5-i

CHAPTER 5 ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 METHODOLOGY OVERVIEW.................................................................................... 5-1

5.3 PRICING ANALYSIS OVERVIEW .............................................................................. 5-2

5.3.1 Manufacturer Production Costs........................................................................... 5-3

5.3.2 Selection of Units................................................................................................. 5-4

5.3.3 Manufacturer Markup .......................................................................................... 5-6

5.4 REPRESENTATIVE EQUIPMENT CLASSES, WATTAGES, AND FIXTURES ...... 5-9

5.5 Design Standard............................................................................................................. 5-11

5.6 Calculation of Efficiency and Input power.................................................................... 5-12

5.7 70 WATT METAL HALIDE LAMP FIXTURES ........................................................ 5-12

5.7.1 Baseline Models................................................................................................. 5-12

5.7.2 Candidate Standard Levels ................................................................................ 5-13

5.7.3 Ballast and Fixture Prices.................................................................................. 5-14

5.7.4 Engineering Summary ....................................................................................... 5-14

5.8 250 WATT METAL HALIDE LAMP FIXTURES...................................................... 5-15

5.8.1 Baseline Models................................................................................................. 5-15

5.8.2 Candidate Standard Levels ................................................................................ 5-15

5.8.3 Ballast and Fixture Prices.................................................................................. 5-17

5.8.4 Engineering Summary ....................................................................................... 5-17

5.9 400 WATT METAL HALIDE LAMP FIXTURES...................................................... 5-18

5.9.1 Baseline Models................................................................................................. 5-18

5.9.2 Candidate Standard Levels ................................................................................ 5-19

5.9.3 Ballast and Fixture Prices.................................................................................. 5-20

5.9.4 Engineering Summary ....................................................................................... 5-21

5.10 1000 WATT METAL HALIDE LAMP FIXTURES .................................................... 5-22

5.10.1 Baseline Models................................................................................................. 5-22

5.10.2 Candidate Standard Levels ................................................................................ 5-22

5.10.3 Ballast and Fixture Prices.................................................................................. 5-24

5.10.4 Engineering Summary ....................................................................................... 5-24

LIST OF TABLES

Table 5.1 Ballast Types for Teardowns....................................................................................... 5-6

Table 5.2 Fixture Types for Teardowns....................................................................................... 5-6

Table 5.3 Gross Profit Margin for Four Metal Halide Lamp Ballast Manufacturers* ................ 5-8

Table 5.4 Calculated Manufacturer Markups for Metal Halide Lamp Ballasts........................... 5-9

Table 5.5 Calculated Manufacturer Markups for Metal Halide Lamp Fixtures.......................... 5-9

Table 5.6 Equipment Classes and Representative Wattages & Fixtures................................... 5-10

Table 5.7 Baseline Model for the 70 W Representative Wattage.............................................. 5-13

Table 5.8 Summary of the CSLs for the 70 W Representative Wattage .................................. 5-14
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Table 5.9 Summary of the Manufacturing Selling Prices for the 70 W Representative Wattage 5-

14

Table 5.10 70 W Representative Wattage Engineering Summary ............................................ 5-15

Table 5.11 Baseline Models for the 250 W Representative Wattage ........................................ 5-15

Table 5.12 Summary of the CSLs for the 250 W Representative Wattage .............................. 5-17

Table 5.13 Summary of the Manufacturing Selling Prices for the 250 W Representative Wattage

.................................................................................................................................................... 5-17

Table 5.14 250 W Representative Wattage Engineering Summary .......................................... 5-18

Table 5.15 Baseline Models for the 400 W Representative Wattage ........................................ 5-19

Table 5.16 Summary of the CSLs for 400 W Representative Wattages................................... 5-20

Table 5.17 Summary of the Manufacturing Selling Prices for the 400 W Representative Wattage

.................................................................................................................................................... 5-21

Table 5.18 400 W Representative Wattage Engineering Summary .......................................... 5-21

Table 5.19 Baseline Models for the 1000 W Representative Wattage ...................................... 5-22

Table 5.20 Summary of the CSLs for the 1000 W Representative Wattage ............................ 5-24

Table 5.21 Summary of the Manufacturing Selling Prices for the 1000 W Representative 

Wattage ...................................................................................................................................... 5-24

Table 5.22 1000 W Representative Wattage Engineering Summary ........................................ 5-25

LIST OF FIGURES

Figure 5.3.1 Manufacturer Selling Price...................................................................................... 5-3
5-1

CHAPTER 5 ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed an engineering analysis to establish 

the relationship between the manufacturer production cost (MPC) of metal halide lamp fixtures 

and the energy efficiency of metal halide lamp ballasts (hereafter “ballasts”) contained in the 

fixtures. The relationship between the MPC and energy efficiency, or the cost-efficiency 

relationship, serves as the basis for cost-benefit calculations for individual customers, 

manufacturers, and the Nation. This section provides an overview of the engineering analysis, 

discusses the equipment classes, establishes baseline unit specifications for those equipment

classes, discusses incremental efficiency levels, and discusses the analysis and results for each 

equipment class.

The primary inputs to the engineering analysis include cost data from teardown and retail 

price scaling analysis, efficiency data from testing, and design options from the screening 

analysis. The primary output of the engineering analysis is a set of cost-efficiency curves. In a 

subsequent life-cycle cost (LCC) analysis (preliminary TSD chapter 8), DOE used the industry 

cost-efficiency curves to determine customer prices for the equipment analyzed in the 

engineering analysis by applying the appropriate distribution channel markups.

5.2 METHODOLOGY OVERVIEW

DOE typically structures its engineering analysis around one of three methodologies: (1) 

the design-option approach, which calculates the incremental cost of adding specific design 

options to the baseline model; (2) the efficiency-level approach, which calculates the relative 

costs of achieving increases in energy efficiency levels, without regard to the particular design 

options used to achieve such increases; and/or (3) the reverse engineering cost-assessment 

approach, which involves a “bottom-up” manufacturing cost assessment based on a detailed bill 

of materials (BOM) derived from teardowns of products being analyzed. Deciding which 

methodology to use for the engineering analysis depends on the equipment, the technologies 

under study, and any historical data DOE has available. To establish the industry cost-efficiency 

curves for ballasts included in metal halide lamp fixtures, DOE used both the efficiency-level 

approach to identify incremental improvements in efficiency for each equipment type and the 

reverse engineering cost-assessment approach to develop a cost for each efficiency level. 

DOE generally follows five steps in the engineering analysis:

Determine Representative Equipment Classes: DOE first reviews covered equipment and 

the associated equipment classes. DOE selects certain classes with high market volumes as 

“representative” and concentrates its analytical effort on these. For those equipment classes it 

does not analyze, DOE can extrapolate the candidate standard levels from representative 

equipment classes to other equipment classes. For this rulemaking, DOE did not use 

representative equipment classes and therefore directly analyzed each of the four metal halide 

lamp fixture equipment classes. 

Select Baseline Models: For each analyzed equipment class, DOE establishes baseline 

models. Generally, a baseline model is a commercially available ballast that just meets existing 
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Federal energy conservation standards and provides basic consumer utility. The baseline serves 

as a reference point for each equipment class, against which DOE measures changes from 

potential amended energy conservation standards. To determine energy savings and changes in 

price, DOE compares each higher energy-efficiency level with the baseline unit.

If no standard exists for that specific model, the baseline model represents the typical 

model sold within an equipment class with the lowest ballast efficiency. To determine the ballast 

efficiency, DOE tests a range of metal halide lamp ballasts contained in covered fixtures from 

multiple manufacturers. Appendix 5A presents the test results. DOE selects specific 

characteristics such as rated wattage, starting method, circuit design, and input voltage to 

characterize the most common model.

Select Candidate Designs: DOE selects commercially available models with higher

ballast efficiencies as replacements for each baseline model in the equipment classes by 

considering the design options identified in the technology assessment and screening analysis 

(preliminary TSD chapter 4). DOE can identify many of the distinguishing design options 

associated with each model. However, at some levels, these design options cannot be identified 

by the product number or catalog description, and therefore are assumed to be used in the 

fixture’s ballast to achieve a higher ballast efficiency. In identifying more efficient substitutes, 

DOE uses a database of commercially available metal halide fixture ballasts. DOE then tests 

these ballasts to establish their appropriate ballast efficiency. Appendix 5A presents these test 

results. All ballast efficiency values were calculated according to the metal halide lamp ballast 

test procedure (10 CFR 431.324)

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

each baseline model, DOE develops candidate standard levels (CSLs). DOE based its analysis on 

two factors: (1) the design options associated with the specific models studied, and (2) the 

maximum technologically feasible efficiency level.

unless otherwise specified.

Conduct Price Analysis. DOE generates a bill of materials by disassembling multiple 

manufacturers’ fixtures and ballasts that span a range of efficiency levels 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 develops a cost model that converts the BOMs and 

efficiency levels into MPCs. By applying derived manufacturer markups to the MPCs, DOE 

calculates the manufacturer selling prices (MSPs)a

The sections that follow discuss how DOE applies this methodology to each equipment

class to create the engineering analysis and the methodology DOE used to develop fixture prices.

and constructs industry cost-efficiency 

curves. 

5.3 PRICING ANALYSIS OVERVIEW

DOE based MSPs for different metal halide lamp fixtures on teardown data. In doing so, 

DOE determined a manufacturer markup to scale the teardown sourced MPC to an MSP. DOE 

 a The MSP is the price at which the manufacturer can recover all production and non-production costs and earn a 

profit. Non-production costs include selling, general, and administration (SG&A) costs, the cost of research and 

development, and interest.
5-3

generated ballast and empty fixture (physical enclosure & optics) MSPs separately and then 

combined the prices to create an overall metal halide lamp fixture MSP. In a few cases, DOE 

was unable to base MSPs directly on teardowns. DOE discusses these exceptions and the 

alternative scaling methodologies in sections 5.7 through 5.10.

Developing ballast and empty fixture teardown-sourced MSPs for different metal halide 

lamp ballasts involved two main sources: (1) teardown data and (2) a markup analysis to develop 

the MSP from the teardown-sourced MPC. Figure 5.3.1 shows the general breakdown of costs 

and profit associated with manufacturing and selling a product. The full cost of production is

broken down into two main costs: the manufacturer production cost and the non-production cost. 

The non-production cost plus profits is equal to the manufacturer markup. DOE totaled the cost 

of materials, labor, and direct overhead used to manufacture a product in order to calculate the 

MPC.b Section 5.3.1 describes how DOE arrived at the MPC. Section 5.3.3 describes how DOE 

established a markup that estimates non-production costs and profit.

Figure 5.3.1 Manufacturer Selling Price

5.3.1 Manufacturer Production Costs

The MPC is composed of direct labor, direct material, and overhead costs. In the case of 

electronic ballasts, direct material costs represent the direct purchase price of components 

(resistors, connecting wires, etc.). In the case of magnetic ballasts, direct material costs represent 

the purchase price of steel laminations, copper wires, and other components. Manufacturers 

commented that the materials involved in fixture manufacturing are highly correlated to 

commodity pricing. DOE used five year average material prices from 2006 to 2010 when 

possible.

DOE conducted teardown analyses for select commercially available metal halide lamp 

ballasts and empty fixtures. The direct labor costs include fabrication and assembly labor. The 

teardown results also included estimates for direct labor costs associated with the assembly of the 

product. Separate labor rates were used for components that required manual (hand) insertion 

versus those that were automated. Based on conversations with manufacturers, DOE assumed the 

ballasts were generally manufactured in China and Mexico and applied the corresponding labor 

 b When viewed from the company-wide perspective, the sum of all material, labor, and overhead costs equals the 

company’s sales cost, also referred to as the cost of goods sold (COGS).
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rates. During manufacturer interviews, DOE learned that fixtures are typically manufactured 

domestically, so DOE applied a United States labor rate for fixture teardowns.

One of the challenges associated with tearing down magnetic ballasts is identifying the 

type of electrical steel used. The grade or type of electrical steel affects the overall efficiency of 

the ballast but is impossible to discern from a visual assessment. As a result, DOE made

assumptions regarding the grade of electrical steel for the purposes of its cost model. 

In the case of magnetic ballasts at the 250 W and 400 W levels, DOE learned from the 

manufacturers that consumers tend to purchase ballasts that just meet EISA standards. As a 

result, manufacturers often do not offer magnetic ballast above the baseline level. Manufacturers 

provided input to DOE during interviews on specific changes required with the electrical steel to 

improve efficiencies of the baseline magnetic ballasts. For the magnetic ballasts in these 

equipment classes, DOE tore down baseline efficiency units and then changed the electrical steel 

input to the cost model for more efficient magnetic ballasts using the manufacturer input. DOE 

refers to these magnetic units as “virtual” teardowns when it discusses them in sections 5.8 and 

5.9.

In the case of magnetic ballasts at the 70 W and 1000 W levels, DOE received no specific 

information on what changes would be required to reach specific efficiencies. Because no 

efficiency standards exist at those levels, DOE assumed them to use a low-grade, non-oriented 

electrical steel at all CSLs. Any variation in efficiency is due to the amount of steel, type and 

amount of conductor, and geometry and design of the ballast. Consistent with this assumption, 

DOE observed little efficiency variation in magnetic ballasts at 70 W and 1000 W.

The teardown results did not include overhead estimates. Overhead includes indirect 

material and labor costs, maintenance, depreciation, taxes, and insurance related to assets. 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, finding it to be about 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 (section 5.3.3). 

Then, DOE computed the ratio of aggregated teardown-sourced material and labor costs to the 

manufacturer markdown sourced MPC. DOE found the material and labor costs to be about 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, which is reasonable as electronics manufacturing 

generally has low overhead costs. DOE found overhead and depreciation to be about 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.

5.3.2 Selection of Units

DOE carefully selected fixtures and ballasts for the teardown analysis to generate data 

useful for estimating manufacturer production costs. DOE mapped out a matrix of equipment 

specifications and then compared ballasts that differ by only one attribute. Ballasts are described 

by a long list of specifications, so DOE concentrated on the specifications it expected to have the 
5-5

greatest effect on efficiency. This list included high versus regular advertised efficiency, rated 

wattage, input voltage, starting method, electronic configuration, and circuit type. For fixtures, 

DOE consulted with manufacturers to learn which application types were typically used in 

particular wattage ranges. In addition to strategically selecting ballast specification 

characteristics and fixture types, DOE also selected common ballast and fixture models from 

major manufacturers. This choice helped DOE capture the most accurate incremental price 

difference by tearing down high volume, mainstream equipment. 

DOE was only able to select unpotted ballasts for the teardown analysis. Some ballast 

manufacturers add potting (often an epoxy) to the ballast enclosure to improve performance and 

durability. The potting is a better conductor of heat than air and helps the electronic elements 

dissipate heat. Furthermore, the potting can provide mechanical stability that mitigates vibration 

and seal out moisture. Because the potting completely engulfs the electronics and is not easily 

removable, DOE was unable to reverse engineer potted ballasts through a teardown analysis. As 

a result, DOE only conducted teardowns for unpotted ballasts and ballasts removed from a 

manufacturing facility before the potting procedure. 

DOE selected 8 metal halide lamp fixtures and 24 metal halide lamp ballasts to tear down 

for the engineering analysis. Table 5.1 lists the ballast types submitted for teardowns, and Table 

5.2 lists the fixture types selected for teardowns.
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Table 5.1 Ballast Types for Teardowns

Item Type Wattage

1 Magnetic 70

2 Magnetic 70

3 Magnetic 70

4 Magnetic 70

5 Magnetic 70

6 Magnetic 250

7 Magnetic 250

8 Magnetic 250

9 Magnetic 250

10 Magnetic 400

11 Magnetic 400

12 Magnetic 1000

13 Magnetic 1000

14 Magnetic 1000

15 Magnetic 1000

16 Magnetic 1000

17 Electronic 70

18 Electronic 70

19 Electronic 250

20 Electronic 250

21 Electronic 400

22 Electronic 400

23 Electronic 400

24 Electronic 400

Table 5.2 Fixture Types for Teardowns

Item Type Wattage

25 Canopy 70

26 Wall Pack 250

27 High-Bay 

Electronic 400

28 High-Bay 

Magnetic 400

29 Low-Bay 

Electronic 400

30 Low-Bay 

Magnetic 400

31 Parking / Area 400

32 Flood 400

5.3.3 Manufacturer Markup

More efficient equipment typically has higher production costs than baseline equipment. 

To meet new or amended energy conservation standards, manufacturers often must introduce 

design changes to their existing products or discontinue less efficient products, resulting in 

standards-compliant equipment with higher MPCs. Depending on the competitive environment 

for the particular equipment types, some or all of the increased production costs can be “passed 

on” from manufacturers to customers in the form of higher purchase prices. As production costs 

increase, manufacturers also typically incur additional overhead at the factory and corporate 
5-7

levels. The MSP must cover both of these additional contributions to overhead if a company is to 

maintain its current level of profitability. 

As discussed previously, overhead costs within the DOE model are a function of 

investments, material costs, labor costs, or total costs, depending on the overhead category. 

Together, materials, labor, and factory overhead comprise the manufacturer production cost. 

DOE applies another multiplier to the manufacturer production cost to account for corporate 

non-production costs and profit. This latter multiplier, the manufacturer markup, is the focus of 

this section.

The manufacturer markup is an integral part of the overall markup from production costs 

to installation costs. However, the manufacturer markup is different than the other markups in 

the distribution chain (which includes wholesalers, distributors, retailers, contractors, etc.) that 

convert MSP to customer price. The customer prices and installation costs are key inputs to the 

LCC analysis, payback period (PBP) analysis, and national impact analysis (NIA). Through the 

use of the manufacturer and distribution chain markups and installation costs, DOE can calculate 

the first costs that customers would face under the various efficiency levels. DOE evaluates the 

tradeoff between the increase in first cost and the resulting energy cost savings at each efficiency 

level in the LCC and PBP analyses (preliminary TSD chapter 8) and NIA analysis (preliminary 

TSD chapter 10). In this section, DOE presents its methodology for converting the MPCs to 

manufacturer selling prices using the manufacturer markup.

Manufacturer Selling Price

DOE calculated the MSP for metal halide lamp fixtures by multiplying the MPC by the 

calculated manufacturer markup, which is explained below. In general, the manufacturer markup 

should ensure that the MSP of the equipment is high enough to recover the full cost (i.e., 

production and non-production costs), and yield a satisfactory profit.

Manufacturer Financial Information Sources

Publicly owned companies are required by law to disclose financial information on a 

regular basis by filing different forms with the U.S. Securities and Exchange Commission. The 

SEC form 10-K, filed by companies on an annual basis, provides a comprehensive overview of 

the company’s business and financial conditions. Relevant information in the 10-K reports 

includes the company’s revenues and direct and indirect costs. To derive manufacturer markup, 

DOE used 10-K reports from publicly owned ballast or fixture manufacturing companies and 

inputs from manufacturer interviews. The financial figures necessary for calculating the 

manufacturer markup are net sales, costs of sales, and gross profit. The income statement section 

of the 10-K reports often reports these figures.

DOE calculated the manufacturer markup for both ballasts and fixtures by using financial 

figures from manufacturers’ SEC 10-K reports, such as the net sales (revenues) and cost of sales 

to calculate gross profit and gross profit margins. DOE used averages of the financial figures 

spanning 2000 to 2009 to calculate the manufacturer markup for ballasts and 2002 to 2008 for 

the manufacturer markup for fixtures. 

DOE used the following equations to calculate the gross profit and gross profit margins: 
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Equation 5.3-1

Gross Profit ($) = Net Sales – Cost of Sales

Equation 5.3-2

Table 5.3 contains the calculated gross profit margins for four sample ballast 

manufacturers. Table 5.3.3 contains the calculated gross profit margins for six sample fixture 

manufacturers.

Table 5.3 Gross Profit Margin for Four Metal Halide Lamp Ballast Manufacturers*

Parameter

IndustryWeighted 

Average

Manufacturer

A B C D

Net Sales Million $ 66,614 90,705 46,952 38,118 63,862

Cost of Sales Million $ 44,203 58,350 29,567 27,562 44,804

Gross Profit Million $ 22,411 32,355 17,385 10,556 19,057

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8

* Data taken from 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports. 

Table 5.3.3 Gross Profit Margin for Six Metal Halide Lamp Fixture Manufacturers*

Parameter

IndustryWeighted 

Average

Manufacturer

A B C D E F

Net Sales Million $ 65,337 100,996 44,363 34,988 15,164 15,877 0,978

Cost of Sales Million $ 44,237 65,844 31,614 28,824 10,119 11,317 0,489

Gross Profit Million $ 20,757 35,152 12,749 6,164 5,045 4,560 0,489

Gross Profit Margin % 31.8 34.8 28.7 17.6 33.3 28.7 50.0

* Data taken from 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, and 2009 SEC 10-K reports.

To calculate the time-averaged gross profit margin for each firm, DOE first summed the 

gross profit for all the years and then divided the result by the sum of the net sales for those 

years. Each manufacturer’s markup was calculated as: 

Equation 5.3-3

 

Table 5.4 shows the ballast manufacturer markups using this method. Table 5.5 shows the fixture 

manufacturer markups using the same method.
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Table 5.4 Calculated Manufacturer Markups for Metal Halide Lamp Ballasts

Manufacturer Manufacturer Markup

Manufacturer A 1.55

Manufacturer B 1.59

Manufacturer C 1.38

Manufacturer D 1.43

Average 1.50

Table 5.5 Calculated Manufacturer Markups for Metal Halide Lamp Fixtures

Manufacturer Manufacturer Markup

Manufacturer A 1.53

Manufacturer B 1.40

Manufacturer C 1.21

Manufacturer D 1.50

Manufacturer E 1.40

Manufacturer F 2.00

Average 1.48

DOE calculated the average ballast manufacturer markup to be 1.50, and the average 

fixture manufacturer markup to be 1.48 based on the estimated market share of each 

manufacturer. In other words, on average, metal halide lamp ballast manufacturers sell their 

products to the next party in the distribution channel at 50 percent above the manufacturing 

production cost, and metal halide lamp fixture manufacturers sell their product at 48 percent 

above the manufacturing production cost.

Although all publicly owned companies file 10-K reports, the financial information 

summarized therein is not usually exclusive to the metal halide portion of their business. It can 

include financial information from other product sectors, whose margins could be quite different 

from those of the metal halide ballast and fixture industries. Therefore, during interviews, DOE 

asked manufacturers to comment on the calculated average MSP, and to provide both the 

manufacturer markup and the manufacturer selling price of metal halide lamp ballasts or metal 

halide lamp fixtures sold through two main distribution chains: from the manufacturer to an 

original equipment manufacturer (OEM), and from the manufacturer to a distributor. 

Considering these calculations, the information provided in Table 5.4 and Table 5.3.5, 

actual MSPs, and manufacturer feedback, DOE determined that a manufacturer markup of 

approximately 1.47 for both the metal halide lamp ballast and fixture industries was appropriate.

DOE used these multipliers in the engineering analysis to determine the MSPs for each 

equipment class. DOE used a constant markup to reflect the MSPs of the baseline products as 

well as more efficient products. DOE took this approach because amended standards may make 

high-efficiency products, which currently are considered premium products, the baseline and 

commodity products in the future.

5.4 REPRESENTATIVE EQUIPMENT CLASSES, WATTAGES, AND FIXTURES
5-10

As discussed in the market and technology assessment (preliminary TSD chapter 3), 

DOE is considering revising the Energy Policy and Conservation Act (EPCA) table of standards 

for metal halide fixtures to contain four equipment classes (

Table 5.6). Because each equipment class represents a unique bundle of products, range 

of efficiency, and cost, DOE chose to analyze all equipment classes as representative. Therefore, 

DOE did not need to scale results from one equipment class to an equipment class not directly 

analyzed.

Table 5.6 Equipment Classes and Representative Wattages & Fixtures

Equipment 

Class Rated Lamp Wattage Representative 

Wattage Representative Fixture Types

1 ≥50 W and <150 W 70 W Canopy

2 ≥150 W and ≤250 W 250 W Low-bay, Canopy, Wallpack

3 >250 W and ≤500 W 400 W Flood, High-bay, Canopy

4 >500 W 1000 W Flood, High-bay, Canopy 

DOE selected one representative wattage for each equipment class. Based on analysis of 

product availability in catalogs and manufacturer input, DOE identified the most commonly sold 

wattage within an equipment class. For the ≥ 50 W and < 150 W equipment class, DOE analyzes 

70W fixtures as the representative wattage. For the ≥ 150 W and ≤ 250 W, > 250 W and ≤ 500 

W, and > 500 W equipment classes DOE analyzes 250 W, 400 W, and 1000 W fixtures as 

representative wattages.

DOE also identified representative fixture types for each representative wattage as 

described in Table 5.6. First, DOE identified the applications commonly served by particular 

wattage ranges. Low-wattage (less than 150 W) lamps are mainly used in commercial and some 

residential applications for general lighting purposes. Medium-wattage (150-500 W) lamps are 

the most widely used and include warehouse, street, and general commercial lighting. Highwattage (greater than 500 W) lamps are mainly used in searchlights, stadiums, stage applications, 

and other applications that require powerful white light. Then, DOE identified fixture types 

typically used in these applications to assign representative fixture types.

Next, DOE considered whether the fixture cost changes with efficiency and in particular, 

with a transition from magnetic to electronic technology. If fixture cost changed with efficiency, 

DOE would need to assign different fixture costs to different CSLs. If fixture cost did no change 

with efficiency, fixture cost could be the same for all CSLs. When determining whether a fixture 

must be altered to accommodate a given ballast, DOE considered two issues. Most important is 

whether the ballast will physically fit within the space allotted to it. For all efficiency levels 

analyzed, DOE found that each fixture type was capable of physically containing the ballast with 

minimal or no modification. The second consideration is, particularly in the case of electronic 

ballasts, whether the fixture can dissipate enough heat to keep the ballast at an acceptable 

temperature. This consideration is much more difficult to explore, as it varies with each 
5-11

particular ballast/fixture combination and requires simultaneously monitoring temperature at 

several different points within the fixture.

Instead of performing fixture-specific thermal testing, DOE preliminarily concluded that 

thermal management would not require significant fixture modification based on two 

observations. The first observation is that, at lower wattages, electronic ballasts are already quite 

prevalent in a variety of fixtures. Many manufacturers of electronic metal halide lamp ballasts 

also manufacturer electronic ballasts for fluorescent lamp fixtures of similar wattage. Though the 

two lighting types are not identical, they face some similar thermal challenges and having solved 

the problem in one lighting realm suggests it may be tractable in the other. The second 

observation is that, at medium and higher wattages, fixtures tend to be less space-constrained or 

“open.” This could allow a manufacturer to more easily thermally connect the hot ballast to the 

cooler fixture or in the open case, to add heat sinking directly to the ballast itself. Based on 

review of product catalogs, DOE discovered that manufacturers have already employed heat 

sinking for most 400 W ballasts currently on the market. 

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

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

incremental costs. The empty fixture MPC for a representative wattage was calculated as the 

average teardown cost of each of the fixture types identified as representative. This resulted in a 

“composite” fixture price representative of all the fixture types commonly used at a particular 

representative wattage. Therefore any changes in the total fixture MSP is only based on change 

in ballast cost. In the sections that follow, DOE describes its analysis of the representative 

wattage assigned to each equipment class.

5.5 DESIGN STANDARD

EISA 2007 gave DOE the authority to set design, in addition to performance, standards 

for metal halide lamp fixtures. In so doing, DOE may specify or prohibit certain features or 

qualities, which can be useful when more energy savings can be realized than with a 

performance standard alone. Although probe-start ballasts may not be tested to be less efficient 

than pulse-start units, probe-start lamps tend to exhibit poorer lumen maintenance than their 

pulse-start counterparts. Because acceptable lighting levels must be maintained over the life of 

the lamp, this implies that a space lit with probe-start fixtures needs either more or higher 

wattage fixtures than if than same space were lit with pulse-start fixtures. Many manufacturers 

market pulse-start fixtures as lower-wattage replacements for probe-start, especially at low and 

mid wattages. 250 W probe-start ballasts, for instance, could be replaced with a lower wattage

pulse-start ballast. Alternatively, a consumer could opt to save energy by replacing a certain 

number of 250 W probe-start fixtures with fewer pulse-start fixtures of the same wattage.

DOE understands the pulse-starting may have further benefits unrelated to energy 

consumption, such as shorter startup time and improved color rendition, but has learned of no 

technical benefits to probe-starting. As a result, DOE is considering setting a design standard that 

prohibits probe-starting, at least for some wattages.
5-12

5.6 CALCULATION OF EFFICIENCY AND INPUT POWER

Ballast efficiency and input power values were calculated in the same way for all 

wattages. Efficiency values were calculated according to DOE’s published metal halide ballast 

test procedure using tested input power and tested output power. Input power values were 

normalized by dividing rated lamp wattage by efficiency, instead of using tested input wattage 

values directly. Although the input power derived this way can differ from a particular test value, 

DOE believes that ballasts are generally designed to operate lamps at their rated wattages. 

Furthermore, DOE reviewed its test data and found no evidence of a trend or correlation between 

efficiency and the ratio of rated lamp power to tested ballast output power. 

DOE sought to present an input power representative of the efficiency level and not an 

artifact of the particular model chosen. If it finds operating a lamp at wattages greater or less than 

its rating affects either ballast efficiency or lamp efficacy, DOE will consider amending this 

approach. So as to avoid confusion with tested input power, DOE is using the term “normalized 

input power” hereafter when referring to the quantity rated lamp power divided by tested ballast 

efficiency.

5.7 70 WATT METAL HALIDE LAMP FIXTURES

In this section, DOE analyzes 70W metal halide lamp fixtures as the representative 

wattage for the ≥ 50 W and < 150 W equipment class.

5.7.1 Baseline Models 

DOE selected baseline models as reference points for each equipment class, against 

which DOE measured changes resulting from potential amended energy conservation standards. 

As discussed in section 5.2, a baseline model just meets current Federal energy conservation 

standards (if any exist) and provides basic consumer utility. To determine energy savings and 

changes in price, DOE compared each higher energy efficiency level with the baseline unit.

DOE chose to analyze one baseline ballast for the 70 W representative wattage. Because

EISA 2007 did not regulate 70 watt units, the least efficient ballasts have efficiencies near 70% -

characteristic of equipment purchased based on first cost. DOE considered the ballast’s 

characteristics in choosing the most appropriate equipment, including starting method, input 

voltage, and electronic configuration. In considering these characteristics, DOE sought to choose 

a baseline ballast that exhibits characteristics of a common, less efficient ballast. Ballasts 

operating 70 W lamps are commonly operated on either 120 V power characteristic of residential 

or light commercial power, or 277 V power standard in commercial and light industrial settings. 

The least efficient ballasts are often magnetic and frequently operate at 208 V and 240 V in 

addition to 120 V and 277 V. Magnetic 70 W ballasts typically use the high reactance high 

power factor (HX-HPF) circuit type, but constant wattage autotransformer (CWA) ballasts are 

also common. The baseline unit selected by DOE is a magnetic CWA ballast that operates at 

120, 208, 240, and 277 V and has an efficiency of 72.3 percent.
5-13

Table 5.7 Baseline Model for the 70 W Representative Wattage

Type Starting Method

Normalized 

Input Power

W

Ballast

Efficiency

Current 

Federal 

Standard

Magnetic Pulse 96.8 72.3% (none)

5.7.2 Candidate Standard Levels

For the 70 W representative wattage, DOE surveyed and tested many manufacturer 

product offerings for ballast efficiency to identify the efficiency levels corresponding to the 

highest number of models. DOE identified the most prevalent ballast efficiency values in the 

range of available equipment and established CSLs based on that equipment. DOE determined 

the maximum improvement in ballast efficiency that is technologically feasible (“max-tech”) for 

metal halide lamp fixtures, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To 

determine this level, DOE conducted a survey of the metal halide lamp fixture market and the 

research fields that support the market. DOE believes that, within a given equipment class, no 

working prototypes exist that have a distinguishably higher ballast efficiency than currently 

available equipment. Therefore the highest CSL presented, which represents the most efficient 

tier of commercially available equipment, is the max-tech level that DOE determined for this 

preliminary rulemaking.

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

DOE considered for the 70 W representative wattage. As discussed in the screening analysis 

(preliminary TSD chapter 4), DOE used design options that achieve a higher ballast efficiency 

than the baseline model. Efficiency improvements to the magnetic baseline unit required a higher 

grade of steel and an eventual move to electronic circuitry.

CSL1. Efficiency: 76.1 percent

This level corresponds to a magnetic ballast with higher grade steel than that of the baseline unit.

CSL2. Efficiency: 89.3 percent

This level corresponds to a move from magnetic to electronic circuitry.

CSL3. Efficiency: 91.1 percent

This level corresponds to an improved electronic design with more efficient components. It 

represents the maximum technologically feasible CSL.
5-14

Table 5.8 Summary of the CSLs for the 70 W Representative Wattage

Candidate Standard Level Ballast Efficiency Requirement

%

CSL1 76.1

CSL2 89.3

CSL3 91.1

5.7.3 Ballast and Fixture Prices

DOE analyzed each CSL for the 70 W representative wattage to develop appropriate 

MSPs. The total fixture MSP is equal to the sum of the empty fixture MSP and the ballast MSP. 

As discussed in section 5.4, the empty fixture cost is the same for each CSL (does not change 

with increasing efficiency) and is calculated as the average of the teardown MPCs for all fixture 

types identified as representative. Therefore, MSP variance across CSLs is due only to changes 

in the ballast itself. 

For the baseline unit and for CSL1, DOE based the ballast price on teardown-sourced 

MSPs. DOE was unable to determine which grade of electrical steel was used in those units but, 

reasoning that those ballasts are sold largely on a first-cost basis, modeled them as if they 

contained very low-grade, non-oriented electrical steel. CSL2 corresponds to an electronic 

ballast, whose price DOE calculated using teardown analysis. CSL3 is scaled from another CSL 

using a ratio of retail data between the two CSLs. Total fixture MSP increases with increased 

ballast efficiency.

Table 5.9 Summary of the Manufacturing Selling Prices for the 70 W Representative 

Wattage

Candidate Standard Level Total Fixture 

MSP

$

Baseline $51.53

CSL1 $52.23

CSL2 $54.69

CSL3 $61.12

5.7.4 Engineering Summary

The following table summarizes the engineering data developed for each CSL for the 70 

W representative wattage.
5-15

Table 5.10 70 W Representative Wattage Engineering Summary Candidate Standard Level Ballast Type Starting Method Input Voltage Normalized Input Power Ballast Efficiency Ballast Manufacturer Production Cost Empty Fixture 

Manufacturer 

Production Cost

Total Fixture 

Manufacturer 

Selling Price

V W $ $ $

Baseline CWA Pulse Quad 96.8 72.3% 18.80 16.26 51.53

CSL1 HX-HPF Pulse Quad 92.0 76.1% 19.27 16.26 52.23

CSL2 Electronic Pulse Quad 78.4 88.2% 20.94 16.26 54.69

CSL3 Electronic Pulse Quad 76.8 89.5% 25.32 16.26 61.12

Note: “Quad” input voltage means 120, 208, 240, and 277 V.

5.8 250 WATT METAL HALIDE LAMP FIXTURES

In this section, DOE analyzes 250 W metal halide lamp fixtures as the representative 

wattage for the ≥ 150 W and ≤ 250 W equipment class.

5.8.1 Baseline Models

DOE selected baseline models as reference points for each equipment class, against 

which DOE measured changes resulting from potential amended energy conservation standards. 

As discussed in section 5.2, a baseline model just meets current Federal energy conservation 

standards (if any exist) and provides basic consumer utility. To determine energy savings and 

changes in price, DOE compared each higher energy efficiency level with the baseline unit.

DOE chose to analyze one baseline ballast for the 250 watt representative wattage. EISA 

2007 covered 250 W ballasts in new fixtures, and no model could be less than 88% efficient. 

Although electronic ballasts are not uncommon for 250 W ballasts, magnetic, pulse-start, CWA, 

quad-voltage units predominate. For the 250 W baseline, DOE used a ballast from an EISAcompliant fixture and assumed it to be 88% efficient. DOE tore down the ballast, using 

manufacturer-provided data regarding which grade of steel would be required to achieve baseline

efficiency.

Table 5.11 Baseline Models for the 250 W Representative Wattage

Type Starting Method

Normalized 

Input Power

W

Ballast

Efficiency Current Federal Standard

Magnetic Pulse 284.1 88% 88%

5.8.2 Candidate Standard Levels

For the 250 W representative wattage, DOE surveyed and tested many manufacturer 

product offerings for ballast efficiency to identify the efficiency levels corresponding to the 

highest number of models. DOE identified the most prevalent ballast efficiency values in the 
5-16

range of available equipment and established CSLs based on that equipment. DOE determined 

the maximum improvement in ballast efficiency that is technologically feasible (“max-tech”) for 

metal halide lamp fixtures, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To 

determine this level, DOE conducted a survey of the metal halide lamp fixture market and the 

research fields that support the market. DOE believes that, within a given equipment class, no 

working prototypes exist that have a distinguishably higher ballast efficiency than currently 

available equipment. Therefore the highest CSL presented, which represents the most efficient 

tier of commercially available equipment, is the max-tech level that DOE determined for this 

preliminary rulemaking.

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

DOE considered for the 250 W representative wattage. As discussed in the screening analysis 

(preliminary TSD chapter 4), DOE used design options that achieve a higher ballast efficiency 

than the baseline model. Efficiency improvements to the magnetic baseline unit required a higher 

grade of steel, more and better conductor, and an eventual move to electronic circuitry.

As with the baseline unit, DOE relied on manufacturer-furnished data regarding what 

types and sizes of core and windings would be required to achieve a given efficiency level for 

CSLs 1 and 2. These CSLs represent “virtual” ballasts, where the efficiencies were specified (as 

opposed to tested) and the costs modeled (as opposed to teardown-derived).

CSL1. Efficiency: 90.0 percent

This level requires a less lossy grade of steel, which may have thinner laminations. The 

stack height is maintained, and so is the ballast footprint. A decrease in steel thickness due to the 

steel grade and no change in the stack height equates to additional laminations and thus an 

improvement in efficiency. Conductor may be added and partially or wholly changed from 

aluminum to copper.

CSL2. Efficiency: 91.5 percent

This level requires the use of even better grade of steel, which might have thinner 

laminations. The stack height is maintained, and so is the ballast footprint. A decrease in steel 

thickness due to the steel grade and no change in the stack height equates to additional 

laminations and thus an improvement in efficiency. Conductor may be added to reach this 

efficiency, and it is almost certainly copper.

CSL3. Efficiency: 93.2 percent

This level corresponds to the use of electronic ballasts. 

CSL4. Efficiency: 93.6 percent

This level represents the maximum technologically feasible level and represents a slight 

improvement in efficiency over CSL3. This level corresponds to electronic ballasts built with 

improved components relative to CSL3.
5-17

Table 5.12 Summary of the CSLs for the 250 W Representative Wattage

Candidate Standard Level Ballast Efficiency Requirement

%

CSL1 90.0

CSL2 91.5

CSL3 93.2

CSL4 93.6

5.8.3 Ballast and Fixture Prices

DOE analyzed each CSL for the 250 W representative wattage to develop appropriate 

MSPs. The total fixture MSP is equal to the sum of the empty fixture MSP and the ballast MSP. 

As discussed in section 5.4, the empty fixture cost is the same for each CSL (does not change 

with increasing efficiency) and is calculated as the average of the teardown MPCs for all fixture 

types identified as representative. Therefore, MSP variance across CSLs is due only to changes 

in the ballast itself. 

For the ballast component, CSLs 1 and 2 correspond to “virtual” teardowns, where a 

magnetic ballast of similar size and wattage is torn down and then modeled as if it had features 

(e.g., better steel, more conductor) that enabled higher efficiency. DOE interviewed 

manufacturers to determine which features were required to reach a given efficiency level. CSLs 

3 and 4 corresponded to electronic ballasts torn down directly. Note that CSL3 carries a higher 

MSP than CSL4. This unusual situation arises from the fact that the CSL3 ballast is rated for 

operation at wattages up to 400 and includes non-electronic parts that would ordinarily be 

considered part of a fixture. Because CSL3 is atypical, DOE is considering testing alternative 

units as part of the NOPR analysis. The CSL4 ballast is a dedicated wattage unit, and can use 

smaller, less costly circuit elements.

Table 5.13 Summary of the Manufacturing Selling Prices for the 250 W Representative 

Wattage

Candidate Standard Level Total Fixture MSP

$

Baseline 106.38

CSL1 112.49

CSL2 119.17

CSL3 137.88

CSL4 134.41

5.8.4 Engineering Summary

The following table summarizes the engineering data developed for each CSL for the 250 

W representative wattage.
5-18

Table 5.14 250 W Representative Wattage Engineering Summary Candidate Standard Level Ballast Type Starting Method Input Voltage Normalized Input Power Ballast Efficiency Ballast Manufacturer Production Cost

Empty Fixture 

Manufacturer 

Production Cost

Total Fixture 

Manufacturer 

Selling Price

V W $ $ $

Baseline CWA Pulse Quad 284.1 88.0% 32.57 39.80 106.38

CSL1 CWA Pulse Quad 276.2 90.5% 36.73 39.80 112.49

CSL2 CWA Pulse Quad 273.2 91.5% 41.27 39.80 119.17

CSL3 Electronic Pulse Tri 268.2 93.2% 54.00 39.80 137.88

CSL4 Electronic Pulse 208/277 267.1 93.6% 51.64 39.80 134.41

Note: “Tri” input voltage means 208, 240, and 277 V. “Quad” adds 120 V to tri.

5.9 400 WATT METAL HALIDE LAMP FIXTURES 

In this section, DOE analyzes 400 W metal halide lamp fixtures as the representative 

wattage for the > 250 W and ≤ 500 W equipment class.

5.9.1 Baseline Models

DOE selected baseline models as reference points for each equipment class, against 

which DOE measured changes resulting from potential amended energy conservation standards. 

As discussed in section 5.2, a baseline model just meets current Federal energy conservation 

standards (if any exist) and provides basic consumer utility. To determine energy savings and 

changes in price, DOE compared each higher energy efficiency level with the baseline unit.

DOE chose to analyze one baseline ballast for the 400 watt representative wattage. EISA 

2007 covered 400 W ballasts in new fixtures, and no model could be less than 88% efficient. 

Although electronic ballasts are not uncommon for 400 W ballasts, magnetic, pulse-start, CWA, 

quad-voltage units predominate. For the 400 W baseline, DOE used a ballast from an EISAcompliant fixture and assumed it to be 88% efficient. DOE tore down the ballast, using 

manufacturer-provided data regarding which grade of steel would be required to achieve baseline

efficiency.
5-19

Table 5.15 Baseline Models for the 400 W Representative Wattage

Type Starting Method

Normalized 

Input Power

W

Ballast

Efficiency Current Federal Standard

Magnetic Pulse 454.5 88% 88%

5.9.2 Candidate Standard Levels

For the 400 W representative wattage, DOE surveyed and tested many manufacturer 

product offerings for ballast efficiency to identify the efficiency levels corresponding to the 

highest number of models. DOE identified the most prevalent ballast efficiency values in the 

range of available equipment and established CSLs based on that equipment. DOE determined 

the maximum improvement in ballast efficiency that is technologically feasible (“max-tech”) for 

metal halide lamp fixtures, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To 

determine this level, DOE conducted a survey of the metal halide lamp fixture market and the 

research fields that support the market. DOE believes that, within a given equipment class, no 

working prototypes exist that have a distinguishably higher ballast efficiency than currently 

available equipment. Therefore the highest CSL presented, which represents the most efficient 

tier of commercially available equipment, is the max-tech level that DOE determined for this 

preliminary rulemaking.

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

DOE considered for the 400 W representative wattage. As discussed in the screening analysis 

(preliminary TSD chapter 4), DOE used design options that achieve a higher ballast efficiency 

than the baseline model. Efficiency improvements to the magnetic baseline unit required a higher 

grade of steel, more and better conductor, and an eventual move to electronic circuitry.

As with the baseline unit, DOE relied on manufacturer-furnished data regarding what 

types and sizes of core and windings would be required to achieve a given efficiency level for 

CSLs 1 and 2. These CSLs represent “virtual” ballasts, where the efficiencies were specified (as 

opposed to tested) and the costs modeled (as opposed to teardown-derived).

CSL1. Efficiency: 90.0 percent

This level requires a less lossy grade of steel, which might have thinner laminations. The 

stack height is maintained, as is the ballast footprint. A decrease in steel thickness due to the 

steel grade and no change in the stack height equates to additional laminations and thus an 

improvement in efficiency. Conductor may be added and partially or wholly changed from 

aluminum to copper.

CSL2. Efficiency: 91.7 percent

This level requires the use of even better grade of steel, which might have thinner 

laminations. The stack height is maintained, and so is the ballast footprint. A decrease in steel 

thickness due to the steel grade and no change in the stack height equates to additional 
5-20

laminations and thus an improvement in efficiency. Conductor may be added to reach this 

efficiency, and the conductor material is almost certainly copper.

CSL3. Efficiency: 92.7 percent

This level requires the use of electronic ballasts rather than magnetic ballasts. The least 

efficient electronic ballasts meet CSL3. The CSL3 representative unit is a low frequency 

electronic ballast.

CSL4. Efficiency: 93.9 percent

This level represents the maximum technologically feasible level and represents a slight 

improvement in efficiency over CSL3. This level corresponds to electronic ballasts built with the 

better components and improved circuit designs compared to CSL3. The representative unit at 

CSL4 is a high frequency electronic ballast.

Table 5.16 Summary of the CSLs for 400 W Representative Wattages

Candidate Standard Level Ballast Efficiency Requirement

%

CSL1 90.0

CSL2 91.7

CSL3 92.7

CSL4 93.9

5.9.3 Ballast and Fixture Prices

DOE analyzed each CSL for the 400 W representative wattage to develop appropriate 

MSPs. The total fixture MSP is equal to the sum of the empty fixture MSP and the ballast MSP. 

As discussed in section 5.4, the empty fixture cost is the same for each CSL (does not change 

with increasing efficiency) and is calculated as the average of the teardown MPCs for all fixture 

types identified as representative. Therefore, MSP variance across CSLs is due only to changes 

in the ballast itself. 

For the ballast component, CSLs 1 and 2 correspond to “virtual” teardowns, where a 

magnetic ballast of similar size and wattage is torn down and then modeled as if it had features 

(e.g., better steel, more conductor) that enabled higher efficiency. DOE interviewed 

manufacturers to determine which features were required to reach a given efficiency level. CSL3 

corresponded to an electronic ballast torn down directly. CSL4 corresponded to an electronic 

ballast, costed by dividing the manufacturer’s retail price by a distributor markup (with the 

assumption being that the manufacturer had internalized the cost of distribution) and then by 

manufacturer markup to arrive at an MPC.
5-21

Table 5.17 Summary of the Manufacturing Selling Prices for the 400 W Representative 

Wattage

Candidate Standard Level Total Fixture MSP

$

Baseline 135.72

CSL1 148.24

CSL2 156.72

CSL3 184.63

CSL4 204.44

5.9.4 Engineering Summary

The following table summarizes the engineering data developed for each CSL for the 400 

W representative wattage.

Table 5.18 400 W Representative Wattage Engineering Summary Candidate Standard Level Ballast Type Starting Method Input Voltage Normalized Input Power Ballast Efficiency Ballast Manufacturer Production Cost Empty Fixture 

Manufacturer 

Production Cost

Total Fixture 

Manufacturer 

Selling Price

V W $ $ $

Baseline CWA Pulse Quad 454.5 88.0% 24.25 132.77 135.72

CSL1 CWA Pulse Quad 444.4 90.0% 32.77 132.77 148.24

CSL2 CWA Pulse Quad 436.2 91.7% 38.54 132.77 156.72

CSL3 Electronic Pulse Tri 431.5 92.7% 63.95 132.77 184.63

CSL4 Electronic Pulse Tri 426.0 93.9% 77.43 132.77 204.44

Note: “Tri” input voltage implies 208, 240, and 277 V.
5-22

5.10 1000 WATT METAL HALIDE LAMP FIXTURES 

In this section, DOE analyzes 1000 W metal halide lamp fixtures as the representative 

wattage for the >500 W equipment class.

5.10.1 Baseline Models

DOE selected baseline models as reference points for each equipment class, against 

which DOE measured changes resulting from potential amended energy conservation standards. 

As discussed in section 5.2, a baseline model just meets current Federal energy conservation 

standards (if any exist) and provides basic consumer utility. To determine energy savings and 

changes in price, DOE compared each higher energy efficiency level with the baseline unit.

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

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

smaller units. DOE did not test any ballasts below 91% in efficiency. DOE identified no 1000 W 

electronic ballasts on the market. This could be partly because magnetic ballasts can be quite 

efficient at the 1000 W level and partly because of thermal challenges for high wattage electronic 

ballasts. Pulse-start ballasts are available at the 1000 W level, but probe-start, CWA, quadvoltage units predominate. DOE selected the least efficient, quad-voltage ballast as its baseline. 

Although the unit happened to be pulse-start, efficiency (as measured by the test procedure) is 

not directly affected by starting method, which is part of the reason DOE is considering a design 

standard that eliminates probe-starting. See Section 5.5 for further detail.

Table 5.19 Baseline Models for the 1000 W Representative Wattage

Type Starting Method Normalized Input Power

W

Ballast

Efficiency Current Federal Standard

Magnetic Pulse 1088.1 91.9% (none)

5.10.2 Candidate Standard Levels

For the 1000 W representative wattage, DOE surveyed and tested many manufacturer 

product offerings for ballast efficiency to identify the efficiency levels corresponding to the 

highest number of models. DOE identified the most prevalent ballast efficiency values in the 

range of available equipment and established CSLs based on that equipment. DOE determined 

the maximum improvement in ballast efficiency that is technologically feasible (“max-tech”) for 

metal halide lamp fixtures, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To 

determine this level, DOE conducted a survey of the metal halide lamp fixture market and the 

research fields that support the market. DOE believes that, within a given equipment class, no 

working prototypes exist that have a distinguishably higher ballast efficiency than currently 

available equipment. Therefore the highest CSL presented, which represents the most efficient 

tier of commercially available equipment, is the max-tech level that DOE determined for this 

preliminary rulemaking.
5-23

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

DOE considered for the 1000 W representative wattage. As discussed in the screening analysis 

(preliminary TSD chapter 4), DOE used design options that achieve a higher ballast efficiency 

than the baseline model. Efficiency improvements to the magnetic baseline unit required a higher 

grade of steel and an eventual move to electronic circuitry.

CSL1. Efficiency: 92.6 percent

This level requires a less lossy grade of steel, which might have thinner laminations. The 

stack height is maintained, and so is the ballast footprint. A decrease in steel thickness due to the 

steel grade and no change in the stack height equates to additional laminations and thus an 

improvement in efficiency. Conductor may be added and partially or wholly changed from 

aluminum to copper.

CSL2. Efficiency: 93.3 percent

This level requires the use of even better grade of steel, which might have thinner 

laminations. The stack height is maintained, and so is the ballast footprint. A decrease in steel 

thickness due to the steel grade and no change in the stack height equates to additional 

laminations and thus an improvement in efficiency. Conductor may be added to reach this 

efficiency, and the conductor material is almost certainly copper.

The 1000 W level is unique in that its max-tech unit is magnetic; the lower-wattage 

equipment classes all had electronic max-tech units. DOE has not identified any currently 

available 1000 W ballasts and has learned of several possible reasons for this in its interviews 

with manufacturers. First, the high power levels make thermal management a challenge. 

Maintaining an operating temperature tolerable to electronic elements would require spacing 

those elements and heat sinking them extensively. Those changes would add size, weight, cost, 

and complexity to ballasts, and possibly require larger fixtures. Second, magnetic ballasts at the 

1000 W level tend to be relatively efficient. At lower wattages, using electronic ballasts may 

increase efficiency by fifteen or twenty percent. Use of electronic ballasts at 1000 W would be 

likely increase the efficiency of electronic ballasts by only two or three percent. Finally, 1000 W 

ballasts are overwhelmingly used outdoors, where they more often subjected to high voltage 

transients that can damage electronic elements. Using an electronic ballast could require adding 

inline transient protection, and further increase cost and complexity relative to their magnetic 

counterparts. Although this concern applies equally to lower wattage ballasts placed outdoors, 

these wattages are less often used outdoors. DOE concluded that, although not a technical 

impossibility, constructing a reliable 1000 W electronic ballast would result in a product not 

suitable for use as a substitute for magnetic ballasts based on increased size, weight, and 

potentially cost.
5-24

Table 5.20 Summary of the CSLs for the 1000 W Representative Wattage

Candidate Standard Level Ballast Efficiency Requirement

%

CSL1 92.6

CSL2 93.3

5.10.3 Ballast and Fixture Prices

DOE analyzed each CSL for the 250 W representative wattage to develop appropriate 

MSPs. The total fixture MSP is equal to the sum of the empty fixture MSP and the ballast MSP. 

As discussed in section 5.4, the empty fixture cost is the same for each CSL (does not change 

with increasing efficiency) and is calculated as the average of the teardown MPCs for all fixture 

types identified as representative. Therefore, MSP variance across CSLs is due only to changes 

in the ballast itself. 

DOE did not perform teardowns for the 1000 W empty fixtures. Instead, DOE scaled the 

400 W empty fixture teardown prices using ratios of 400 W and 1000 W retail prices from the 

same retailers. DOE selected pairs of 400 W and 1000 W fixtures of parking/area type and 

averaged their respective retail price ratios to develop a 400 W to 1000 W empty fixture ratio. 

For the baseline and for both CSLs, DOE based the price on teardown-sourced MSPs. 

DOE was unable to determine which grade of electrical steel was used in those units but, 

reasoning that those ballasts are sold largely on a first-cost basis, modeled them as if they 

contained very low-grade, non-oriented electrical steel.

Table 5.21 Summary of the Manufacturing Selling Prices for the 1000 W Representative 

Wattage

Candidate Standard Level Total Fixture

MSP

$

Baseline 254.00

CSL1 263.18

CSL2 267.68

5.10.4 Engineering Summary

The following table summarizes the engineering data developed for each CSL for the 

1000 W representative wattage.
5-25

Table 5.22 1000 W Representative Wattage Engineering Summary Candidate Standard Level Ballast Type Starting Method Input Voltage Normalized Input Power Ballast Efficiency Ballast Manufacturer Production Cost

Empty Fixture 

Manufacturer 

Production Cost

Total Fixture 

Manufacturer 

Selling Price

V W $ $ $

Baseline CWA Pulse Quad 1088.1 91.9% 40.02 132.77 254.00

CSL1 CWA Pulse Quad 1079.9 92.6% 46.26 132.77 263.18

CSL2 CWA Pulse Quad 1071.8 93.3% 49.32 132.77 267.68

Note: “Quad” input voltage implies 120, 208, 240, and 277 V.