

ballasts. 

Fixtures. The six large fixture 

manufacturers typically serve largescale commercial lighting markets, 

while small fixture manufacturers tend 

to operate in niche lighting markets 

such as architectural and designer 

lighting. Small fixture manufacturers 

also frequently fill custom orders that 

are much smaller in volume than large 

fixture manufacturers’ typical orders 

are. Because small manufacturers 

typically offer specialized products and 

cater to individual customers’ needs, 

they can command higher markups than 

most large manufacturers. Like large 

ballast manufacturers, large fixture 

manufacturers offer a wider range of 

metal halide lamp fixtures than small 

fixture manufacturers. A small fixture 

manufacturer may offer fewer than 50 

models, while a large manufacturer may 

typically offer several hundred models. 

Almost all small fixture manufacturers 

offer a variety of lighting products in 

addition to those covered by this 

rulemaking, such as fluorescent, 

incandescent, and LED fixtures. 

2. Description and Estimate of 

Compliance Requirements 

Ballasts. Because three of the five 

small metal halide ballast manufacturers 

offer only electronic ballasts that 

already meet the standards at TSL 3, the 

level proposed in today’s notice, DOE 

does not expect any product or capital 

conversion costs for these small ballast 

manufacturers. The fourth small ballast 

manufacturer offers a wide range of 

magnetic and electronic ballasts, so DOE 

does not expect this manufacturer’s 

conversion costs to differ significantly 

from those of the large manufacturers. 

The fifth small ballast manufacturer 

currently offers a large variety of 

lighting products, but only two models 

of metal halide ballasts. Because it 

would likely invest in other parts of its 

business, this manufacturer stated to 

DOE that this rulemaking is unlikely to 

significantly affect it. 

Fixtures. As stated above, DOE 

identified approximately 54 small metal 

halide lamp fixture businesses affected 

by this rulemaking. Based on interviews 

with two of these manufacturers and 

examinations of product offerings on 

company Web sites, DOE believes that 

approximately one-fourth of these small 

businesses will not face any conversion 


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costs because they offer very few metal 

halide lamp fixture models and would, 

therefore, focus on more substantial 

areas of their business. Of the remaining 

small businesses DOE identified, nearly 

two-thirds primarily serve the 

architectural or specialty lighting 

markets. Because these products 

command higher prices and margins 

compared to the typical products 

offered by a large manufacturer, DOE 

believes that these small fixture 

manufacturers will be able to pass on 

any necessary conversion costs to their 

customers without significantly 

impacting their businesses. 

The remaining small fixture 

manufacturers (roughly 14 in number) 

could be differentially impacted by 

today’s proposed standards. These 

manufacturers operate partially in 

industrial and commoditized markets in 

which it may be more difficult to pass 

on any disproportionate costs to their 

customers. The impacts could be 

relatively greater for a typical small 

manufacturer because of the far lower 

production volumes and the relatively 

fixed nature of the R&D and capital 

resources required per fixture family. 

Based on interviews, however, DOE 

anticipates that small manufacturers 

would take steps to mitigate the costs 

required to meet new and amended 

energy conservation standards. At TSL 

3, DOE believes that under the proposed 

standards, small fixture businesses 

would likely selectively upgrade 

existing product lines to offer products 

that are in high demand or offer 

strategic advantage. Small 

manufacturers could then spread out 

further investments over a longer time 

period by not upgrading all product 

lines prior to the compliance date. 

Additionally, DOE does not expect 

that small fixture manufacturers would 

be burdened by compliance 

requirements. As discussed in section 

IV.A, the standards proposed in this 

NOPR provide simplifying amendments 

to the current testing and reporting 

procedures. One of DOE’s goals in this 

rulemaking was to have minimal, if any, 

increase in testing and reporting burden 

on manufacturers. DOE is only 

mandating testing at a single input 

voltage for metal halide lamp fixtures. 

Other options considered would have 

increased testing to either two or four 

input voltages per fixture. Because DOE 

selected the least burdensome input 

voltage option, DOE concludes that 

regulations in this NOPR would not 

have an adverse impact on the testing 

burden of small manufacturers. 

The existing test procedures already 

dictate that testing for certification 

requires a sample of at least four fixtures 

for compliance. DOE is not proposing to 

change this minimum sample size, and 

as such, does not find an increased 

testing burden on small manufacturers. 

As discussed in section IV.A, DOE is 

amending the test procedures to 

mandate the equipment with which 

high-frequency electronic ballasts are to 

be tested, since existing test procedures 

prescribe test instrumentation only for 

magnetic and low-frequency electronic 

ballasts. DOE proposes that equipment 

be permitted for testing the output 

frequency of the ballast. Once it is 

determined that a fixture’s output 

frequency is greater than or equal to 

1000 Hz, the frequency at which DOE 

proposes to define high-frequency 

electronic ballasts, the test procedures 

would require equipment to consist of 

(1) a power analyzer that conforms to 

ANSI C82.6–2005 with a maximum of 

100 pF capacitance to ground and 

frequency response between 40 Hz and 

1 MHz, (2) a current probe compliant 

with ANSI C82.6–2005 that is 

galvanically isolated and has a 

frequency response between 40 Hz and 

20 MHz, and (3) a lamp current 

measurement device where its full 

transducer ratio is set in the power 

analyzer to match the current probe to 

the analyzer. DOE finds that these test 

requirements do not affect small 

manufacturers, noting that the 

equipment described above is the same 

equipment that is already required for 

the testing of fluorescent lamp ballasts. 

Because many lighting companies that 

manufacture or sell metal halide ballasts 

also manufacture or sell fluorescent 

lamp ballasts, this proposed change to 

the test procedures should not affect 

manufacturers’ testing burden or costs. 

In addition, DOE believes that the 

equipment specified for high-frequency 

electronic ballast testing is 

representative of typical high-quality 

equipment currently used by 

manufacturers in the business of 

designing and selling these ballasts. 

DOE seeks comment on the potential 

impacts of new and amended standards 

on the small metal halide ballast and 

metal halide lamp fixture 

manufacturers. 

3. Duplication, Overlap, and Conflict 

With Other Rules and Regulations 

DOE is not aware of any rules or 

regulations that duplicate, overlap, or 

conflict with the rule being considered 

today. 

4. Significant Alternatives to the 

Proposed Rule 

The discussion above analyzes 

impacts on small businesses that would 

result from the other TSLs DOE 

considered. Though TSLs lower than 

the proposed TSLs are expected to 

reduce the impacts on small entities, 

DOE is required by EPCA to establish 

standards that achieve the maximum 

improvement in energy efficiency that 

are technically feasible and 

economically justified, and result in 

significant conservation of energy. Thus, 

DOE rejected the lower TSLs. 

In addition to the other TSLs being 

considered, the NOPR TSD includes a 

regulatory impact analysis in chapter 

18. For metal halide lamp fixtures, this 

report discusses the following policy 

alternatives: (1) No standard, (2) 

customer rebates, (3) customer tax 

credits, (4) manufacturer tax credits, and 

(5) early replacement. DOE does not 

intend to consider these alternatives 

further because they are either not 

feasible to implement, or not expected 

to result in energy savings as large as 

those that would be achieved by the 

standard levels under consideration. 

DOE continues to seek input from 

businesses that would be affected by 

this rulemaking and will consider 

comments received in the development 

of any final rule. 

C. Review Under the Paperwork 

Reduction Act 

Manufacturers of metal halide lamp 

fixtures must certify to DOE that their 

equipment complies with any 

applicable energy conservation 

standard. In certifying compliance, 

manufacturers must test their 

equipment according to the DOE test 

procedures for metal halide lamp 

fixtures, including any amendments 

adopted for those test procedures. DOE 

has established regulations for the 

certification and recordkeeping 

requirements for all covered customer 

products and commercial equipment, 

including metal halide lamp fixtures. 76 

FR 12422 (March 7, 2011). The 

collection-of-information requirement 

for certification and recordkeeping is 

subject to review and approval by OMB 

under the Paperwork Reduction Act 

(PRA). This requirement has been 

approved by OMB under OMB control 

number 1910–1400. Public reporting 

burden for the certification is estimated 

to average 20 hours per response, 

including the time for reviewing 

instructions, searching existing data 

sources, gathering and maintaining the 

data needed, and completing and 

reviewing the collection of information. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 


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that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

Pursuant to the National 

Environmental Policy Act (NEPA) of 

1969, DOE has determined that the 

proposed rule fits within the category of 

actions included in Categorical 

Exclusion (CX) B5.1 and otherwise 

meets the requirements for application 

of a CX. See 10 CFR part 1021, 

appendix. B, B5.1(b); 1021.410(b) and 

appendix B, B(1)–(5). The proposed rule 

fits within the category of actions 

because it is a rulemaking that 

establishes energy conservation 

standards for consumer products or 

industrial equipment, and for which 

none of the exceptions identified in CX 

B5.1(b) apply. Therefore, DOE has made 

a CX determination for this rulemaking, 

and DOE does not need to prepare an 

Environmental Assessment or 

Environmental Impact Statement for 

this proposed rule. CX determination for 

this proposed rule is available at 

http://cxnepa.energy.gov. 

E. Review Under Executive Order 13132 

Executive Order 13132, ‘‘Federalism,’’ 

64 FR 43255 (Aug. 10, 1999), imposes 

certain requirements on Federal 

agencies formulating and implementing 

policies or regulations that preempt 

state law or that have Federalism 

implications. The E.O. requires agencies 

to examine the constitutional and 

statutory authority supporting any 

action that would limit the 

policymaking discretion of the states 

and to carefully assess the necessity for 

such actions. The E.O. also requires 

agencies to have an accountable process 

to ensure meaningful and timely input 

by state and local officials in the 

development of regulatory policies that 

have Federalism implications. On 

March 14, 2000, DOE published a 

statement of policy describing the 

intergovernmental consultation process 

it will follow in the development of 

such regulations. 65 FR 13735. EPCA 

governs and prescribes Federal 

preemption of state regulations as to 

energy conservation for the products 

that are the subject of today’s proposed 

rule. States can petition DOE for 

exemption from such preemption to the 

extent, and based on criteria, set forth in 

EPCA. (42 U.S.C. 6297) No further 

action is required by E.O. 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of E.O. 

12988, ‘‘Civil Justice Reform,’’ imposes 

on Federal agencies the general duty to 

adhere to the following requirements: 

(1) Eliminate drafting errors and 

ambiguity; (2) write regulations to 

minimize litigation; and (3) provide a 

clear legal standard for affected conduct 

rather than a general standard and 

promote simplification and burden 

reduction. 61 FR 4729 (Feb. 7, 1996). 

Section 3(b) of E.O.12988 specifically 

requires that Executive agencies make 

every reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal 

law or regulation; (3) provides a clear 

legal standard for affected conduct 

while promoting simplification and 

burden reduction; (4) specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of E.O. 12988 

requires Executive agencies to review 

regulations in light of applicable 

standards in section 3(a) and section 

3(b) to determine whether they are met 

or it is unreasonable to meet one or 

more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this 

proposed rule meets the relevant 

standards of E.O. 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (UMRA) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on state, 

local, and tribal governments and the 

private sector. Public Law 104–4, sec. 

201 (codified at 2 U.S.C. 1531). For a 

proposed regulatory action likely to 

result in a rule that may cause the 

expenditure by state, local, and tribal 

governments, in the aggregate, or by the 

private sector of $100 million or more 

in any one year (adjusted annually for 

inflation), section 202 of UMRA requires 

a Federal agency to publish a written 

statement that estimates the resulting 

costs, benefits, and other effects on the 

national economy. (2 U.S.C. 1532(a), (b)) 

UMRA also requires a Federal agency to 

develop an effective process to permit 

timely input by elected officers of state, 

local, and tribal governments on a 

proposed ‘‘significant intergovernmental 

mandate,’’ and requires an agency plan 

for giving notice and opportunity for 

timely input to potentially affected 

small governments before establishing 

any requirements that might 

significantly or uniquely affect small 

governments. On March 18, 1997, DOE 

published a statement of policy on its 

process for intergovernmental 

consultation under UMRA. 62 FR 

12820. DOE’s policy statement is also 

available at www.gc.energy.gov. 

Although today’s proposed rule does 

not contain a Federal intergovernmental 

mandate, it may require expenditures of 

$100 million or more on the private 

sector. Specifically, the proposed rule 

will likely result in a final rule that 

could require expenditures of $100 

million or more. Such expenditures may 

include: (1) Investment in research and 

development and capital expenditures 

by metal halide lamp fixture 

manufacturers in the years between the 

final rule and the compliance date for 

the new standards, and (2) incremental 

additional expenditures by customers to 

purchase higher-efficiency metal halide 

lamp fixtures, starting at the compliance 

date for the applicable standard. 

Section 202 of UMRA authorizes a 

Federal agency to respond to the content 

requirements of UMRA in any other 

statement or analysis that accompanies 

the proposed rule. (2 U.S.C. 1532(c)) 

The content requirements of section 

202(b) of UMRA relevant to a privatesector mandate substantially overlap 

with the economic analysis 

requirements that apply under section 

325(o) of EPCA and E.O. 12866. The 

SUPPLEMENTARY INFORMATION section of 

this NOPR and the ‘‘Regulatory Impact 

Analysis’’ section of the NOPR TSD for 

this proposed rule respond to those 

requirements. 

Under section 205 of UMRA, the 

Department is obligated to identify and 

consider a reasonable number of 

regulatory alternatives before 

promulgating a rule for which a written 

statement under section 202 is required. 

(2 U.S.C. 1535(a)) DOE is required to 

select from those alternatives the most 

cost-effective and least-burdensome 

alternative that achieves the objectives 

of the proposed rule unless DOE 

publishes an explanation for doing 

otherwise, or the selection of such an 

alternative is inconsistent with law. As 

required by 42 U.S.C. 6295(d), (f), and 

(o), 6313(e), and 6316(a), today’s 

proposed rule would establish energy 

conservation standards for metal halide 

lamp fixtures that are designed to 

achieve the maximum improvement in 

energy efficiency that DOE has 

determined to be both technologically 

feasible and economically justified. A 

full discussion of the alternatives 

considered by DOE is presented in the 

‘‘Regulatory Impact Analysis’’ section of 

the NOPR TSD for today’s proposed 

rule. 


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H. Review Under the Treasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any rule 

that may affect family well-being. This 

rule would not have any impact on the 

autonomy or integrity of the family as 

an institution. Accordingly, DOE has 

concluded that it is not necessary to 

prepare a Family Policymaking 

Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under E.O. 

12630, ‘‘Governmental Actions and 

Interference with Constitutionally 

Protected Property Rights’’ 53 FR 8859 

(Mar. 18, 1988), that this regulation 

would not result in any takings that 

might require compensation under the 

Fifth Amendment to the U.S. 

Constitution. 

J. Review Under the Treasury and 

General Government Appropriations 

Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516, note) 

provides for Federal agencies to review 

most disseminations of information to 

the public under guidelines established 

by each agency pursuant to general 

guidelines issued by OMB. OMB’s 

guidelines were published at 67 FR 

8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 

62446 (Oct. 7, 2002). DOE has reviewed 

today’s NOPR under the OMB and DOE 

guidelines and has concluded that it is 

consistent with applicable policies in 

those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, ‘‘Actions 

Concerning Regulations That 

Significantly Affect Energy Supply, 

Distribution, or Use’’ 66 FR 28355 (May 

22, 2001), requires Federal agencies to 

prepare and submit to OIRA at OMB, a 

Statement of Energy Effects for any 

proposed significant energy action. A 

‘‘significant energy action’’ is defined as 

any action by an agency that 

promulgates or is expected to lead to 

promulgation of a final rule, and that: 

(1) Is a significant regulatory action 

under E.O. 12866, or any successor 

order; and (2) is likely to have a 

significant adverse effect on the supply, 

distribution, or use of energy, or (3) is 

designated by the Administrator of 

OIRA as a significant energy action. For 

any proposed significant energy action, 

the agency must give a detailed 

statement of any adverse effects on 

energy supply, distribution, or use 

should the proposal be implemented, 

and of reasonable alternatives to the 

action and their expected benefits on 

energy supply, distribution, and use. 

DOE has tentatively concluded that 

today’s regulatory action, which sets 

forth energy conservation standards for 

metal halide lamp fixtures, is not a 

significant energy action because the 

proposed standards are not likely to 

have a significant adverse effect on the 

supply, distribution, or use of energy, 

nor has it been designated as such by 

the Administrator at OIRA. Accordingly, 

DOE has not prepared a Statement of 

Energy Effects on the proposed rule. 

L. Review Under the Information 

Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in 

consultation with the Office of Science 

and Technology Policy (OSTP), issued 

its Final Information Quality Bulletin 

for Peer Review (the Bulletin). 70 FR 

2664 (Jan. 14, 2005). The Bulletin 

establishes that certain scientific 

information shall be peer reviewed by 

qualified specialists before it is 

disseminated by the Federal 

Government, including influential 

scientific information related to agency 

regulatory actions. The purpose of the 

bulletin is to enhance the quality and 

credibility of the Government’s 

scientific information. Under the 

Bulletin, the energy conservation 

standards rulemaking analyses are 

‘‘influential scientific information,’’ 

which the Bulletin defines as ‘‘scientific 

information the agency reasonably can 

determine will have or does have a clear 

and substantial impact on important 

public policies or private sector 

decisions.’’ 70 FR 2667. 

In response to OMB’s Bulletin, DOE 

conducted formal in-progress peer 

reviews of the energy conservation 

standards development process and 

analyses and has prepared a Peer 

Review Report pertaining to the energy 

conservation standards rulemaking 

analyses. Generation of this report 

involved a rigorous, formal, and 

documented evaluation using objective 

criteria and qualified and independent 

reviewers to make a judgment as to the 

technical/scientific/business merit, the 

actual or anticipated results, and the 

productivity and management 

effectiveness of programs and/or 

projects. The ‘‘Energy Conservation 

Standards Rulemaking Peer Review 

Report’’ dated February 2007 has been 

disseminated and is available at the 

following Web site: 

www1.eere.energy.gov/buildings/

appliance_standards/peer_review.html. 

VIII. Public Participation 

A. Attendance at the Public Meeting 

The time, date, and location of the 

public meeting are listed in the DATES

and ADDRESSES sections at the beginning 

of this notice. If you plan to attend the 

public meeting, please notify Ms. 

Brenda Edwards at (202) 586–2945 or 

Brenda.Edwards@ee.doe.gov. As 

explained in the ADDRESSES section, 

foreign nationals visiting DOE 

Headquarters are subject to advance 

security screening procedures. 

In addition, you can attend the public 

meeting via webinar. Webinar 

registration information, participant 

instructions, and information about the 

capabilities available to webinar 

participants will be published on DOE’s 

Web site at: www1.eere.energy.gov/

buildings/appliance_standards/

product.aspx/productid/49. Participants 

are responsible for ensuring that their 

systems are compatible with the 

webinar software. 

B. Procedure for Submitting Prepared 

General Statements For Distribution 

Any person who has plans to present 

a prepared general statement may 

request that copies of his or her 

statement be made available at the 

public meeting. Such persons may 

submit requests, along with an advance 

electronic copy of their statement in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format, to the appropriate address 

shown in the ADDRESSES section at the 

beginning of this notice. The request 

and advance copy of statements must be 

received at least one week before the 

public meeting and may be emailed, 

hand-delivered, or sent by mail. DOE 

prefers to receive requests and advance 

copies via email. Please include a 

telephone number to enable DOE staff to 

make follow-up contact, if needed. 

C. Conduct of the Public Meeting 

DOE will designate a DOE official to 

preside at the public meeting and may 

also use a professional facilitator to aid 

discussion. The meeting will not be a 

judicial or evidentiary-type public 

hearing, but DOE will conduct it in 

accordance with section 336 of EPCA 

(42 U.S.C. 6306). A court reporter will 

be present to record the proceedings and 

prepare a transcript. DOE reserves the 

right to schedule the order of 

presentations and to establish the 

procedures governing the conduct of the 

public meeting. After the public 

meeting, interested parties may submit 

further comments on the proceedings as 

well as on any aspect of the rulemaking 

until the end of the comment period. 


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51554 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

The public meeting will be conducted 

in an informal, conference style. DOE 

will present summaries of comments 

received before the public meeting, 

allow time for prepared general 

statements by participants, and 

encourage all interested parties to share 

their views on issues affecting this 

rulemaking. Each participant will be 

allowed to make a general statement 

(within time limits determined by DOE), 

before the discussion of specific topics. 

DOE will allow, as time permits, other 

participants to comment briefly on any 

general statements. 

At the end of all prepared statements 

on a topic, DOE will permit participants 

to clarify their statements briefly and 

comment on statements made by others. 

Participants should be prepared to 

answer questions by DOE and by other 

participants concerning these issues. 

DOE representatives may also ask 

questions of participants concerning 

other matters relevant to this 

rulemaking. The official conducting the 

public meeting will accept additional 

comments or questions from those 

attending, as time permits. The 

presiding official will announce any 

further procedural rules or modification 

of the above procedures that may be 

needed for the proper conduct of the 

public meeting. 

A transcript of the public meeting will 

be included in the docket, which can be 

viewed as described in the Docket 

section at the beginning of this notice. 

In addition, any person may buy a copy 

of the transcript from the transcribing 

reporter. 

D. Submission of Comments 

DOE will accept comments, data, and 

information regarding this proposed 

rule before or after the public meeting, 

but no later than the date provided in 

the DATES section at the beginning of 

this proposed rule. Interested parties 

may submit comments, data, and other 

information using any of the methods 

described in the ADDRESSES section at 

the beginning of this notice. 

Submitting comments via 

regulations.gov. The regulations.gov 

Web page will require you to provide 

your name and contact information. 

Your contact information will be 

viewable to DOE Building Technologies 

staff only. Your contact information will 

not be publicly viewable except for your 

first and last names, organization name 

(if any), and submitter representative 

name (if any). If your comment is not 

processed properly because of technical 

difficulties, DOE will use this 

information to contact you. If DOE 

cannot read your comment due to 

technical difficulties and cannot contact 

you for clarification, DOE may not be 

able to consider your comment. 

However, your contact information 

will be publicly viewable if you include 

it in the comment itself or in any 

documents attached to your comment. 

Any information that you do not want 

to be publicly viewable should not be 

included in your comment, nor in any 

document attached to your comment. 

Otherwise, persons viewing comments 

will see only first and last names, 

organization names, correspondence 

containing comments, and any 

documents submitted with the 

comments. 

Do not submit to regulations.gov 

information for which disclosure is 

restricted by statute, such as trade 

secrets and commercial or financial 

information (hereinafter referred to as 

Confidential Business Information 

(CBI)). Comments submitted through 

regulations.gov cannot be claimed as 

CBI. Comments received through the 

Web site will waive any CBI claims for 

the information submitted. For 

information on submitting CBI, see the 

Confidential Business Information 

section below. 

DOE processes submissions made 

through regulations.gov before posting. 

Normally, comments will be posted 

within a few days of being submitted. 

However, if large volumes of comments 

are being processed simultaneously, 

your comment may not be viewable for 

up to several weeks. Please keep the 

comment tracking number that 

regulations.gov provides after you have 

successfully uploaded your comment. 

Submitting comments via email, hand 

delivery/courier, or mail. Comments and 

documents submitted via email, hand 

delivery, or mail also will be posted to 

regulations.gov. If you do not want your 

personal contact information to be 

publicly viewable, do not include it in 

your comment or any accompanying 

documents. Instead, provide your 

contact information in a cover letter. 

Include your first and last names, email 

address, telephone number, and 

optional mailing address. The cover 

letter will not be publicly viewable as 

long as it does not include any 

comments 

Include contact information each time 

you submit comments, data, documents, 

and other information to DOE. Email 

submissions are preferred. If you submit 

via mail or hand delivery/courier, 

please provide all items on a CD, if 

feasible. It is not necessary to submit 

printed copies. No facsimiles (faxes) 

will be accepted. 

Comments, data, and other 

information submitted to DOE 

electronically should be provided in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format. Provide documents that are not 

secured, that are written in English, and 

that are free of any defects or viruses. 

Documents should not contain special 

characters or any form of encryption 

and, if possible, they should carry the 

electronic signature of the author. 

Campaign form letters. Please submit 

campaign form letters by the originating 

organization in batches of between 50 to 

500 form letters per PDF or as one form 

letter with a list of supporters’ names 

compiled into one or more PDFs. This 

reduces comment processing and 

posting time. 

Confidential Business Information. 

According to 10 CFR 1004.11, any 

person submitting information that he 

or she believes to be confidential and 

exempt by law from public disclosure 

should submit via email, postal mail, or 

hand delivery/courier two well-marked 

copies: One copy of the document 

marked confidential including all the 

information believed to be confidential, 

and one copy of the document marked 

non-confidential with the information 

believed to be confidential deleted. 

Submit these documents via email or on 

a CD, if feasible. DOE will make its own 

determination about the confidential 

status of the information and treat it 

according to its determination. 

Factors of interest to DOE when 

evaluating requests to treat submitted 

information as confidential include: (1) 

A description of the items; (2) whether 

and why such items are customarily 

treated as confidential within the 

industry; (3) whether the information is 

generally known by or available from 

other sources; (4) whether the 

information has previously been made 

available to others without obligation 

concerning its confidentiality; (5) an 

explanation of the competitive injury to 

the submitting person which would 

result from public disclosure; (6) when 

such information might lose its 

confidential character due to the 

passage of time; and (7) why disclosure 

of the information would be contrary to 

the public interest. 

It is DOE’s policy that all comments 

may be included in the public docket, 

without change and as received, 

including any personal information 

provided in the comments (except 

information deemed to be exempt from 

public disclosure). 

E. Issues on Which DOE Seeks Comment 

Although DOE welcomes comments 

on any aspect of this proposal, DOE is 

particularly interested in receiving 

comments and views of interested 

parties concerning the following issues: 


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1. The appropriateness of continuing 

the exemption of regulated-lag ballasts; 

2. The exclusion of dedicated 480 V 

electronic ballasts in the scope of this 

rulemaking; 

3. The inclusion of ballasts that are 

rated only for used with 150 W lamps, 

use in wet locations, and operation in 

ambient air temperature higher than 50 

°C in the scope of this rulemaking; 

4. The expansion of coverage of this 

rulemaking to include metal halide 

lamp fixtures that operate lamps rated 

greater than or equal to 50 W and less 

than or equal to 150 W, and fixtures that 

operate lamps rated greater than 500 W 

and less than or equal to 2000 W; 

5. The decision that fixtures above 

1000 W are available for general lighting 

applications and are thus covered by 

this rulemaking; 

6. The appropriateness of setting 

efficiency standards for metal halide 

lamp fixtures based on ballast 

efficiency; 

7. The appropriateness of the 

proposed amendments to the testing 

procedure, especially the specification 

of input voltage, high-frequency test 

instrumentation, and rounding 

requirements; 

8. The appropriateness of DOE testing 

metal halide lamp fixtures at a single 

input voltage, based on the lamp 

wattage operated by the ballast; 

9. The appropriateness of placing 

indoor and outdoor fixtures into 

separate equipment classes; 

10. How to best combine the HID 

lamp and MHLF energy conservation 

standards; 

11. The technological feasibility of the 

max tech levels selected, specifically 

data on the potential change in 

efficiency, the design options employed, 

and the associated change in cost; 

12. Any technological barriers to an 

improvement in efficiency above the 

max tech efficiency levels for all or 

certain types of ballasts; 

13. The appropriateness of separate 

equipment classes for ballasts tested at 

480 V (in accordance with the test 

procedures); 

14. The appropriateness of not 

dividing equipment classes by 

electronic configuration or circuit type; 

15. The suitability of defining 

equipment class by the rated lamp 

wattage ranges ≥50 W to ≤100 W, >100 

W to ≤150 W, ≥150 W to ≤250 W, >250 

W to ≤500 W, and >500 W to ≤2000 W, 

specially the inclusion of 150 W fixtures 

previously exempted by EISA 2007 in 

the >100 W and ≤150 W range, and 150 

W fixtures subject to EISA 2007 

standards in the ≥150 W to ≤250 W 

range; 

16. The appropriateness of the 

equipment classes proposed in this 

NOPR; 

17. The assumption that there will be 

no lessening of utility or performance 

such that the physical size, including 

footprint, stack height, and weight, 

would be adversely affected for the 

magnetic ballast efficiencies associated 

with efficiency levels based on modeled 

ballasts; 

18. The appropriateness of the design 

options selected by the screening 

analysis presented in this NOPR; 

19. The possibility of setting a 

standard that requires a high-frequency 

ballast; 

20. The issue of operating a lamp at 

wattages greater or less than its rating 

and its effect on ballast efficiency or 

lamp efficacy; 

21. The analysis method of applying 

a 5.5 percent increase when calculating 

the representative input power of 

magnetic ballasts to account for the 

increase in wattage over a ballast’s 

lifetime; 

22. The addition of the electronic 70 

W baseline ballast; 

23. The possibility of high-frequency 

electronic ballasts requiring additional 

thermal and transient protection relative 

to low-frequency electronic ballasts and, 

if so, the technical reasons for this 

difference and whether ballast or fixture 

redesigns can overcome these barriers; 

24. The appropriateness of the 

efficiency levels proposed in this NOPR 

and whether or not an adjustment is 

needed for sources of variation not 

currently captured by the methodology; 

25. The proposal to apply a scaling 

factor of 0.6 percent to the efficiency 

levels for quad-volt ballasts to 

determine the appropriate values for 

480 V ballasts; 

26. The determination to include a 

design standard that would prohibit the 

sale of probe-start ballasts in newly sold 

fixtures, the proposed methods of 

analyzing these levels, and the potential 

for any lessening of the utility or the 

performance through the prohibition of 

the sale of probe-start ballasts in newly 

sold fixtures; 

27. The applicability and 

appropriateness of the adder to MPC of 

electronic ballasts for 120 V auxiliary 

power functionality and the adders to 

the MPC of fixtures with electronic 

ballasts for thermal management and 

transient protection; 

28. The appropriateness of the 

derived MSPs presented in this NOPR; 

29. Methods to improve DOE’s energy 

use analysis, as well as any data 

supporting alternate operating hour 

estimates or assumptions regarding 

fixture dimming; 

30. The impact and feasibility of a 

compliance date of January 1, 2015; 

31. The assumptions and 

methodology for estimating annual 

operating hours, which were based on 

data from the 2010 U.S. Lighting Market 

Characterization, and assumed to be 

3,615 hours per year in the commercial 

sector, 6,113 hours per year in the 

industrial sector, and 4,493 hours per 

year for the outdoor stationary sector; 

32. Methods to improve DOE’s fixture 

price projections beyond the 

assumption of constant real prices, as 

well as any data supporting alternate 

methods; 

33. The reasonableness of assuming a 

zero percent rebound effect (the 

tendency for customers to increase 

MHLF usage in response to life-cycle 

cost savings associated with more 

efficient ballasts used in new fixtures); 

34. Whether the shipment scenarios 

under various policy scenarios are 

reasonable and likely to occur; 

35. The impediments that prevent 

users of metal halide lamp fixtures from 

switching to LED lighting to garner 

further energy savings; 

36. The expected impact of new and 

revised standards on the rate at which 

MHLF customers transition to nonMHLF technology; 

37. The methodology applied to 

determine the product and capital 

conversion costs; 

38. The degree to which the 

manufacturers’ ability to recoup 

investment, combined with the 

opportunity cost of investment, would 

encourage manufacturers to exit the 

metal halide lamp fixture market; 

39. The appropriateness of proposed 

trial standard levels; 

40. The presence of features or 

attributes of the more energy efficient 

ballasts used in new fixtures that 

manufacturers would produce to meet 

the standards in this proposed rule that 

might affect the welfare, positively or 

negatively, of customers who purchase 

metal halide lamp fixtures; 

41. The possibility that the more 

widespread use of electronic ballasts 

would involve any performance or 

reliability effects for either 70-watt or 

150-watt fixtures, and how any such 

effects should be weighed in the choice 

of standards for these two wattage 

categories for the final rule; 

42. The appropriateness of choosing 

TSL 3 energy conservation standards; 

and 

43. The potential impacts of new and 

amended standards on the small metal 

halide ballast and metal halide lamp 

fixture manufacturers. 


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51556 Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 

IX. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of today’s proposed rule. 

List of Subjects in 10 CFR Part 431 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Reporting and recordkeeping 

requirements. 

Issued in Washington, DC, on August 13, 

2013. 

David T. Danielson, 

Assistant Secretary, Energy Efficiency and 

Renewable Energy. 

For the reasons set forth in the 

preamble, DOE proposes to amend part 

431 of Chapter II, subchapter D of title 

10 of the Code of Federal Regulations, 

as set forth below: 

PART 431—ENERGY EFFICIENCY 

PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL 

EQUIPMENT 

■ 1. The authority citation for part 431 

continues to read as follows: 

Authority: 42 U.S.C. 6291–6317. 

■ 2. Section 431.322 is amended by 

adding in alphabetical order definitions 

for ‘‘general lighting application,’’ 

‘‘high-frequency electronic metal halide 

ballast,’’ and ‘‘nonpulse-start electronic 

ballast,’’ to read as follows: 

§ 431.322 Definitions concerning metal 

halide ballasts and fixtures. 

* * * * * 

General lighting application means 

lighting that provides an interior or 

exterior area with overall illumination. 

High-frequency electronic metal 

halide ballast means an electronic 

ballast that operates a lamp at an output 

frequency of 1000 Hz or greater. 

* * * * * 

Nonpulse-start electronic ballast 

means an electronic ballast with a 

starting method other than pulse-start. 

* * * * * 

■ 3. Section 431.324 is amended by: 

■ a. Revising paragraphs (b)(1)(i), (b)(3) 

and (c)(1); and 

■ b. Adding paragraphs (b)(1)(iii), and 

(b)(1)(iv). 

The additions and revisions read as 

follows: 

§ 431.324 Uniform test method for the 

measurement of energy efficiency and 

standby mode energy consumption of metal 

halide ballasts. 

* * * * * 

(b) * * * 

(1) * * * 

(i) Test Conditions. The power 

supply, ballast test conditions (with the 

exception of input voltage), lamp 

position, lamp stabilization, and test 

instrumentation except as specified in 

paragraph (b)(1)(iii) of this section shall 

all conform to the requirements 

specified in section 4.0, ‘‘General 

Conditions for Electrical Performance 

Tests,’’ of ANSI C82.6 (incorporated by 

reference; see § 431.323). Ambient 

temperatures for the testing period shall 

be maintained at 25 °C ± 5 °C. Airflow 

in the room for the testing period shall 

be ≤0.5 meters/second. The ballast shall 

be operated until equilibrium. Lamps 

used in the test shall conform to the 

general requirements in section 4.4.1 of 

ANSI C82.6 and be seasoned for a 

minimum of 100 hours prior to use in 

ballast tests. Basic lamp stabilization 

shall conform to the general 

requirements in section 4.4.2 of ANSI 

C82.6, and stabilization shall be reached 

when the lamp’s electrical 

characteristics vary by no more than 3- 

percent in three consecutive 10- to 15- 

minute intervals measured after the 

minimum burning time of 30 minutes. 

After the stabilization process has 

begun, the lamp shall not be moved or 

repositioned until after the testing is 

complete. In order to avoid heating up 

the test ballast during lamp 

stabilization, which could cause 

resistance changes and result in 

unrepeatable data, it is necessary to 

warm up the lamp on a standby ballast. 

This standby ballast should be a 

commercial ballast of a type similar to 

the test ballast in order to be able to 

switch a stabilized lamp to the test 

ballast without extinguishing the lamp. 

Fast-acting or make-before-break 

switches are recommended to prevent 

the lamps from extinguishing during 

switchover. 

* * * * * 

(iii) Instrumentation for HighFrequency Electronic Metal Halide 

Ballasts. If the output frequency of the 

ballast (frequency of power supplied to 

the lamp) is greater than 1000 Hz, the 

testing instrumentation shall conform to 

the following paragraphs (b)(1)(iii)(A), 

(b)(1)(iii)(B), and (b)(1)(iii)(C) of this 

section. Instrumentation for 

determination of the output frequency 

shall be compliant with section 4.0 of 

ANSI C82.6 (incorporated by reference; 

see § 431.323). 

(A) Power Analyzer. In addition to the 

specifications in ANSI C82.6, the power 

analyzer shall have a maximum 100 pF 

capacitance to ground and frequency 

response between 40 Hz and 1 MHz. 

(B) Current Probe. In addition to the 

specifications in ANSI C82.6, the 

current probe shall be galvanically 

isolated and have frequency response 

between 40 Hz and 20 MHz. 

(C) Lamp Current. For the lamp 

current measurement, the full 

transducer ratio shall be set in the 

power analyzer to match the current 

probe to the power analyzer. 

Full Transducer Ratio = 

Where: 

Iin is current through the current transducer 

Vout is the voltage out of the transducer 

Rin is the power analyzer impedance 

Rs is the current probe output impedance. 

(iv) Input Voltage for Tests. For 

ballasts designed to operate lamps rated 

less than 150 W that have 120 V as an 

available input voltage, testing shall be 

performed at 120 V. For ballasts 

designed to operate lamps rated less 

than 150 W that do not have 120 V as 

an available voltage, testing shall be 

performed at the highest available input 

voltage. For ballasts designed to operate 

lamps rated greater than or equal to 150 

W that have 277 V as an available input 

voltage, testing shall be conducted at 

277 V. For ballasts designed to operate 

lamps rated greater than or equal to 150 

W that do not have 277 V as an available 

input voltage, testing shall be conducted 

at the highest available input voltage. 

* * * * * 

(3) Efficiency Calculation. The 

measured lamp output power shall be 

divided by the ballast input power to 

determine the percent efficiency of the 

ballast under test to the nearest tenth of 

a percent. 

(i) A fractional number at or above the 

midpoint between two consecutive 

decimal places shall be rounded up to 

the higher of the two decimal places; or 

(ii) A fractional number below the 

midpoint between two consecutive 

decimal places shall be rounded down 

to the lower of the two decimal places. 

(c) * * * 

(1) Test Conditions. (i) The power 

supply, ballast test conditions with the 

exception of input voltage, and test 

instrumentation with the exception of 

high-frequency electronic ballasts shall 

all conform to the requirements 

specified in section 4.0, ‘‘General 

Conditions for Electrical Performance 

Tests,’’ of the ANSI C82.6 (incorporated 

by reference; see § 431.323). Ambient 

temperatures for the testing period shall 

be maintained at 25 °C ± 5 °C. Send a 

signal to the ballast instructing it to 

have zero light output using the 

appropriate ballast communication 

protocol or system for the ballast being 

tested. 


sroberts on DSK5SPTVN1PROD with PROPOSALSEP20AU13.070</GPH>
Federal Register / Vol. 78, No. 161 / Tuesday, August 20, 2013 / Proposed Rules 51557 

(ii) Input Voltage for Tests. For 

ballasts less than 150 W that have 120 

V as an available input voltage, ballasts 

are to be tested at 120 V. For ballasts 

less than 150 W that do not have 120 V 

as an available voltage, ballasts are to be 

tested at the highest available input 

voltage. For ballasts greater than or 

equal to 150 W and less than or equal 

to 2000 W that have 277 V as an 

available input voltage, ballasts are to be 

tested at 277 V. For ballasts greater than 

or equal to 150 W and less than or equal 

to 2000 W that do not have 277 V as an 

available input voltage, ballasts are to be 

tested at the highest available input 

voltage. 

(iii) Instrumentation for HighFrequency Electronic Metal Halide 

Ballasts. If the output frequency of the 

ballast (frequency of power supplied to 

the lamp) is greater than 1000 Hz, the 

testing instrumentation shall conform to 

paragraphs (b)(1)(iii)(A), (b)(1)(iii)(B), 

and (b)(1)(iii)(C) of this section. 

Instrumentation for determination of the 

output frequency shall be compliant 

with section 4.0 of ANSI C82.6 

(incorporated by reference; see 

§ 431.323). 

(A) Power Analyzer. In addition to the 

specifications in ANSI C82.6, the power 

analyzer shall have a maximum 100 pF 

capacitance to ground and frequency 

response between 40 Hz and 1 MHz. 

(B) Current Probe. In addition to the 

specifications in ANSI C82.6, the 

current probe shall be galvanically 

isolated and have frequency response 

between 40 Hz and 20 MHz. 

(C) Lamp Current. For the lamp 

current measurement, the full 

transducer ratio shall be set in the 

power analyzer to match the current 

probe to the power analyzer. 

Full Transducer Ratio = 

Where: 

Iin is current through the current transducer 

Vout is the voltage out of the transducer 

Rin is the power analyzer impedance 

Rs is the current probe output impedance. 

* * * * * 

■ 4. Section 431.326 is amended by 

adding paragraphs (c), (d), and (e) to 

read as follows: 

§ 431.326 Energy conservation standards 

and their effective dates. 

* * * * * 

(c) Except when the requirements of 

paragraph (a) of this section are more 

stringent (i.e., require a larger minimum 

efficiency value) or as provided by 

paragraph (e) of this section, each metal 

halide lamp fixture manufactured on or 

after January 1, 2015 shall contain a 

metal halide ballast with an efficiency 

not less than the value determined from 

the appropriate equation in the 

following table: 

Rated lamp wattage Tested input voltage ‡‡ Minimum standard equation 

% 

≥50 W and ≤100 W ......................... Tested at 480 V ............................. 99.4/(1 + 2.5 * P ∧ (¥0.55)) ††.

≥50 W and ≤100 W ......................... All others ........................................ 100/(1 + 2.5 * P ∧ (¥0.55)). 

>100 W and <150 †. W .................... Tested at 480 V ............................. 99.4/(1 + 0.36 * P ∧ (¥0.30)). 

>100 W and <150 † W ..................... All others ........................................ 100/(1 + 0.36 * P ∧ (¥0.30)). 

≥150 ‡ W and ≤250 W ..................... Tested at 480 V ............................. For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 

6.0 * 10 ∧ (¥2) * P + 76.0. 

≥150 ‡ W and ≤250 W .................... All others ........................................ For ≥150 W and ≤200 W: 88.0. 

For >200 W and ≤250 W: 

7.0 * 10 ∧ (¥2) * P + 74.0. 

>250 W and ≤500 W ....................... Tested at 480 V ............................. 91.0. 

>250 W and ≤500 W ....................... All others ........................................ 91.5. 

>500 W and ≤2000 W ..................... Tested at 480 V ............................. For >500 W to <1000 W: 

0.994 * (3.2 * 10 ∧ (¥3) * P + 89.9). 

For ≥1000 W to ≤2000 W: 92.5. 

>500 W and ≤2000 W ..................... All others ........................................ For >500 W to <1000 W: 

3.2 * 10 ∧ (¥3) * P + 89.9. 

For ≥1000 W to ≤2000 W: 93.1. 

† Includes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. ‡Excludes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001. ††P is defined as the rated wattage of the lamp the fixture is designed to operate. 

‡‡ Tested input voltage is specified in 10 CFR 431.324. 

(d) Except as provided in paragraph 

(e) of this section, metal halide lamp 

fixtures manufactured on or after 

January 1, 2015 that operate lamps with 

rated wattage >500 W to ≤2000 W shall 

not contain a probe-start metal halide 

ballast. 

(e) The standards described in 

paragraphs (c) and (d) of this section do 

not apply to— 

(1) Metal halide lamp fixtures with 

regulated-lag ballasts; and 

(2) Metal halide lamp fixtures that use 

electronic ballasts that operate at 480 

volts. 

[FR Doc. 2013–20006 Filed 8–19–13; 8:45 am] 

BILLING CODE 6450–01–P 


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