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

- 145

- ii Table 5.9 Summary of the Manu facturing 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

- 1 7 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 fo r the 1000 W Representative Wattage

............................ 5

- 24
Table 5.21 Summary of the Manufacturing Selling Prices for the 1000 W Representative Wattag e

................................ ................................ ................................ ................................ ...... 5

- 24 Table 5.22 1000 W Representative Wattage Engineering Summary

................................ ........ 5

- 25

LIST OF FIGURES

Figure 5.3.1 Manufacturer Selling Price

................................ ................................ ...................... 5

- 35

- 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 cos t

- benefit calculations for individual customers, manufacturers, and the N ation. 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 optio ns from the scree n ing 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 custome r 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 cal culates 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” manufac turing 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

rev erse 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 equipme nt 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 equ ipment class, DOE establishes baseline
models . Generally, a baseline model is a commercially available ballast that just meets existing5

- 2 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 a n equipment class with the lowest ballast effic ien cy. To determine the ballast efficiency , DOE tests a range of metal halide lamp ballasts contained in covered fixtures f rom 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 c ommercially available models with higher
ballast efficienc ies as replacement s 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 des ign 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 commercia lly available metal halide fixture ballasts. DOE then tests these ballasts to establish their appropriate ballast efficiency . Appendix 5A presents the se 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
eff iciency 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 eac h 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 MSP s for different metal halide lamp fixtures on teardown data

. In doing so

, DOE determined a manufacturer mark up 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 MS Ps directly on teardown s . 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 pr oduct in order to calculate the

MPC. b 5.3.1 Section 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 ballast s , direct materia l 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 pric es 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 w ere generally manufactured in China and Mexico and applied the corresponding labor

b Whe n 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).5

- 4 rates. During manufacturer interviews, DOE learned that fixtures are typically manufactured domestically, so DOE applied a United States labor rate for fixture teardowns.

On e 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 assumption s 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 b aseline 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

re fers 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 s tandards 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 insuranc e 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 (SE C) 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

perc ent 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 the5

- 5 greatest effect on efficiency. This list included high v ersus 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 tea rdowns , and Table

5

. 2 lists the fixture types selected for teardowns.5

- 6 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

1 6 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

2 6 Wall Pack 250

2 7 High

- Bay
Electronic 400

2 8 High

- Bay Magnetic 400

2 9 Low

- Bay
Electronic 400

3 0 Low

- Bay Magnetic 400

3 1 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, re sulting 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 p urchase prices. As production costs increase, manufacturers also typically incur additional overhead at the factory and corporate5

- 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 manu facturer 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.) tha t 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 calc ulated 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

. , p roduction 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 an d 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 marku p 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 r eports, 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 manuf acturer markup for fixtures

.

DOE used the following equations to calculate the gross profit and gross profit margins:5

- 8 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 Industry

Weighted 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 Industry

Weighted 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

- average d 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 manufactu rer markups using this method

. Table 5

. 5 shows the fixture manufacturer markups using the same method.5

- 9 Table 5

. 4 Calcul ated 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 the ir 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 ow ned 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
fr om those of the metal halide ballast and fixture industr ies . 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 bo th the metal halide lamp ballast and fixture industr ies 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
commodit y products in the future

.

5.4 REPRESENTATIVE EQUIPMENT CLASSES
, WATTAGES, AND FIXTUR ES5

- 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 clas ses (
Table 5.6 )

. Because each equipment class represents a unique bundle of products, range of efficiency, and cost, DOE chose to analyze all equipmen t 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. L ow

- wattage (less than 150 W) lamps are mainly used in commercial and some residential applications for g eneral lighting purposes. Medium

- wattage (150

- 500 W) lamps are the most widely used and include warehouse, street, and general commercial lighting. High

wattage (greater than 500 W) lamps are mainly used in searchlights, stadiums, stage applications,
and o ther 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,

w ith 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 ea ch 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 acceptab le temperature. This consideration is much more difficult to explore, as it varies with each5

- 11 particular ballast/fixture combination and requires simultaneously monitoring temperature at several different points within the fixture.

Instead of performing fi xture

- 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 preval ent in a variety of fixtures. Many manufacturers of electronic metal halide lamp ballasts
als o manufacturer electronic ballasts for fluorescent lamp fixtures of similar wattage. Though the two lighting types are not identical, they face some similar therma l 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 m ost 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 no t 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
represent ative 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 prohibi t certain features or qualities, which can be useful when more energy savings can be realized than with a performa nce 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 main tained 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

- watta ge 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 2 50 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 d esign standard that prohibits probe

- starting, at least for some wattages.5

- 12 5.6 CALCULATION OF EFFIC IENCY AND INPUT POWE R

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 inpu t 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
ef

ficienc y 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 ra ted 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 bas eline 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 efficien cy 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 e fficiencies 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 s tandard in commercial and light industrial settings.
The least efficient ballasts are often m agnetic 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 9 6.8 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

r ange of available equipment and established CSLs based on that equipment. D OE 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 distinguish ably 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 ball ast 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 hi gher 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 efficie nt 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 , t he 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 o n 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 electrica l steel. CSL2 corresponds to an electronic ballast, whose price DOE calculated using teardown analysis. CSL 3 is scaled from another CSL using a ratio of retail data between the two CSLs

. Total f ixture 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 SummaryCandidate StandardLevelBallast TypeStarting MethodInput VoltageNormalized InputPowerBallast EfficiencyBallastManufacturerProduction CostEmpty FixtureManufacturerProduction CostTotalFixtureManufacturerSelling 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 fixture s 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, again st which DOE measured changes resulting from potential amended energy conservation standards.
As discussed in section 5.2 , a baseline model just me ets 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 baseli ne 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 EISA

compliant 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 baselin e efficienc y

.

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 bal last efficiency values in the5

- 16 range of available equipment and established CSLs based on that equipment. D OE 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 prototype s 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 f or 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 op tions 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

o pposed 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: 9 3.2 percent

This level corresponds to the use of electronic ballasts.

CS L4 . 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 CSL 3

.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 9 3.2

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 , t he 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 car ries 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 1 34.41

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 SummaryCandidate StandardLevelBallast TypeStarting MethodInput VoltageNormalized InputPowerBallast EfficiencyBallastManufacturerProduction CostEmpty FixtureManufacturerProduction CostTotalFixtureManufacturerSelling 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 9 3.2 % 54.00 39.80 137.88

CSL4 Electronic Pulse 208/277 267.1 93.6% 51.64 39.80 1 34.41 Note: “Tri” input voltage means 208, 240, and 277 V. “Quad” adds 120 V to tri

.

5.9 400 WATT METAL HALID E LAMP FIXTURES

In this section, DOE analyzes 400 W metal halide lamp fixture s 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 comp ared 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 el ectronic 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 EISA

compliant fixture and assumed it to be 88% efficient. DOE tore down the ballast, usin g manufacturer

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

.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. D OE 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 f ields 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 th e 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 represen tative 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 s teel , 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 fo r 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, wh ich 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 b allast footprint. A decrease in steel thickness due to the steel grade and no change in the stack height equates to additional5

- 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 Leve l 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 , t he empty fixture cost is the same for each CSL (does not change with increasing efficiency) and is ca lculated 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 a s 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 b y 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 156.7 2

CSL3 18 4.63

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 SummaryCandidate StandardLevelBallast TypeStarting MethodInput VoltageNormalized InputPowerBallast EfficiencyBallastManufacturerProduction CostEmpty FixtureManufacturerProduction CostTotalFixtureManufacturerSelling 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 % 38.54 132.77 156.7 2

CSL3 Electronic Pulse Tri 431.5 92. 7 % 63.95 132.77 18 4.63

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 HALI DE LAMP FIXTURES

In this section, DOE analyzes 1000 W metal halide lamp fixture s 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 e ach 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 p artly because magnetic ballasts can be quite efficient at the 1000 W level and partly because of thermal challenges for high watt age electronic
ballasts

. Pulse

- start ballasts are available at the 1000 W level, but probe

- start, CWA, quad

voltage units predominate. DOE selected the least efficient, quad

- voltage ballast as its baseline. Although the unit happened to be pulse

- start, eff iciency (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. D OE determined the maximum improvement in ballast efficiency that is technologically fea sible (“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 beli eves 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 a vailable 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 sc reening 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 electroni c 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 gr ade 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 improv ement 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
ballast s 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 w attage 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 m agnetic 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 , t he 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 i dentified 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 fo r 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 263.1 8

CSL2 267.6 8

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 Represent a tive Wattage Engineering SummaryCandidate StandardLevelBallast TypeStarting MethodInput VoltageNormalized InputPowerBallast EfficiencyBallastManufacturerProduction CostEmpty FixtureManufacturerProduction CostTotalFixtureManufacturerSelling Price

V W $ $ $

Baseline CWA Pulse Quad 1088.1 91.9% 40.02 132.77 254.00

CSL1 CWA Pulse Quad 10 79.9 92.6% 46.26 132.77 263.1 8

CSL2 CWA Pulse Quad 107 1.8 93.3% 49.32 132.77 267.6 8

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