i

Energy Conservation Standards 

Rulemaking Framework Document for 

Metal Halide Lamp Fixtures 

RIN: 1904-AC00

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

December 18, 2009 

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TABLE OF CONTENTS 

1 INTRODUCTION .................................................................................................................. 1

1.1 The Appliances and Commercial Equipment Standards Program ................................... 2

1.2 Overview of the Scope of Metal Halide Fixture Energy Conservation Standards........... 5

1.2.1 Scope of Existing Energy Conservation Standards .................................................. 5

1.2.2 Scope of Energy Conservation Standards Rulemaking ............................................ 5

1.2.3 Standby Mode and Off Mode Standards ................................................................... 6

1.3 Overview of the Rulemaking Process .............................................................................. 8

1.3.1 Test Procedures ......................................................................................................... 8

1.3.2 Rulemaking Process and Participation of Interested Parties..................................... 8

1.4 Preliminary Analysis ...................................................................................................... 10

1.5 Notice of Proposed Rulemaking .................................................................................... 12

1.6 Final Rule ....................................................................................................................... 12

2 OVERVIEW OF ANALYSES FOR RULEMAKING......................................................... 13

3 MARKET AND TECHNOLOGY ASSESSMENT ............................................................. 15

3.1 Market Assessment ........................................................................................................ 15

3.1.1 Equipment Classes .................................................................................................. 16

3.2 Technology Assessment ................................................................................................. 22

4 SCREENING ANALYSIS ................................................................................................... 24

5 ENGINEERING ANALYSIS ............................................................................................... 25

5.1 Engineering Analysis Overview..................................................................................... 25

5.2 Representative Equipment Classes................................................................................. 26

5.3 Scaling Method .............................................................................................................. 27

5.4 Baseline Models ............................................................................................................. 28

5.5 Cost-Efficiency Relationship and Analysis.................................................................... 29

5.6 Proprietary Designs ........................................................................................................ 30

5.7 Outside Regulatory Changes Affecting the Engineering Analysis ................................ 31

6 ENERGY USE AND END-USE LOAD CHARACTERIZATION .................................... 31

7 MARKUPS FOR EQUIPMENT PRICE DETERMINATION ............................................ 32

8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES ......................................... 34

8.1 Energy Prices.................................................................................................................. 35

8.2 Life-Cycle Cost Discount Rates ..................................................................................... 36

8.3 Metal Halide Lamp Fixture Lifetimes ............................................................................ 36

8.4 Installation, Maintenance, and Repair Costs .................................................................. 36

9 SHIPMENTS ANALYSIS ................................................................................................... 37

9.1 Base-Case Forecast ........................................................................................................ 37

9.2 Accounting Methodology ............................................................................................... 38

9.3 Standards Impacts on Metal Halide Lamp Fixture Shipments....................................... 39

10 NATIONAL IMPACT ANALYSIS ..................................................................................... 39

10.1 Inputs to Forecasts ...................................................................................................... 40

10.2 Calculation of National Energy Savings .................................................................... 42

10.3 Net Present Value of Consumer Savings .................................................................... 42

11 LIFE-CYCLE COST SUBGROUP ANALYSIS ................................................................. 43

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12 MANUFACTURER IMPACT ANALYSIS......................................................................... 43

12.1 Sources of Information for the Manufacturer Impact Analysis .................................. 44

12.2 Industry Cash-Flow Analysis ..................................................................................... 45

12.1 Manufacturer Subgroup Analysis ............................................................................... 45

12.2 Competitive Impacts Analysis .................................................................................... 45

12.3 Cumulative Regulatory Burden .................................................................................. 46

13 UTILITY IMPACT ANALYSIS .......................................................................................... 47

14 EMPLOYMENT IMPACT ANALYSIS .............................................................................. 47

15 ENVIRONMENTAL ASSESSMENT ................................................................................. 48

16 MONETIZATION OF EMISSIONS REDUCTIONS.......................................................... 50

17 REGULATORY IMPACT ANALYSIS .............................................................................. 53

APPENDIX A – LIST OF ITEMS FOR COMMENT ................................................................. 53

APPENDIX B – DEFINITIONS .................................................................................................. 56

APPENDIX C – ENERGY INDEPENDENCE AND SECURITY ACT OF 2007 ..................... 59

LIST OF TABLES 

Table 1.1 Rulemaking Schedule for Metal Halide Lamp Fixtures Energy Conservation Standard

....................................................................................................................................................... 10

Table 3.1 EPCA Equipment Categories Established by EISA 2007 for Metal Halide Lamp 

Ballasts .......................................................................................................................................... 17

Table 3.2 Initial Equipment Classes ............................................................................................. 22

Table 5.1 Initial Representative Equipment Classes..................................................................... 27

Table 5.2 Initial Baseline Models ................................................................................................. 28

Table 8.1 Inputs to the Life-Cycle Cost and Payback Period Analyses ....................................... 35

Table 10.1 Inputs to the National Impact Analysis....................................................................... 41

LIST OF FIGURES 

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard 

Rulemaking 14

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LIST OF ACRONYMS 

AEO Annual Energy Outlook 

ANSI American National Standards Institute 

BOM bill of materials 

BT Building Technologies Program 

C Celsius 

CAIR Clean Air Interstate Rule

CAMR Clean Air Mercury Rule 

CBECS Commercial Building Energy Consumption Survey 

CFR Code of Federal Regulations 

CO2 carbon dioxide 

CSL candidate standard level 

CWA constant-wattage autotransformer 

CWI constant-wattage isolated autotransformer

DALI digital addressable lighting interface 

DC District of Columbia 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

EGU electricity generating unit 

EIA Energy Information Administration 

EISA 2007 Energy Independence and Security Act of 2007 

EMI electromagnetic interference 

EPA U.S. Environmental Protection Agency 

EPACT 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act 

FCC Federal Communications Commission 

FR Federal Register 

FTC Federal Trade Commission 

GHG greenhouse gas emissions 

GRIM Government Regulatory Impact Model 

GSFL general service fluorescent lamp 

GSIL general service incandescent lamp 

Hg mercury 

HID high intensity discharge 

HX-HPF high-reactance autotransformer 

Hz Hertz 

ImSET Impact of Sector Energy Technologies 

IQ intelligence quotient 

IRL incandescent reflector lamp 

kWh kilowatt hour 

LCC life-cycle cost 

LMC U.S. Lighting Market Characterization 

mag-reg magnetically regulated lamp ballast 

MECS Manufacturer Energy Consumption Survey 

MIA manufacturer impact analysis 

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MPC manufacturer production cost 

MSP manufacturer selling price 

NCI Navigant Consulting, Inc. 

NEMS National Energy Modeling System 

NEMS-BT National Energy Modeling System – Building Technologies 

NES national energy savings 

NIA national impact analysis 

NOPR notice of proposed rulemaking 

NOX oxides of nitrogen 

NPV net present value 

OEM original equipment manufacturer 

OMB U.S. Office of Management and Budget 

PBP payback period 

PM particulate matter 

RoHS Restriction on Hazardous Substance 

SCC social cost of carbon 

SEC U.S. Securities and Exchange Commission 

SO2 sulfur dioxide 

TSD technical support document 

TSL trial standard level 

UL Underwriters Laboratories 

U.S.C. United States Code 

V volt 

W watt 

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Rulemaking Framework Document for Metal Halide Lamp Fixtures 

1 INTRODUCTION 

The U.S. Department of Energy (DOE) Appliances and Commercial Equipment 

Standards Program, within the Office of Energy Efficiency and Renewable Energy‘s Building 

Technologies Program (BT), develops and promulgates test procedures and energy conservation 

standards for certain consumer appliances and commercial equipment. The process for 

developing standards involves analysis, public notice and comment, and consultation with 

interested parties. ―Interested parties‖ include manufacturers, consumers, energy conservation 

and environmental advocates, State and Federal agencies, and any other groups or individuals 

with an interest in these standards and test procedures. A DOE Report to Congress1

 submitted on 

January 31, 2006, which has been updated twice a year since first publication, identifies the 

numerous rulemakings for a variety of products that DOE has scheduled for completion by 

January 2015 and explains many of the techniques DOE will be applying during the rulemaking 

process to meet this schedule. 

The purpose of this document is to describe the procedural and analytical approaches 

DOE anticipates using to evaluate potential amended energy conservation standards for metal 

halide lamp fixtures (see section 1.1 below for a discussion of the statutory authority for this 

rulemaking). This document is intended to inform interested parties of the process DOE will 

follow for the standards rulemaking for these metal halide lamp fixtures and to encourage and 

facilitate the input of interested parties during the rulemaking. This document is merely the 

starting point for developing energy conservation standards and is not a definitive statement on 

any issue to be determined in the rulemaking. 

Section 1 of this report provides an overview of DOE‘s rulemaking process. Sections 2 

through 16 discuss analyses DOE intends to conduct to fulfill the statutory requirements and 

guidance for this particular energy conservation standards rulemaking. The foundation of this 

rulemaking includes a statutory mandate to determine whether to amend statutorily-prescribed 

energy conservations standards for ―metal halide lamp fixtures,‖ which specify requirements for 

several distinct types of metal halide lamp ballasts commonly found in such fixtures. DOE will 

analyze each fixture type to determine whether amended energy conservation standards are 

technologically feasible, economically justified, and would result in significant energy savings. 

DOE will maintain information about this rulemaking on its website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_bal

lasts.html. 

 

1 Energy Conservation Standards Activities; Submitted Pursuant to Section 141 of the Energy Policy Act of 

2005(EPACT 2005) and in response to section 305 of the Energy Independence and Security Act of 2007 (EISA 

2007), Pub. L. 110-140; U.S. Department of Energy (August 2009). Available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/seventh_report_congress_aug_09.pdf. 

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While DOE invites comment on all aspects of the material presented in this document, 

several specific issues on which DOE seeks comment are set out in comment boxes like this 

one. DOE uses these comment boxes to highlight issues and ask specific questions on the 

approaches DOE plans to follow to conduct the analyses required for the energy 

conservation standards rulemaking. Such requests for feedback are numbered sequentially 

throughout the document and are repeated in appendix A. 

1.1 The Appliances and Commercial Equipment Standards Program 

Title III of the Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163, (42 

United States Code (U.S.C.) 6291 et seq.) established an energy conservation program for major 

household appliances and industrial and commercial equipment. More specifically, Part A of 

Title III (42 U.S.C. 6291-6309) establishes the ―Energy Conservation Program for Consumer 

Products Other Than Automobiles.‖ Subsequent amendments to EPCA have given DOE the 

authority to regulate the energy efficiency of several additional kinds of equipment, including 

certain metal halide lamp fixtures, which is the focus of this document. 

The discussion below summarizes the pertinent legislative and regulatory history for 

metal halide lamp fixtures, and it sets the stage for the issues raised in the balance of this 

framework document. Through the framework document, DOE is initiating its first rulemaking 

cycle to review and consider amendments to the energy conservation standards in effect for 

metal halide lamp fixtures, as required under 42 U.S.C. 6295(hh)(2), which provides as follows: 

(2) Final rule by January 1, 2012. — 

 (A) In general. — 

Not later than January 1, 2012, the Secretary shall publish a final rule to 

determine whether the standards established under paragraph (1) should be 

amended. 

 (B) Administration. — 

The final rule shall— 

(i) contain any amended standard; and 

(ii) apply to products manufactured on or after January 1, 2015. 

By way of background, on December 19, 2007, the President signed the Energy 

Independence and Security Act of 2007 (EISA 2007) (Pub. L. 110-140), which made numerous 

amendments to EPCA and directed DOE to undertake several new rulemakings for appliance 

energy conservation standards. For a complete listing of the metal halide lamp fixtures 

provisions contained in EISA 2007, please see appendix D of this framework document. To 

summarize these metal halide lamp fixture provisions (as more fully explained below), section 

324 of EISA 2007 amended EPCA by: 

Inserting definitions pertaining to ―metal halide ballast,‖2 ―metal halide lamp,‖

3

 and 

―metal halide lamp fixtures‖

4

 (among others) into section 321 of EPCA (42 U.S.C. 

6291(62),(63), and (64)); 

 

2

 ―Metal halide ballast‖ means ―a ballast used to start and operate metal halide lamps.‖ (42 U.S.C 6291(62)) 

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Amending section 323(b) of EPCA to direct DOE to develop a test procedure for metal 

halide lamp ballasts based on the American National Standard Institute (ANSI) Standard 

C82.6-2005, American National Standard for Lamp Ballasts-Ballasts for High-Intensity 

Discharge (HID) Lamps-Methods of Measurement (42 U.S.C. 6293(b)(18)); 

Amending section 324(a)(2) of EPCA by directing the Federal Trade Commission (FTC) 

to conduct a labeling rulemaking for metal halide lamp fixtures (42 U.S.C. 

6294(a)(2)(C)); and 

Amending section 325 of EPCA by prescribing energy conservation standards for metal 

halide lamp fixtures that require the equipment to contain ballasts that meet or exceed 

defined efficiency levels. Compliance with the EISA 2007-prescribed standards was 

required as of January 1, 2009. (42 U.S.C. 6295(hh)(1)) Additionally, the Secretary is 

directed to publish a final rule no later than January 1, 2012, after publication to 

determine whether the energy conservation standards established by EISA 2007 for metal 

halide lamp fixtures should be amended, and if such amended standards are appropriate 

under the relevant statutory criteria, the final rule shall also contain amended standards 

for those products which shall apply to products manufactured on or after January 1, 

2015. (42 U.S.C. 6295(hh)(2)). The Secretary is further directed to conduct a second 

rulemaking to review and amend its energy conservation standards for metal halide lamp 

fixtures, which requires publication of a final rule by January 1, 2019. (42 U.S.C. 

6295(hh)(3)) 

 The following statutory provisions are directly relevant to the energy conservation 

standards rulemaking for metal halide lamp fixtures that is the subject of this framework 

document. As amended by EISA 2007, EPCA regulates metal halide lamp fixtures designed to 

be operated with lamps rated greater than or equal to 150 watts (W) but less than or equal to 

500W by prescribing performance requirements for the metal halide lamp ballasts used in those 

metal halide lamp fixtures. Both metal halide lamps and ballasts are energy-consuming 

components of metal halide fixtures. For this metal halide lamp wattage range, metal halide lamp 

fixtures must contain: 

(i) a pulse-start metal halide ballast with a minimum ballast efficiency of 88 percent; 

(ii) a magnetic probe-start ballast with a minimum ballast efficiency of 94 percent; or 

(iii) a nonpulse-start electronic ballast with— 

(I) a minimum ballast efficiency of 92 percent for wattages greater than 250 

watts; and 

(II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 

250 watts. 

(U.S.C 6292 (hh)(1)(A)) 

 

3

 ―Metal halide lamp‖ means ―a high intensity discharge lamp in which the major portion of the light is produced by 

radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors.‖ (42 

U.S.C 6291(63)) 

4

 ―Metal halide lamp fixture‖ means ―a light fixture for general lighting application designed to be operated with a 

metal halide lamp and a ballast for a metal halide lamp.‖ (42 U.S.C 6291(64)) 

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 In addition to prescribing minimum efficiency requirements for the above-described 

metal halide lamp ballasts contained in metal halide lamp fixtures, EISA 2007 amended EPCA to 

exclude the following types of metal halide lamp fixtures from the statutorily-prescribed energy 

conservation standards: 

 

(i) fixtures with regulated lag ballasts; 

(ii) fixtures that use electronic ballasts that operate at 480 volts; or 

(iii) fixtures that— 

(I) are rated only for 150 watt lamps; 

(II) are rated for use in wet locations, as specified by the National Electrical Code 

2002, section 410.4(A); and 

(III) contain a ballast that is rated to operate at ambient air temperatures above 50° 

C, as specified by UL [Underwriters Laboratories] 1029–2001 [―Standard for 

High-Intensity-Discharge Lamp Ballasts‖].

(42 U.S.C 6292 (hh)(1)(B)) 

 Pursuant to section 310 of EISA 2007, EPCA further directs DOE to incorporate standby 

mode and off mode energy use in any amended (or new) standard adopted after July 1, 2010. (42 

U.S.C. 6295(gg)(3)) Because this energy conservation standards rulemaking must be completed 

by January 1, 2012, the requirement to incorporate standby mode and off mode energy use into 

the energy conservation standards analysis is applicable. The application of standby mode and 

off mode energy use in this rulemaking is discussed in detail in section 1.2.3. 

The following statutory provisions (and associated rulemakings) are related to metal 

halide lamp fixtures generally but are separate from and not directly related to the current 

standards rulemaking. 

 • In conjunction with energy conservation standards for metal halide lamp fixtures, EPCA 

requires DOE to undertake a determination to see if energy conservation standards for 

high intensity discharge (HID) lamps (including metal halide lamps) would be 

technologically feasible and economically justified, and would result in significant 

energy savings. (42 U.S.C 6317(a)(1)) DOE must complete the HID determination by 

June 2010. 

 • Additionally, as discussed in section 1.3.1, DOE will complete a test procedure 

rulemaking for metal halide lamp ballasts, as required by EPCA through amendments 

from EISA 2007. (U.S.C 6293(b)(18)) In furtherance of this obligation, DOE published 

a notice of proposed rulemaking for this test procedure in the Federal Register on July 

10, 2009. 74 FR 33171. 

 • As part of the requirements set forth by EISA 2007 for metal halide lamp fixtures, the 

FTC is directed to conduct a labeling rulemaking. (42 U.S.C. 6294(a)(2)(C)) To this end, 

the FTC published a final rule in the Federal Register on July 9, 2008, amending 16 Code 

of Federal Regulations (CFR) Part 305, ―Rule Concerning Disclosures Regarding Energy 

Consumption and Water Use of Certain Home Appliances and Other Products Required 

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Under the Energy Policy and Conservation Act ( ̳Appliance Labeling Rule‘).‖ 73 FR 

39221. On October 23, 2008, the FTC published in the Federal Register additional 

amendments to 16 CFR part 305 for metal halide lamp fixtures in the form of technical 

corrections. 73 FR 63066. Both final rules fulfilled the FTC‘s obligations under EISA 

2007 pertaining to labeling requirements for metal halide lamp fixtures and metal halide 

lamp ballasts. 

1.2 Overview of the Scope of Metal Halide Fixture Energy Conservation Standards 

1.2.1 Scope of Existing Energy Conservation Standards 

As noted above, the existing energy conservation standards for metal halide lamp fixtures 

are established by EPCA through amendments made by EISA 2007. (U.S.C 6292(hh)(1)(A)) 

EISA 2007 prescribed energy conservation standards for metal halide lamp fixtures by setting 

minimum ballast efficiency requirements for new fixtures. The performance requirements 

prescribed by EISA 2007 pertain to new fixtures manufactured after January 1, 2009. Currently, 

coverage is determined by selected rated wattages of lamps used in the metal halide lamp 

fixtures (150W to 500W). Such lamps must be equipped with a ballast with a designated starting 

method (pulse-start and probe-start) and electronic configuration (magnetic or electromagnetic 

and electronic). However, the statute excludes from coverage metal halide lamp fixtures with 

regulated lag ballasts, electronic ballasts that operate at 480 volts (V), and fixtures that: (1) are 

rated only for 150W lamps, (2) are rated for use in wet locations,5 and (3) contain a ballast that is 

rated to operate at ambient air temperatures above 50 °Celsius (C).6

1.2.2 Scope of Energy Conservation Standards Rulemaking 

EPCA gives DOE authority to determine whether current energy conservation standards 

for metal halide lamp fixtures should be amended. (42 U.S.C. 6295(hh)(2)(A)) DOE notes that 

though metal halide fixtures may be composed of a metal halide lamp and metal halide ballast, in 

establishing metal halide fixture energy conservation standards, EPCA set minimum efficiency 

requirements for only the ballast component of the fixture. As DOE is evaluating minimum 

efficiency requirements for metal halide lamps in a separate rulemaking (the HID determination), 

DOE has preliminarily decided that in amending metal halide fixture standards, DOE will only 

evaluate amending minimum ballast efficiency requirements, consistent with the current 

statutory approach. DOE welcomes comment on its approach of amending only minimum ballast 

efficiency requirements as part of the metal halide lamp fixture energy conservation standards 

rulemaking. 

DOE interprets its statutory mandate as permitting consideration of changes to the 

existing scope of energy conservation standards to include currently excluded equipment or 

equipment not captured in the existing regulation (due to the 150W-500W lamp wattage 

limitation) that could provide significant energy savings. A wide variety of metal halide lamp 

fixtures are not covered by existing energy conservation standards. Accordingly, these metal 

halide lamp fixtures are potential candidates for expanded coverage pursuant to 42 U.S.C. 

 

5

 Specifications for ―wet locations‖ are from the National Electrical Code 2002, section 410.4(A). 

6

 Specifications for ballasts that operate at ambient air temperatures above 50 °C are found in UL 1029-2001.

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6295(hh)(2)(A). Significant additional energy savings may be possible by regulating fixtures that 

operate lamps with additional rated lamp wattages and metal halide ballasts exempted by EISA 

2007, through requirements on their ballasts‘ efficiency. 

DOE is considering expanding its coverage of energy conservation standards to include 

all metal halide lamp fixtures that operate lamps rated to less than 150W and above 500W 

because of the potential for significant energy savings. Similar to the current standards, energy 

savings would be achieved through requirements on the ballasts for those fixtures. DOE‘s initial 

review of ballast manufacturer catalogs (an indication of product availability of fixtures) shows 

many types of metal halide lamp ballasts outside the lamp rated wattage range of currently

regulated fixtures are available in the market. The catalogs also show that approximately 30 

percent of available metal halide ballasts are designed for lamps rated below 150W. 

Approximately 13 percent of available metal halide ballasts are designed for lamps rated above 

500W. DOE has tentatively concluded that there is potential for significant energy savings by 

including the entire range of lamp rated wattage for the analysis. DOE invites comments on its 

planned expansion of scope for metal halide lamp fixtures that operate lamps rated less than 

150W and above 500W. 

DOE is also considering expanding its coverage of energy conservation standards to 

include metal halide fixtures excluded by EISA 2007, including fixtures with regulated lag 

ballasts; electronic ballasts that operate at 480V; and ballasts that are rated only for 150W lamps, 

are rated for use in wet locations, and are rated to operate at ambient air temperatures above 50 

°C. (42 U.S.C 6292 (hh)(1)(B)) Although DOE‘s initial review of ballast manufacturer catalogs 

indicates that a small number of excluded fixtures is available in the market, DOE has limited 

information on those products and consequently intends to explore further the potential energy 

savings for this equipment. DOE invites comments on its planned expansion of coverage to 

include metal halide lamp fixtures excluded by EISA 2007. 

 

A detailed initial consideration of scope, including the rationale for coverage for 

individual fixtures, will be published with DOE‘s preliminary analysis. DOE invites comment on 

its planned expansion of scope for metal halide lamp fixtures. 

1.2.3 Standby Mode and Off Mode Standards 

DOE is directed to incorporate standby mode and off mode energy use in any amended 

energy conservation standard adopted after July 1, 2010. (42 U.S.C. 6295(gg)(3)) Because this 

energy conservation standards rulemaking will be completed by January 1, 2012, the requirement 

to incorporate standby mode and off mode energy use into the energy conservation standards 

analysis is applicable. 

In amending 42 U.S.C. 6295(gg)(1)(A)(i), (ii), and (iii), section 310 of EISA 2007 

defined the terms ―active mode,‖ ―off mode,‖ and ―standby mode.‖ ―Active mode‖ is defined as 

the condition in which an energy-using piece of equipment is connected to a main power source, 

has been activated, and provides one or more main functions. ―Off mode‖ is defined as the 

condition in which an energy-using piece of equipment is connected to a main power source, and 

is not providing any standby or active mode function. ―Standby mode‖ is defined as the 

condition in which an energy-using piece of equipment is connected to a main power source and 

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offers one or more of the following user-oriented or protective functions: facilitating the 

activation or deactivation of other functions (including active mode) by remote switch (including 

remote control), internal sensor, or timer; or providing continuous functions, including 

information or status displays (including clocks) or sensor-based functions. 

In developing the metal halide lamp ballast test procedure, DOE proposed adopting the 

statutory definitions of ―active mode,‖ ―off mode,‖ and ―standby mode‖ and analyzed them to 

determine their applicability to metal halide lamp ballasts. DOE tentatively found that while it is 

possible for metal halide ballasts to operate in active mode and standby mode, the off mode 

condition does not apply because it addresses a mode of energy use in which metal halide 

ballasts do not operate. 74 FR 33171, 33175 (July 10, 2009). The definition of ―off mode‖

requires that ballasts be connected to a main power source and not provide any standby mode or 

active mode function. (42 U.S.C. 6295(gg)(1)(A)(ii)) As discussed in the proposed test 

procedure, DOE does not believe there is any condition in which the ballast is connected to the 

main power source and is not already accounted for in either active mode or standby mode. 

Therefore, for this metal halide lamp fixtures energy conservation standard rulemaking, DOE is 

only considering the active mode and standby mode energy use provisions from EISA 2007 

applicable to metal halide lamp fixtures that are (or could be) covered by this rulemaking. DOE 

has tentatively concluded that no further consideration of power consumption in off mode is 

necessary. 

DOE recognizes that metal halide ballasts can be designed with auxiliary control devices, 

which may consume energy in standby mode. One example of this ballast design is a DALI7-

enabled ballast. These ballasts may consume power in standby mode, as the internal circuitry 

that is integral to the design of the ballast remains on and active even when the ballast is not 

driving any lamps. DOE continues to study DALI-enabled ballasts, as well as other types of 

metal halide lamp ballasts, to evaluate the issue of standby mode energy use in metal halide lamp 

fixtures. DOE invites comments on this issue of standby mode and off mode energy use. 

Item 1 DOE welcomes comment on its approach of amending only minimum ballast 

efficiency requirements, and not lamp efficiency requirements, as part of the metal 

halide lamp fixture energy conservation standards rulemaking. 

Item 2 DOE welcomes comments on the expansion of the scope of this rulemaking to 

potentially include all metal halide lamp fixtures that operate lamps rated to less than 

150W and above 500W, in addition to those fixtures already covered by standards 

which operate lamps in the 150W to 500W range. 

Item 3 DOE welcomes comments on the expansion of the scope of this rulemaking to 

include all metal halide lamp fixtures currently excluded under 42 U.S.C. 

6295(hh)(1)(B). 

 

7

 DALI stands for the ―Digital Addressable Lighting Interface.‖ It represents a system that enables communication 

between a central lighting controls system and the individual components, including the ballasts. 

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Item 4 DOE welcomes comment on issues arising from the standby mode and off 

mode provisions from EISA 2007, including: (a) whether DOE should modify its test 

procedure for metal halide lamp ballasts, and if so, how; (b) whether metal halide lamp 

fixtures consume energy in off mode, and if so, which ones; (c) which covered metal 

halide lamp fixtures use energy in standby mode; and (d) how DOE should incorporate 

standby mode energy consumption into its analysis for the energy conservation 

standard. 

1.3 Overview of the Rulemaking Process 

1.3.1 Test Procedures 

EPCA directs DOE to establish test procedures for metal halide lamp ballasts that are in 

accord with ANSI Standard C82.6-2005, ―Ballasts for High Intensity Discharge Lamps—

Methods of Measurement.‖ (42 U.S.C. 6293(b)(18)) DOE published the notice of proposed 

rulemaking for the test procedure for metal halide lamp ballasts on July 10, 2009, which included 

definitions and test procedures for that equipment. 74 FR 33171. Additionally, the proposed test 

procedure provides a method for measuring the standby mode of metal halide lamp ballasts. If 

these ANSI test procedures are updated during the course of this rulemaking, DOE will consider 

updating its test procedure for metal halide lamp ballasts. 

Item 5 DOE welcomes comments on the issue of whether it is necessary to update the 

metal halide lamp ballast test procedure, and if so, how. 

1.3.2 Rulemaking Process and Participation of Interested Parties 

EPCA specifies that any standard DOE prescribes for consumer products shall be 

designed to ―achieve the maximum improvement in energy efficiency . . . which the Secretary 

[of Energy] determines is technologically feasible and economically justified.‖ (42 U.S.C. 

6295(o)(2)(A)) Moreover, EPCA states that the Secretary may not establish an amended standard 

if such standard would not result in ―significant conservation of energy,‖ or ―is not 

technologically feasible or economically justified.‖ (42 U.S.C. 6295(o)(3)(B)) When DOE 

evaluates any new or amended energy conservation standard for covered products under EPCA, 

DOE considers to the greatest extent practicable the following seven factors to determine 

whether a standard is economically justified: 

(1) The economic impact of the standard on the manufacturers and on the consumers of the 

products subject to such standard; 

(2) The savings in operating costs throughout the estimated average life of the covered 

products in the type (or class) compared to any increase in the price, or in the initial 

charges for, or maintenance expenses of the covered products which are likely to result 

from the imposition of the standard; 

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(3) The total projected amount of energy (or as applicable, water) savings likely to result 

directly from the imposition of the standard; 

(4) Any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

(5) The impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

(6) The need for national energy and water conservation; and 

(7) Other factors the Secretary considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) 

Additional statutory requirements of general applicability for prescribing new or amended 

standards are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)-(iii), and (3)–(5). 

The process for developing energy conservation standards involves analysis, public 

notice and comment, and consultation with interested parties. Interested parties generally include 

manufacturers, consumers, environmental advocates, State and Federal agencies, and other 

groups and individuals with an interest in energy conservation standards and test procedures. 

DOE considers the participation of interested parties to be a very important part of the 

rulemaking process. Accordingly, DOE encourages the participation of all interested parties 

during the comment period provided at each stage of the rulemaking. The broad array of 

interested parties who routinely provide comments promotes a balanced discussion of critical 

information required to conduct the standards rulemaking, beginning with public comments on 

the framework document. 

In conducting the test procedure rulemakings and the energy conservation standards 

rulemakings, DOE involves interested parties through a variety of means. As discussed in further 

detail below, the standards rulemaking process involves three public notices, which are published 

in the Federal Register following publication of the framework document. Publication of the 

preliminary analyses as well as the notice of proposed rulemaking (NOPR) will be accompanied 

by public meetings to solicit comment from interested parties to enhance the rulemaking process. 

 • Preliminary Analysis (section 1.4). The preliminary analysis is designed to publicly vet 

the models and tools that DOE will use in the rulemaking, and to facilitate public 

participation before the proposed rule stage. Candidate standard levels, which span the 

range of efficiencies from baseline equipment to the most efficient technology, are the 

basis for demonstrating the functionality of the models and tools. 

 • Notice of Proposed Rulemaking (section 1.5). The NOPR presents a discussion of 

comments received in response to the preliminary analysis; DOE‘s analysis of the 

impacts of potential standards on consumers, manufacturers, and the Nation; DOE‘s 

weighting of these impacts; and the proposed standard levels for public comment. 

 • Final Rule (section 1.6). The final rule presents a discussion of comments received in 

response to the NOPR, the revised analysis of the impacts of standards, DOE‘s weighting 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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of the impacts, and the standard levels DOE is adopting. The final rule also establishes 

the compliance date of the standards. 

DOE has prepared and intends to follow the schedule below for the metal halide lamp 

fixtures rulemaking. 

Table 1.1 Rulemaking Schedule for Metal Halide Lamp Fixtures Energy Conservation 

Standard 

Rulemaking Notice Publication Date

Framework Document December 2009

Preliminary Analysis August 2010

NOPR June 2011

Final Rule January 1, 2012

 The statute provides that any amended energy conservation standard for metal halide 

lamp fixtures will apply to products manufactured on or after January 1, 2015. (42 U.S.C 

6295(hh)(2)(B)(ii)) 

 

1.4 Preliminary Analysis 

As part of its initial rulemaking activity, DOE typically identifies equipment technology 

options and makes a preliminary determination on whether to retain that option for detailed 

analysis or to eliminate it from further consideration. This process includes a market and 

technology assessment (section 3) and a screening analysis (section 4). DOE applies four 

screening criteria in the screening analysis to determine which technology options to eliminate 

from further consideration. These four criteria are: (1) technological feasibility; (2) practicability 

to manufacture, install, and service; (3) adverse impacts on product utility or availability; and (4) 

adverse impacts on health or safety. Technologies that pass through the screening analysis are 

referred to as design options in the engineering analysis. 

DOE consults with interested parties and independent technical experts to identify the 

key issues and design options or efficiency levels that DOE will consider in the rulemaking. 

DOE initiates that dialogue with this framework document, the public meeting following its 

publication, and the request for public comment. This provides an opportunity for input into the 

structural and analytical approach planned for this energy conservation standards rulemaking. 

At the start of the preliminary analysis, DOE considers design options or efficiency levels 

for each equipment class. DOE uses these design options or efficiency levels to collect 

manufacturer cost data, historical shipment data, shipment-weighted average efficiency data, and 

preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing costs, 

and research and development costs). Concurrent with the preliminary analysis, DOE also 

conducts other principal analyses, including: (1) the engineering analysis (section 5); (2) the 

consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 8); (3) the national 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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impact analysis, which considers national energy savings (NES) and consumer net present value 

(NPV) (section 10); and (4) a preliminary manufacturer impact analysis (section 12). DOE will 

present the results of these analyses in the preliminary analysis technical support document 

(TSD). 

 Based on the results of the preliminary analysis, DOE selects candidate standard levels8

(CSLs) from the energy efficiency or energy use levels considered in the preliminary analysis. 

Discussion of various candidate standard levels in the preliminary analysis will help interested 

parties review the spreadsheet models that underpin the analyses. DOE will use interested 

parties‘ comments to refine the models for the next stage of the rulemaking analyses, where DOE 

will propose specific efficiency levels for adoption. In addition to the efficiency corresponding to 

the maximum technologically-feasible (―max-tech‖) design and the efficiency corresponding to 

the minimum LCC point, DOE generally considers levels or design options that span the full 

range of technologically-achievable efficiencies. The range of levels DOE typically analyzes 

includes: 

• The baseline efficiency level (i.e., the minimum level), which is defined by the type of 

equipment with the lowest energy efficiency level currently sold on the market for a 

given category. For equipment categories where minimum energy conservation standards 

already exist, the baseline efficiency level is typically defined by the existing energy 

conservation standard; 

• The level with the minimum LCC or greatest LCC savings; 

• The highest energy efficiency level or lowest energy consumption level that is 

technologically feasible (i.e., max-tech); and 

• Levels that incorporate noteworthy technologies or fill in large gaps between other 

efficiency levels considered. 

 At the preliminary analysis stage, DOE uses analytical models and tools to assess the 

different equipment classes at each efficiency or energy use level analyzed. Many of these 

analytical models and tools are in the form of spreadsheets, which are used to conduct the LCC 

and PBP analyses and to determine the national energy savings and NPV of prospective 

standards. In addition, preliminary analytical results may facilitate discussions among interested 

parties on potential joint recommendations for standard levels. 

 DOE will make the spreadsheet tools and results of the preliminary analysis available on 

its website for review.9 When it publishes the preliminary analysis, DOE will also make a TSD 

available containing the details of all the analyses performed to date. After publication of the 

 

8

 CSLs are a set of efficiency levels considered in the preliminary analysis that spans the range of ballast 

efficiencies from baseline equipment to maximum technologically feasible equipment. 

9

 All materials associated with the rulemakings for metal halide lamp fixtures test procedures and energy 

conservation standards are available on DOE‘s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_ballasts.html. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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preliminary analysis, DOE will provide a 60-day public comment period and hold one public 

meeting. At that point, DOE encourages interested parties to develop joint recommendations for 

standard levels. 

1.5 Notice of Proposed Rulemaking 

In developing the NOPR, DOE will consider all the comments it received after 

publication of the preliminary analysis. This process may result in revisions to the preliminary 

analysis, including the engineering and LCC analyses. At this point, DOE will conduct additional 

economic and environmental impact analyses. These analyses generally include a consumer LCC 

subgroup analysis (section 11), a complete manufacturer impact analysis (section 12), a utility 

impact analysis (section 13), an employment impact analysis (section 14), an environmental 

assessment (section 15), and a regulatory impact analysis (section 17).

 DOE will describe the methodology used and make the results of all the analyses 

available on its website for review. Based on comments from interested parties, further revisions 

to the analysis may be made. This analytical process ends with the selection of proposed standard 

levels (if any) that DOE will present in the NOPR. DOE selects the proposed standard levels 

from the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking. The 

NOPR, published in the Federal Register, will document the evaluation and selection of any 

proposed standards levels, along with a discussion of other TSLs considered but not selected and 

the reasons DOE did not select them. 

For each equipment class, DOE will identify the max-tech efficiency level. If DOE 

proposes a lower level, it will sequentially explain the reasons for eliminating higher levels, 

beginning with the highest level considered. DOE will present the analytical results in the 

NOPR, and provide the details of the analysis in an accompanying TSD. 

DOE considers many factors in selecting proposed standards, as discussed in section 

1.3.2. These factors are contained in EPCA and take into consideration the benefits, costs, and 

impacts of energy conservation standards. Additionally, DOE encourages interested parties to 

develop joint recommendations for standard levels. DOE will carefully consider such 

recommendations in its decision process. 

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with 

copies of the NOPR and TSD to solicit feedback on the impact of the proposed standard levels 

on competition in both the metal halide lamp fixtures and metal halide lamp ballasts industries. 

DOJ will review these standard levels in light of any lessening of competition likely to result 

from the imposition of standards (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)). Publication of the 

NOPR will be followed by a 60-day public comment period that includes one public meeting. 

1.6 Final Rule 

After publication of the NOPR, DOE will consider public comments it receives on the 

proposal and accompanying analyses. DOE will review the engineering and economic impact 

analyses and proposed standards based on these comments and consider modifications where 

necessary. Before the final rule is issued, DOE also will consider DOJ comments on the NOPR 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
13

relating to the impacts of the proposed standard levels on competition to determine whether 

changes to these standard levels are needed. DOE will publish the DOJ comments and DOE‘s 

response as part of the final rule. 

The standards rulemaking will conclude with publication of the final rule. DOE will 

select the final standard level based on the complete record of the standards rulemaking. The 

final rule will promulgate the final standard level and the effective date and explain the basis for 

their selection. The final rule will be accompanied by a final TSD. 

2 OVERVIEW OF ANALYSES FOR RULEMAKING 

The purpose of the analyses is to ensure that DOE selects energy conservation standards 

that achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified and will result in significant energy savings, as required by EPCA. 

Economic justification includes the consideration of economic impacts on domestic 

manufacturers and consumers, national benefits including environmental impacts, issues of 

consumer utility, and impacts from any lessening of competition. DOE expects the selection of 

such standards to achieve the maximum energy savings that are technologically feasible and 

economically justified without imposing excessive financial burden on any particular party. 

Figure 1 summarizes the analytical components of the DOE standard-setting process. The 

analyses are presented in the center column. Each analysis has a set of key inputs, which are data 

and information required for the analysis. Approaches are the methods that DOE will use to 

obtain key inputs, which may vary depending on the information in question. For example, some 

key inputs exist in public databases; DOE will collect other information from interested parties 

or experts with special knowledge, and DOE will develop yet other information independently in 

support of this rulemaking. The results of each analysis are key outputs, which feed directly into 

the rulemaking. Arrows indicate the flow of information between the various analyses. DOE 

ensures a consistent approach to its analyses throughout the rulemaking by considering each 

analysis as a part of the overall standard-setting framework. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
14

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard 

Rulemaking 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
15

3 MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment will provide information about the manufacturers 

of metal halide lamp fixtures and ballasts and the performance attributes of these equipment. 

Although EPCA directs DOE to consider amended energy conservation standards for metal 

halide lamp fixtures, DOE is considering regulating the lamp component of the fixture in a 

separate rulemaking (the HID determination). Accordingly, the statutorily-prescribed standards 

and DOE‘s plans for amending those standards revolve around changes to the requirements for 

metal halide lamp ballast efficiency. This market and technology assessment is particularly 

important at the outset of the rulemaking for developing equipment classes and for identifying 

technology options that improve ballast efficiency. 

3.1 Market Assessment 

DOE will qualitatively and quantitatively characterize the structure of the markets for 

metal halide lamp fixtures and ballasts. In the market assessment, DOE will identify and 

characterize the manufacturers of this equipment, estimate market shares and trends, address 

regulatory and non-regulatory initiatives intended to improve the efficiency or reduce the energy 

consumption of covered fixtures and ballasts, and explore the potential for technological 

improvements in the design and manufacturing of such equipment. 

This market assessment will establish the context for this rulemaking, and it will serve as 

a resource to guide the analyses that follow. For example, DOE may use historical shipments and 

prices as an indicator of future shipments and prices. Similarly, DOE plans to use market 

structure data for the manufacturer impact analysis, data that will be particularly useful for 

assessing competitive impacts. This phase also allows DOE to start updating design options by 

reviewing equipment literature and industry publications. 

DOE recognizes that there may be limited public information on national shipments, 

manufacturing costs, channels of distribution, and manufacturer market shares of metal halide 

lamp fixtures and ballasts. This type of data is an important input for analyses that determine if 

energy conservation standards are economically justified and will result in significant energy 

savings. Therefore, DOE encourages interested parties to submit data that will improve DOE‘s 

understanding of the metal halide lamp fixtures and ballast markets. These data may be provided 

under a confidentiality agreement with DOE‘s contractor responsible for this part of the 

rulemaking analysis, Navigant Consulting, Inc. (NCI). In other rulemakings, NCI works with 

confidential data provided by manufacturers and other organizations in preparing aggregated 

results for DOE‘s analysis. These aggregated results do not divulge the sensitive, individual raw 

data, but enable other interested parties to comment on the aggregated dataset. 

 Alternatively, interested parties may submit confidential data to DOE, indicating in 

writing which data should remain confidential. Interested parties must submit confidential 

information to DOE according to the procedures outlined in 10 CFR 1004.11. Under 10 CFR 

1004.11, any person submitting information that he or she believes to be confidential and exempt 

by law from public disclosure should submit two copies. One copy of the document shall include 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
16

all the information believed to be confidential, and the other copy shall have the information 

believed to be confidential deleted. DOE will make its own determination about the confidential 

status of the information and treat it accordingly.10

DOE is creating a database of commonly-available equipment based on recent 

manufacturer catalogues from small and large metal halide lamp ballast manufacturers. This 

database will enable DOE to understand which ballasts are available in the market and better 

assess which fixtures should be considered in the expansion of scope (section 1.2). DOE will use 

the resulting knowledge about equipment availability to evaluate how the market may respond to 

various standard levels (e.g., consumers substituting metal halide lamp fixtures that are not 

subject to regulation), and to gain insight on the performance attributes of various commerciallyavailable ballast technologies. 

Item 6 DOE welcomes input on estimates of market shares, equipment, features, and 

efficiency trends for the metal halide lamp fixtures covered in this rulemaking. 

Item 7 DOE welcomes input on manufacturers of covered equipment as well as 

distribution channels used for sales of covered equipment. 

3.1.1 Equipment Classes 

When necessary, DOE divides covered equipment into classes by: (a) the type of energy 

used; (b) the capacity of the equipment; or (c) any other performance-related feature that justifies 

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE 

then conducts its analysis and considers establishing or amending standards to provide separate 

standard levels for each equipment class. 

 In amending EPCA, EISA 2007 effectively set four equipment categories for metal halide 

lamp fixtures based upon the ballasts used and the wattage of the lamps in those fixtures, and in 

prescribing initial energy conservation standards for metal halide lamp fixtures, the statute 

established minimum efficiency requirements for the metal halide lamp ballasts contained in 

those fixtures. (42 U.S.C. 6295(hh)(1)(A)) The current equipment categories for metal halide 

lamp fixtures are presented in Table 3.1. 

 

10

 Factors that DOE considers when evaluating requests to treat submitted information as confidential include: (1) a 

description of the items; (2) whether and why such items are customarily treated as confidential within the industry; 

(3) whether the information is generally known by or available from other public sources; (4) whether the 

information has previously been made available to others without obligation concerning its confidentiality; (5) an 

explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date 

after which such information might lose its confidential character; and (7) why disclosure of the information would 

be contrary to the public interest. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Table 3.1 EPCA Equipment Categories Established by EISA 2007 for Metal Halide Lamp 

Fixtures (by Ballast Type and Lamp Wattage) 

Ballast Type and Starting 

Method

Total Rated Lamp Watts

Pulse-Start ≥ 150W and ≤ 500W 

Magnetic Probe-Start ≥ 150W and ≤ 500W 

Non-Pulse-Start Electronic

≥ 150W and ≤ 250W 

> 250W and ≤ 500W

 As discussed above, the equipment categories for metal halide lamp fixtures set forth in 

Table 3.1 are a composite of ballast type and lamp wattage. For pulse-start metal halide ballasts, 

EPCA does not distinguish by electronic configuration (magnetic or electronic), so fixtures with 

either type of pulse-start ballast would be subject to the statutory standards. Magnetic probestart, pulse-start, and non-pulse-start electronic ballasts are considered separately, and two rated 

lamp wattage ranges are identified for non-pulse-start electronic ballasts, thereby resulting in a 

total of four equipment categories. 

Given DOE‘s statutory directive under 42 U.S.C. 6295(hh)(2) to consider amended 

energy conservation standards for metal halide lamp fixtures, it is necessary to evaluate the 

market to analyze other ballast types applicable to those fixtures. DOE must also consider the 

impacts that the statutorily-prescribed standard levels have had on the metal halide lamp fixtures 

market, as would potentially necessitate a change in the existing equipment classes. 

In addition to the metal halide lamp fixtures identified in Table 3.1, the metal halide lamp 

fixture market includes fixtures that contain ballasts that operate low-wattage (e.g., less than 

150W) and high-wattage (e.g., greater than 500W) lamps. In addition, EISA 2007 exempts 

fixtures that contain certain ballasts such as regulated lag ballasts and electronic ballasts that 

operate at 480 volts. As stated earlier, DOE is considering expanding coverage to these exempted 

fixtures.

DOE has also examined recent market trends. One example is that pulse-start ballasts are 

gaining market share, whereas probe-start ballasts are becoming less popular and consequently, 

are losing market share. This market shift is expected to have accelerated in 2009. Based on an 

initial review of catalog information of commercially-available equipment, the standard levels 

(i.e., the ballast efficiencies) established by EISA 2007 for metal halide lamp fixtures will 

essentially eliminate magnetic probe-start ballasts from the marketplace by requiring a ballast 

efficiency that is not currently attainable with electromagnetic ballast technology. Because 

magnetic ballasts comprised the large majority of metal halide ballast sales in the past, there 

likely will be a further increase in the shipments of metal halide electronic and magnetic pulsestart ballasts when standards prevent the sales of magnetic probe-start ballasts. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Because of these market changes and because DOE is anticipating expanding its scope of 

energy conservation standards for metal halide lamp fixtures, DOE is considering amending the 

equipment classes for these fixtures and their associated ballasts. When determining equipment 

classes, DOE examines characteristics or features commonly found in commercially-available 

equipment such as the type of energy used, equipment capacity, or any other performance-related 

feature that justifies different standard levels. For metal halide lamp fixtures, DOE examined 

several possible characteristics or features that could warrant separation into different equipment 

classes, including: (1) rated lamp wattage; (2) input voltage; (3) number of lamps per ballasts; (4) 

lamp starting method; (5) electronic configuration; and (6) circuit type. Each of the listed 

characteristics or features is discussed below. DOE‘s initial position on possible expansion of 

equipment classes by characteristic or feature is also discussed. 

Rated Lamp Wattage 

 

 An initial review of manufacturer catalogs shows that metal halide lamp ballasts are 

available for lamps with rated wattages as low as 20W and as high as 2,000W. Metal halide lamp 

wattage will vary depending on the application. Lamp wattage affects the utility of the lamp and 

is one of the performance features that determines the amount of light output, intensity, quality, 

and efficiency of the lamp-ballast system. Generally, ballast efficiency increases with higher 

rated wattages. An initial review of manufacturer catalogs show that there are ballast efficiency 

variations within a specific rated wattage. In addition, ballast efficiencies gradually increase as 

rated wattage increase, but reach a certain maximum near the 250W range. 

 

 Reviewing manufacturer catalogs shows that metal halide lamp ballasts can be grouped 

as servicing three main lamp wattage ranges, including: (1) low (less than 150W); (2) medium 

(greater than or equal to 150W but less than or equal to 500W); and (3) high (greater than 

500W). In terms of applications, low-wattage lamps are mainly used in commercial and some 

residential applications for general lighting purposes. Medium-wattage lamps are the most 

widely used and include warehouse, street, and general commercial lighting. High-wattage 

lamps are mainly used in searchlights, stadiums, stage applications, and other applications that 

require powerful white light. 

 

 EISA 2007 separates equipment classes by a single rated lamp wattage range (150W to 

500W) for both pulse-start and probe-start metal halide lamp ballasts. For non-pulse-start metal 

halide lamp ballasts, EISA 2007 separates equipment classes by two rated lamp wattage ranges 

(less than or equal to 250W, and greater than 250W). DOE is considering establishing the 

separation of metal halide lamp fixture equipment classes by including additional lamp wattage 

ranges. In total, potential rated lamp wattage ranges may include less than 150W, greater than or 

equal to 150W but less than or equal to 250W, greater than 250W but less than or equal to 

500W, and greater than 500W. 

 Light output changes as lamp wattage changes. Depending on the application, a specific 

or minimum light output is necessary. Because the rated lamp wattage affects lamp-ballast 

system efficiency, DOE believes each listed rated lamp wattage range has a separate utility 

purpose and different efficiency, thereby warranting a separate standard. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Input Voltage 

 

 An initial review of manufacturer catalogs shows that various metal halide lamp fixtures 

are equipped with metal halide lamp ballasts that operate at several different input voltages. 

Voltage affects the power the ballast uses, as well as I2R losses,11 and, therefore, it affects 

efficiency. Generally, as voltage increases, current decreases, thereby reducing current losses and 

increasing ballast efficiency. Metal halide lamp ballast input voltages range by application and 

are commonly available from the typical residential 120 volts (V) up to industrial applications of 

480V. Additionally, there are types of niche equipment that can operate at 600V input voltage. 

On reviewing manufacturer catalogs, DOE determined that metal halide lamp ballasts can be 

grouped into three main input voltage ranges: (1) residential/commercial (retail) at less than 

150V; (2) commercial/industrial at greater than or equal to 150V but less than or equal to 300V; 

and (3) commercial/industrial at greater than 300V. 

 

 DOE is considering also establishing the separation of metal halide lamp fixture 

equipment classes by including the separation of ballast input voltages. Voltage ranges would 

include common residential to commercial voltages under the less than 150V category, greater 

than or equal to 150V but less than or equal to 300V category, and the greater than 300V. 

According to initial findings from manufacturer catalogs, available ballasts with higher voltages 

tend to have higher efficiency than ballasts with lower voltage. However, some manufacturers do 

not show differences in efficiency for ballasts at different voltages. DOE believes each suggested 

input voltage range has a separate utility purpose and characteristics that affect efficiency, as 

would warrant a separate standard. Additionally, some commercially-available ballasts operate 

at multiple input voltages (universal voltage systems). While manufacturers may achieve some 

economic benefit from producing these ballasts, DOE does not believe that universal voltage 

systems provide additional utility. DOE seeks comments on multiple input voltage ballasts and 

whether DOE should provide a separate class for metal halide lamp fixtures equipped with metal 

halide lamp ballasts that employ this feature. 

Number of Lamps Per Ballasts 

 

 Metal halide lamp ballasts are commonly designed to operate with a single lamp because 

of lamp characteristics such as re-striking and voltage regulation. However, an initial review of 

manufacturer catalogs shows that while a majority of available ballasts only operate one lamp, a 

limited number are designed for two lamps. 

 

 If appropriate, DOE could further divide metal halide lamp fixtures equipment classes by 

including separate equipment classes for ballasts that are designed to be operated with multiple 

lamps (e.g., two lamp ballasts). The limited information DOE has gathered shows little to no 

change in efficiency between a one-lamp or two-lamp metal halide ballast. DOE seeks comments 

on the differences between one-lamp and two-lamp metal halide ballasts and whether DOE 

should separate metal halide lamp fixture equipment classes by this feature. 

Lamp Starting Method 

 

11

 I

2R losses are the power losses due to the flow of current through copper conductors. As current flows through 

wires and electrical components, the resistance causes some of the power to dissipate as heat. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
20

 

 Metal halide lamp ballasts currently available in the market are specifically designed to 

operate with either a probe-start or pulse-start lamp, but not both types of lamps at the same time. 

The main differences between both types of starting methods is the inclusion of a third probe in 

probe-start lamps, the need for an igniter circuit for pulse-start lamps, and the different wiring 

specification for ballasts of each starting method. Most new applications in the market are pulsestart due to its inherently better efficacy than probe-start. However, with minor changes to the 

wiring specification and configuration within a fixture as well as the swap of lamp type, probestart ballasts can be replaced by pulse-start ballasts. 

 If appropriate, DOE could further divide equipment classes by the ballast starting method 

(e.g., pulse-start or probe-start). However, DOE‘s initial view is that equipment classes should 

not be further divided by starting method due to their interchangeability and lack of unique or 

separate utility that would affect efficiency. DOE seeks comments on the different lamp starting 

methods and whether there should be an additional separation of metal halide lamp fixture 

equipment classes by this feature. 

Electronic Configuration 

 

 Metal halide lamp ballasts have two distinct types of electronic configuration: electronic 

and electromagnetic (magnetic). The more commonly used magnetic ballasts are typically 

composed of transformer-like copper windings on a steel or iron core. The newer and more 

efficient electronic ballasts rely on the use of electronic filters, switches, and capacitors/inductors 

to control current and voltage to the lamp. In metal halide lamp fixtures, electronic ballasts can 

be used to achieve higher efficiency than magnetic ballasts. In the current metal halide lamp 

fixtures market, electronic ballasts are direct replacements for magnetic ballasts for lower to 

medium wattage applications (less than 150W up to 500W). Initial review of manufacturer 

catalogs shows that at higher wattages, few electronic ballasts are available due to the 

significantly higher cost of components. The use of higher frequencies has also prevented market 

penetration of electronic ballasts for higher wattages. Due to acoustic resonance issues as well as 

electromagnetic interference (EMI) effects, ballasts frequencies above 300 Hz become difficult 

to manufacture and have difficulty complying with Federal Communications Commission (FCC) 

standards.12

 EISA 2007 distinguishes non-pulse-start electronic equipment classes by separation into 

two rated lamp wattage ranges (greater than or equal to 150W but less than or equal to 250W, 

and greater than 250W but less than or equal to 500W). According to an initial review of 

manufacturer catalogs, non-pulse-start electronic metal halide lamp ballasts are not available in 

the market. While EISA 2007 provisions may have been intended to capture alternative 

technologies that could be available in the near term, DOE does not believe equipment classes 

 

12

 FCC regulations at 47 CFR Part 18, Subpart C set forth technical standards for industrial, scientific, and medical 

equipment that specify frequency bands and ranges tolerances as well as electromagnetic fields strength limits. 

Some metal halide lamp ballasts may be covered under these ―industrial, scientific, and medical (ISM) equipment‖ 

standards, which list the general operating conditions for ISM equipment. Ballasts designed to exceed 9 kHz ballast 

frequency have to be designed such that interference with transmitted radio frequencies is eliminated. 47 CFR 

18.111. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
21

should necessarily be divided by electronic configuration. Electronic configuration does not 

present separate utility or efficiency. DOE seeks comments on the different electronic 

configurations and the separation of metal halide lamp fixtures equipment classes by these 

ballast features. 

Circuit Type 

 Magnetic metal halide lamp ballasts are available in the market in several types of circuit 

configurations, including high-reactance autotransformer (HX-HPF), constant-wattage isolated 

transformer (CWI), constant-wattage autotransformer (CWA), linear reactor (reactor), and 

magnetically regulated lag (mag-reg) ballasts. Each circuit type listed has different 

characteristics that could have separate utilities. These characteristics include weight, size, 

efficiency, power regulation, and cost. For electronic ballasts, the only difference in circuit type 

is either ―high‖ or ―low‖ frequency circuit type. For low-frequency electronic ballasts (100 to 

400 Hz), a square current waveform is used to diminish acoustic resonance and maintain lamp 

life. However, higher-frequency electronic ballasts have inherent issues with EMI and acoustic 

resonance, and therefore have limited availability in the market. 

 As noted above, each ballast circuit type may have different utilities and efficiency 

characteristics. Energy conservation standards established by EISA 2007 for metal halide lamp 

fixtures prescribe efficiency levels for magnetic probe-start ballasts at the 150W to 500W rated 

lamp wattage that may not be currently achievable with any circuit type at low to medium lamp 

rated wattage ranges. For pulse-start ballasts at the 150W to 500W rated lamp wattage, current 

energy conservation standards are achievable only by electronic ballasts or certain reactor, magreg, or CWA ballasts. Due to the limited information about differentiation, utility, and efficiency 

characteristics among circuit types, DOE tentatively believes that equipment classes should not 

be further divided by circuit type at this time. Electronic ballasts also can essentially replace any 

type of magnetic ballast and, therefore, eliminate the need for differentiation of circuit type 

within a magnetic ballast category. However, if appropriate, DOE could further divide 

equipment classes by the circuit type based on new data indicating that separation is warranted. 

DOE seeks comments on the different circuit types and the need for additional separation of 

metal halide lamp fixtures equipment classes by this feature. 

 Based on all the characteristics and features previously listed, DOE intends initially to 

establish separate equipment classes for metal halide lamp fixtures by focusing on metal halide 

lamp ballasts that operate specific lamp wattages at specific input voltages. For example, DOE is 

considering establishing one equipment class for all ballasts that operate metal halide lamps with 

rated input wattages between 150W and 250W with input voltages less than 150V. To account 

for the variance in ballast efficiency by rated lamp wattage in an equipment class like this, DOE 

could develop an equation from which manufacturers could calculate the minimum ballast 

efficiency energy conservation standard based on the metal halide lamp wattage and or voltage. 

If DOE chooses not to establish an equation for the minimum ballast efficiency standard that 

accounts for metal halide lamp wattage and or voltage, DOE may choose to subdivide equipment 

classes by the wattage of the lamp operated by the ballast. Table 3.2 shows DOE‘s initial plan for 

equipment classes for this rulemaking. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Table 3.2 Initial Equipment Classes 

Rated Lamp Wattage Input Voltage Equipment 

Classes

< 150W

< 150V 1

≥ 150V and ≤ 300V 2

>300V 3

≥ 150W and ≤ 250W

< 150V 4

≥ 150V and ≤ 300V 5

>300V 6

> 250W and ≤ 500W

< 150V 7

≥ 150V and ≤ 300V 8

>300V 9

> 500W

< 150V 10

≥ 150V and ≤ 300V 11

>300V 12

 DOE seeks comments on all of the possible approaches described above for equipment 

classes, and any other methods for establishing equipment classes corresponding to the 

requirements of 42 U.S.C. 6295(q). 

Item 8 DOE welcomes comments on equipment classes for metal halide lamp fixtures 

and approaches to defining classes in accordance with the requirements of 42 U.S.C. 

6295(q). 

Item 9 DOE seeks input on how ballast efficiency varies by lamp wattage and input 

voltage. 

Item 10 DOE seeks input on the rated lamp wattage bins identified for equipment 

classes. Specifically, DOE is interested in information that could be used to alter the 

number of bins or alter the wattages included in each bin. 

Item 11 DOE welcomes comments on how to approach universal voltage systems that 

are gaining market share and becoming more readily available. 

3.2 Technology Assessment 

The technology assessment centers on understanding how equipment uses energy and 

efficiency measures that would reduce energy consumption by the metal halide lamp ballast, 

which is a key component of the metal halide lamp fixture. Measures that improve the energy 

efficiency of the equipment are called technology options, and they are based on existing 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
23

technologies, as well as prototype designs and concepts. In consultation with interested parties, 

DOE will develop a list of technology options for consideration in this rulemaking. Following 

research into this list of technology options, DOE will consider each one against four screening 

criteria: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) 

adverse impacts on equipment utility or availability; and (4) adverse impacts on health or safety 

(see section 4). Those technology options that pass the four screening criteria are called design 

options and will be considered as appropriate ways of improving the efficiency of the equipment 

in the engineering analysis and will assist DOE in determining the max-tech design. 

DOE is studying technology options by reviewing manufacturer catalogues, recent trade 

publications, technical journals, and patent filings. DOE also intends to consult with technical 

experts who have worked on metal halide lamp ballast designs and to conduct manufacturer 

interviews about these technology options. 

At this time, DOE is aware of a limited set of technology options that could improve 

ballast efficiency. For the preliminary analysis, DOE intends to study the following options: 

Electronic Ballasts. For equivalent light output, electronic ballasts generally consume 

less energy than magnetic ballasts. The electronic ballast converts the 60 hertz 

alternating current input power into a high-frequency voltage (20 kilohertz or higher) 

to operate the lamp. Generally, higher frequency has correspondingly higher 

efficiency. However, EMI and acoustic resonance issues are generally associated 

with high frequencies. 

o Low-Frequency Electronic Ballasts - Electronic ballasts operate at higher 

frequencies than magnetic ballasts. Therefore, the losses near the lamp 

electrode are decreased. In addition, higher-frequency operation of this type of 

electronic ballast requires smaller components, thereby reducing ballast losses 

and making the ballast more efficient. Low-frequency electronic ballasts are 

designed to use a square current wave to avoid acoustic resonance and 

maintain lamp life. 

o High-Frequency Electronic Ballasts - Generally, increasing ballast frequency 

may improve ballast efficiency. Higher frequencies can contribute to a gain in 

ballast efficiency between 4 and 6 percent. However, high-frequency 

electronic ballasts have issues with acoustic resonance and EMI that limit the 

available ballasts in the market to the low- to mid-rated lamp wattage range. 

Acoustic resonance may reduce lamp lifetime and disrupt regular operation. 

The higher cost of high-frequency components also makes this option less 

attractive in the current market. 

 

Integrated Circuits. By substituting integrated circuits for discrete components, 

electronic ballasts can save additional energy by reducing conductive energy losses. 

Higher-Grade Components. Higher-grade components can further reduce energy 

losses in ballasts. For example, using higher-grade magnetic materials in both highfrequency transformers and inductors can increase the efficiency of electronic 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
24

ballasts. Improved semiconductor materials used in integrated circuits can also 

improve the efficiency of a metal halide lamp ballast. 

Improved Circuit Design. Better circuit design may also improve the efficiency of an 

electronic ballast. For instance, through better circuit design, a ballast‘s power factor 

can be increased. The higher a ballast‘s power factor, the lower the current per watt 

required to operate the ballast. These decreased currents reduce additional losses in 

the power distribution system because of lower conductive losses (also called I2R 

losses). Other improvements in design may include using smaller inductors, designing 

circuits to reduce harmonics, or changing component characteristics to increase 

current control. However, improvements in circuit design or additional components 

may also use energy (e.g., use of power factor correction circuits), which could 

mitigate some of the potential energy savings from this technology option. 

Item 12 DOE welcomes comments on the preliminary technology options identified in 

this section and whether there are other technology options it should consider. In 

commenting on design options, please discuss their impacts on safety, performance, 

and consumer utility (if any). 

4 SCREENING ANALYSIS 

The purpose of the screening analysis is to screen out technology options, which will not 

be further analyzed in the engineering analysis. DOE will follow the process set forth below to 

screen out technology options. 

DOE will develop a list of technology options (developed through its own research and in 

consultation with interested parties) for consideration in the engineering analysis (section 5). The 

identified candidate technology options will encompass all those technologies that may be 

technologically feasible. Thereafter, DOE will review each technology option or best available 

technology in light of the following four criteria, as provided in sections 4(a)(4) and 5(b) of the 

Process Rule13 and tailored to the current rulemaking: 

1. Technological feasibility. DOE will screen out technologies that are not incorporated in 

commercially-available products or working prototypes. 

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production of a technology in commercial products and reliable installation and servicing 

of the technology could not be achieved on the scale necessary to serve the relevant 

market by the time of the effective date of the standard, it will not consider that 

technology further. 

 

13

 The Process Rule establishes procedures, interpretations, and policies to guide DOE in the consideration and 

promulgation of new or amended energy conservation standards under EPCA and is found at 10 CFR Part 430, 

Subpart C, Appendix A. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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3. Adverse impacts on product or equipment utility or availability. If DOE determines a 

technology has a significant adverse impact on the utility of the product for significant 

consumer subgroups, or results in the unavailability of any covered product type with 

performance characteristics (including reliability), features, size, capacities, and volumes 

that are substantially the same as products generally available in the United States at the 

time, it will not consider that technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will fully document its reasons for eliminating any technology options during the 

screening analysis, and will publish this documentation for interested parties to review as part of 

the preliminary analysis. Those technology options not screened out by the above four criteria 

will be considered design options in the development of cost-efficiency curves in the engineering 

analysis. 

Item 13 DOE welcomes comments on how the above four screening criteria might 

apply to any additional technology option(s) that an interested party recommends to 

DOE. 

5 ENGINEERING ANALYSIS 

After conducting the screening analysis described above, DOE will perform an 

engineering analysis based on the remaining design options that are available to improve 

equipment efficiency. The engineering analysis consists of estimating the energy consumption 

and cost of equipment at various levels of increased efficiency. Section 5.1 provides an overview 

of the engineering analysis. Section 5.2 discusses representative equipment classes. Section 5.3

discusses scaling methodology. Section 5.4 discusses baseline models. Section 5.5 describes 

DOE‘s planned approach. Section 5.6 addresses proprietary designs. Section 5.7 discusses 

cumulative regulatory burdens that might affect the engineering analysis. 

5.1 Engineering Analysis Overview 

The purpose of the engineering analysis is to determine the relationship between metal 

halide lamp ballast efficiency and the portion of the metal halide lamp fixture manufacturer 

selling price (MSP) that relates to the ballast. This relationship between price and efficiency 

serves as the basis for cost/benefit calculations to individual consumers in the LCC analysis and 

to the Nation in the national impact analysis (NIA). 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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The engineering analysis will focus on selecting commercially-available ballasts that 

incorporate design options that improve the ballast efficiency. The engineering analysis will also 

identify the highest efficiency that is technologically feasible within each equipment class (i.e., 

the max-tech model). DOE may determine the max-tech model by investigating the existence of 

any metal halide ballast prototypes with higher efficiency than those commercially available.

5.2 Representative Equipment Classes 

For the engineering analysis, DOE will first review the metal halide lamp ballasts 

available for the associated metal halide lamp fixtures equipment classes. When a type of 

equipment has multiple equipment classes (e.g., ballasts with rated lamp wattage below 150W 

have three proposed equipment classes), DOE selects certain classes as representative and 

concentrates its analytical effort on these. DOE selects representative equipment classes 

primarily because of their high market volumes. For those equipment classes that are not 

analyzed, DOE extrapolates CSLs from representative equipment classes. 

As previously discussed, DOE is proposing to revise the equipment classes established by 

EPCA and include a total of 12 equipment classes (Table 3.2). Of these equipment classes, DOE 

is initially planning to analyze at least one representative equipment class from each rated lamp 

wattage range. DOE found in manufacturer catalogs many types of equipment for each of these 

equipment classes. However, DOE does not plan to directly analyze all equipment classes. The 

direct analyses for representative equipment classes can be scaled to those equipment classes that 

are not directly analyzed. The representative classes of metal halide lamp fixtures selected will 

be evaluated in both the engineering and LCC analyses (section 8). Table 5.1 shows the 

equipment classes that DOE has initially identified as representative equipment classes. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Table 5.1 Initial Representative Equipment Classes 

Rated Lamp Wattage Input Voltage Equipment 

Classes

< 150W

< 150V Representative 

Equipment Class

≥ 150V and ≤ 300V Scaled

>300V Scaled

≥ 150W and ≤ 250W

< 150V Representative 

Equipment Class

≥ 150V and ≤ 300V Scaled

>300V Scaled

> 250W and ≤ 500W

< 150V Scaled

≥ 150V and ≤ 300V Representative 

Equipment Class

>300V Scaled

> 500W

< 150V Scaled

≥ 150V and ≤ 300V Representative 

Equipment Class

>300V Scaled

Once the representative class analysis is complete, DOE will then scale those findings to 

the other equipment classes that were not analyzed. For this reason, careful selection of 

representative equipment classes is critical. 

Item 14 DOE welcomes comments on the identification and selection of representative 

equipment classes for metal halide lamp fixtures. 

5.3 Scaling Method 

DOE has tentatively decided to choose representative equipment classes based primarily 

on their availability or possibly unique performance characteristics that deserve special 

consideration. It may be possible to extrapolate analyses conducted on one equipment class to 

another (e.g., extrapolate minimum ballast efficiency from ballasts that operate one lamp to 

ballasts that operate two lamps). For the equipment classes not analyzed directly, DOE plans to 

scale the engineering results and CSLs from the representative equipment class test data based on 

ratios observed in catalog data or by extrapolation using regression equations. If specific data for 

a particular equipment class are unavailable, DOE may substitute a scaling factor from a closelyrelated piece of equipment. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Item 15 DOE welcomes comments on its approach to scaling from representative 

equipment classes to classes not directly analyzed in the engineering analysis. 

5.4 Baseline Models 

Once DOE establishes representative equipment classes, it will need to identify baseline 

models of metal halide lamp ballasts (contained in fixtures) that will serve as reference points 

against which it can measure changes resulting from potential energy conservation standards. 

DOE will develop a separate engineering analysis for each baseline model selected. The results 

of DOE‘s analysis will then be scaled from the representative equipment classes to the other 

equipment classes that were not analyzed. 

Selection of the baseline model is a critical aspect of DOE‘s analytical approach. The 

baseline model should represent the characteristics of common equipment sold in a given 

equipment class. Typically, the baseline model would be a model that just meets current energy 

conservation standards, which in the case of metal halide lamp fixtures, means the minimum 

efficiency requirements for ballasts established by EISA 2007. If no standards apply to a type of 

equipment, as is the case with the additional metal halide lamp fixtures and ballasts that DOE 

intends to consider in this rulemaking, DOE will select baseline models typical of the leastefficient model offered for sale in the market. In the present case, selection of the baseline 

model will encompass consideration of ballast features and performance characteristics such as 

rated lamp wattage, input voltage, and ballast efficiency. Table 5.2 shows DOE‘s initial plans for 

baseline models for the various representative equipment classes. 

Table 5.2 Initial Baseline Models 

Representative Equipment Class Baseline Models Characteristics

Rated Lamp 

Wattage

Input 

Voltage

Baseline Model 

Rated Lamp 

Wattage

Baseline 

Model Input 

Voltage

Baseline 

Model 

Efficiency

< 150W < 150V 70W 120V 71.0%

≥ 150W and ≤ 250W < 150V 250W 120V 88.0%

> 250W and ≤ 500W ≥ 150V and 

≤ 300V 400W 277V 88.0%

> 500W ≥ 150V and 

≤ 300V 1000W 277V 87.0%

 

 The planned baseline model characteristics selections are based on an initial review of 

manufacturer catalogs. For the representative ballast that is designed to operate at the less than 

150W rated lamp wattage range, DOE selected a ballast that operates at 70W and 120V due to its 

predominance in the market. To characterize the efficiency of this ballast, DOE used the lowest 

catalog efficiency available in the current market. DOE selected 120V input voltage because the 

majority of metal halide lamps at the less than 150W range are used in residential/commercial 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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applications, which commonly use the 120V line voltage. For the mid-rated lamp wattage range, 

DOE selected ballasts from both residential and commercial applications and with efficiencies 

that match the EISA 2007 levels. For the high-rated lamp wattage range, DOE selected a ballast 

that operates at 1,000W and 277V due to its predominance in the market. To characterize the 

efficiency of this equipment, DOE used the lowest catalog efficiency available in the current 

market. DOE selected the 277V input voltage because the majority of metal halide lamps at the 

high rated lamp wattage range are used in commercial or industrial applications, which 

commonly use 277V to 480V line voltage. 

Item 16 DOE welcomes comments on the selection of baseline models from the 

representative equipment classes. 

5.5 Cost-Efficiency Relationship and Analysis 

The engineering analysis primarily involves estimating the energy consumption and cost 

of equipment at various levels of increased efficiency. These estimates are then used to identify 

the cost-efficiency relationship for the equipment. DOE typically structures its estimation of the 

cost-efficiency relationship 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 incremental costs of achieving increases in 

energy efficiency, without regard to the particular design options used to achieve such increases; 

and (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 equipment being analyzed. Deciding which methodology to use for the engineering 

analysis depends on the equipment, the technologies under study, and any historical data DOE 

can draw upon. Due to the limited availability of public information on cost and efficiency of 

metal halide lamp ballasts, DOE has tentatively decided to use both the efficiency-level approach 

to identify incremental improvements in efficiency for each piece of equipment and the costassessment approach to develop a cost for each efficiency level. 

In the engineering analysis, DOE will select a series of more-efficient, commerciallyavailable ballasts for each of the baseline models considered within each representative 

equipment class. After identifying both the baseline ballast and the more-efficient substitutes, 

DOE will generate a BOM by disassembling multiple manufacturers‘ ballasts spanning a range 

of efficiency levels for each representative equipment class. The BOMs describe the equipment 

in detail, including all manufacturing steps required to make and/or assemble each part. DOE 

will then develop a cost model to convert the BOMs and efficiency levels into manufacturer 

production costs (MPCs). By applying derived manufacturer markups to the MPCs, DOE will 

calculate the manufacturer selling prices and construct industry cost-efficiency curves. For each 

metal halide lamp ballast for which DOE is not able to generate a BOM, DOE will evaluate retail 

prices and estimate an MSP. 

DOE will select metal halide lamp ballasts for the analysis such that potential 

substitutions maintain light output of the lamp-ballast system within 10 percent from the baseline 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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system. In identifying more-efficient substitutes, DOE will use a database of commerciallyavailable ballasts. There are limited publicly-available data on efficiency and costs of metal 

halide lamp ballasts. Therefore, DOE encourages interested parties to submit data that would 

improve DOE‘s understanding of the metal halide lamp ballast cost-efficiency relationship. 

These data may be provided under a confidentiality agreement with NCI. As discussed 

previously, DOE presents aggregated results and does not divulge sensitive raw data from 

interested parties. 

After identifying the more-efficient substitutes for each of the baseline lamp-and-ballast 

systems, DOE will develop CSLs. CSLs are a set of efficiency levels considered in the 

preliminary analysis that spans the range of ballast efficiencies from baseline equipment to 

maximum technologically feasible. Each CSL is analyzed in the LCC and NIA analyses. At the 

NOPR stage of the rulemaking process, DOE will propose energy conservation standard levels 

for each equipment class and invite public comment. 

CSLs for metal halide lamp ballasts (contained in metal halide lamp fixtures) are 

generally based on consideration of several factors, including: (1) design options associated with 

the specific ballasts being studied; (2) the ability of ballasts that operate across multiple wattages 

to comply with the standard level of a given equipment class;14 and (3) the maximum 

technologically-feasible level. DOE welcomes comment from interested parties on its costefficiency approach and the selection of higher-efficiency metal halide lamp ballasts used in 

metal halide lamp fixtures. 

Item 17 DOE seeks comments on its approach to calculating the cost-efficiency 

relationship for metal halide lamp ballasts used in metal halide lamp fixtures. 

Item 18 DOE welcomes comments on commercially-available metal halide lamp 

ballasts for each baseline model with incrementally increasing ballast efficiency, all the 

way to the max-tech ballast. 

Item 19 DOE welcomes comments on how ballast efficiency varies with lamp wattage, 

voltage, or any other ballast parameter. 

5.6 Proprietary Designs 

DOE will consider in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs, that 

meet the screening criteria discussed in section 4. However, DOE will consider a proprietary 

design in the subsequent analyses only if it does not represent a unique path to a given efficiency 

level. If the proprietary design is the only approach available to achieve a given efficiency level, 

then DOE will eliminate the efficiency level from further analysis. DOE will reject a standard 

 

14

 The efficiency of a given ballast will vary depending on the wattage of the lamp it is operating. In selecting 

CSLs, DOE will consider whether ballasts that operate lamps at multiple wattages will meet a given CSL. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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level that can only be met with a single proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically 

unjustifiable. However, if a given energy efficiency level can be achieved by a number of design 

approaches, including a proprietary design, DOE will continue to examine the given efficiency 

level, in spite of the proprietary nature of that one design. 

DOE is sensitive to manufacturer concerns about proprietary designs and will take steps 

to maintain the confidentiality of any proprietary data provided by manufacturers. This 

information will provide input to the competitive impacts assessment and other economic 

analyses. 

Item 20 DOE seeks information on proprietary designs it should be aware of for the 

metal halide lamp ballasts under consideration in this rulemaking, and if such 

proprietary designs exist, how DOE can acquire the cost data necessary for evaluating 

these designs. 

5.7 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE considers the effects of regulatory burdens 

outside DOE‘s statutory energy conservation standards rulemaking process that can affect 

manufacturers of the covered equipment. Some regulatory requirements can also affect the 

energy efficiency or energy consumption of the metal halide lamp fixtures or ballasts covered 

under this rulemaking. DOE will attempt to identify all outside regulatory requirements that 

could affect the engineering analysis. The consideration of these requirements is closely related 

to the cumulative regulatory burden assessment that DOE will conduct as part of the 

manufacturer impact analysis. Based on consideration of the comments received on the 

engineering analysis, DOE will make any necessary changes to its analysis. Those changes will 

be reflected in the NOPR. 

Item 21 DOE welcomes comments on regulatory burdens and changes that should be 

considered in the engineering analysis of metal halide lamp fixtures. 

Item 22 DOE welcomes comments on other engineering issues that could affect the 

engineering analysis. 

6 ENERGY USE AND END-USE LOAD CHARACTERIZATION 

The purpose of the energy-use and end-use load characterization is to identify how 

consumers use equipment, thereby helping to determine the energy savings potential of energy 

efficiency improvements. For metal halide lamp fixtures, DOE‘s analysis will focus on how end 

users install and operate these fixtures. 

The energy-use and end-use load characterization is an input to the LCC and national 

impact analyses, and it will capture and represent the typical energy consumption in the field. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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This usage profile will enable DOE to determine the LCC and PBP of more-efficient metal 

halide lamp fixture technologies relative to the baseline technologies. 

For metal halide lamp fixtures, energy consumption is derived by multiplying the system 

power rating by the number of operating hours in a given year. DOE is considering using data 

from the U.S. Lighting Market Characterization: Volume I (LMC),15 the Energy Information 

Administration‘s (EIA) 2003 Commercial Building Energy Consumption Survey (CBECS),16 and 

the 2002 Manufacturer Energy Consumption Survey (MECS)17 to develop a distribution of 

operating hours for metal halide lamp fixtures by sector and Census Division. The EIA studies 

provide information on the distribution of buildings within the United States by building type 

and Census Division. The LMC, which is based on thousands of building audits and surveys, 

provides national data on annual operating hours by building and lamp type for all sectors. These 

operating hours are broken down by application for the commercial and industrial sectors. DOE 

compares the LMC data to the EIA data to derive annual operating hours by Census Division and 

for selected large States. This approach allows DOE to correlate the electricity price and sales tax 

distributions with the operating hours distribution by Census Division and for selected large 

States in the LCC spreadsheet. 

Using this methodology will allow DOE to conduct a sensitivity analysis to determine 

how high and low estimates of energy use might affect the economic feasibility of any amended 

energy conservation standards. DOE will also be able to correlate regional electricity prices and 

sales tax data to develop a more accurate distribution of the variability in consumer impacts in 

the LCC analysis. 

Item 23 DOE welcomes comments on its use of the planned operating hours profile for 

metal halide lamp fixtures. DOE also welcomes comments on whether the end-use 

operating profiles are different for the various types of metal halide lamp fixtures 

covered under this rulemaking, and if so, how. 

7 MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

DOE uses manufacturer-to-customer markups to convert the manufacturer selling price 

estimates from the engineering analysis to customer prices, which are then used in the LCC and 

PBP analyses, as well as the manufacturer impact analysis. Retail prices are necessary for the 

 

15

 U.S. Department of EnergyCOffice of Energy Efficiency and Renewable Energy, Final Report: U.S. Lighting 

Market Characterization, Volume I: National Lighting Inventory and Energy Consumption Estimate (2002). 

Available at: www.eere.energy.gov/buildings/info/documents/pdfs/lmc_vol1_final.pdf. 

16

 U.S. Department of EnergyCEnergy Information Agency, Commercial Building Energy Consumption Survey: 

Micro-level data, file 2 Building Activities, Special Measures of Size, and Multi-building Facilities (2003). 

Available at: http://www.eia.doe.gov/emeu/cbecs/public_use.html. 

17

 U.S. Department of EnergyCEnergy Information Agency, Manufacturing Energy Consumption Survey, Table 1.4: 

Number of Establishments by First Use of Energy for All Purposes (Fuel and Nonfuel) (2002). Available at: 

http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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baseline efficiency level and all other efficiency levels under consideration. DOE will obtain 

these retail prices by applying manufacturer-to-customer markups (consisting of distribution 

channel markups and sales tax) to the manufacturer selling price estimates which will be 

calculated as part of the engineering analysis. 

Before it can develop markups, DOE must identify distribution channels (i.e., how the 

equipment is distributed from the manufacturer to the customer). As depicted below, DOE has 

identified the primary distribution channel for metal halide lamp fixtures to be as follows 

Ballast Manufacturer  Original Equipment Manufacturer (OEM) or Fixture 

ManufacturerElectrical Wholesaler (Distributor)  Contractor  End-User of 

Lighting System 

Once it establishes proper distribution channels for each equipment class, DOE will rely 

on economic data from public sources and industry input to determine how equipment is marked 

up from the manufacturer to the customer. Publicly-owned companies are required to disclose 

financial information on a regular basis by filing different forms with the U.S. Securities and 

Exchange Commission (SEC). Filed annually, SEC form 10-K provides a comprehensive 

overview of the company‘s business and financial conditions. To estimate OEM and wholesaler 

markups, DOE will use financial data from 10-K reports from publicly-owned lighting fixture 

manufacturers and electrical wholesalers, respectively.18 DOE is considering using a contractor 

markup consistent with that used in the 2000 Fluorescent Ballast Rule.19 DOE intends to use the 

State Tax Clearinghouse to calculate applicable sales taxes.20 To the extent possible, DOE also 

will use collected retail price data to help quantify manufacturer-to-customer markups. 

Item 24 DOE requests comments on the planned distribution path for the metal halide 

lamp fixtures covered under this rulemaking and whether DOE should consider any 

additional paths. DOE also requests information on the relative fraction of shipments 

expected for each path. 

Item 25 DOE requests feedback on the overall markups for the metal halide lamp 

fixtures covered under this rulemaking for each path in the distribution chain. 

Item 26 DOE seeks comments on other sources of relevant data that could be used to 

characterize markups for metal halide lamp fixtures. 

 

18 10-K reports are filed with the U.S. Securities and Exchange Commission and are available at: 

http://www.sec.gov/index.htm 

19 The 2000 Fluorescent Lamp Ballast Rule was published in the Federal Register on September 19, 2000 and is 

available at: http://www1.eere.energy.gov/buildings/appliance_standards/residential/gs_fluorescent_lamps.html 

20

 Sales Tax Clearinghouse, Inc., State Sales Tax Rates along with Combined Average City and County Rates. 

Available at: http://thestc.com/STrates.stm. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
34

8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

The effects of amended energy conservation standards on consumers include a change in 

operating expense (usually decreased) and a change in purchase price (usually increased). The 

LCC of a product is the cost a product incurs over its lifetime, taking into account both purchase 

price and operating expenses. The PBP represents the time it takes to recover the additional 

installed cost of the more-efficient device through annual operating cost savings. DOE analyzes 

the net effect on consumers by calculating the LCC and PBP using the engineering performance 

data (section 5), the energy-use and end-use load characterization data (section 6), and the 

markups for equipment price determination (section 7). Inputs to the LCC calculation include the 

installed cost to the consumer (purchase price plus installation cost), operating expenses (energy 

expenses, and, if applicable, repair costs and maintenance costs), the lifetime of the equipment or 

other defined period of analysis, and a discount rate. Inputs to the payback period calculation 

include the installed cost to the consumer and annual operating costs. 

In addition to the LCC and PBP calculations, DOE also conducts a rebuttable 

presumption analysis for certain equipment. Under 42 U.S.C. 6295(o)(2)(B)(iii), the statute 

establishes a rebuttable presumption that a standard is economically justified ―[i]f the Secretary 

finds that the additional cost to the consumer of purchasing a product complying with an energy 

conservation standard level will be less than three times the value of the energy ... savings 

during the first year that the consumer will receive as a result of the standard, as calculated under 

the applicable test procedure....‖ Because the DOE test procedure for metal halide lamp ballasts 

does not include an input for operating hours, DOE plans to use the average annual operating 

hours of the most common end-use application. While the rebuttable presumption calculation is 

helpful in understanding that certain standard levels have short payback periods, DOE routinely 

conducts a full economic analysis that considers the full range of impacts, including those to the 

consumer, manufacturer, Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). 

The results of this analysis serve as the basis for DOE to definitively evaluate the economic 

justification for a potential standard level (thereby supporting or rebutting the results of any 

preliminary determination of economic justification). Economic justification is based on a 

weighing of the seven EPCA factors described in section 1.3.2. The LCC and PBP analyses 

described in the following section reflect field conditions and are, therefore, a more accurate 

depiction of consumer impacts. 

For the preliminary analysis, DOE will conduct the LCC and PBP analyses using typical 

values to reflect conditions in the field for equipment retail price and life, energy costs, energy 

usage, and discount rates. If DOE determines that there is significant variability in any of these 

inputs, it will conduct sensitivity analyses to determine how high and low estimates for each 

input affects the LCC and PBP. For any sensitivity analyses that it conducts, DOE will account 

for correlations that may exist between inputs (e.g., energy usage may be correlated to energy 

prices). The detailed impact calculation, which DOE will conduct after the preliminary analysis, 

may include an assessment of impacts on consumer subgroups, as described in section 11. 

For the NOPR, DOE will carefully review all of the comments it receives on the LCC 

analysis, evaluate additional parameters not included in the preliminary analysis, and make any 

necessary revisions. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
35

The following sections discuss the methodologies DOE plans to use to develop energy 

prices, discount rates, maintenance, repair, and installation costs, and ballast lifetimes for metal 

halide lamp fixtures. Table 8.1 lists some of the major inputs DOE anticipates it will develop for 

the LCC and PBP analyses. 

Table 8.1 Inputs to the Life-Cycle Cost and Payback Period Analyses

Input Description

Equipment Price The price of certain metal halide lamp fixtures will be established as described in 

section 7, Markups for Equipment Price Determination.

Sales Tax Sales tax is applied to convert the product price to a final consumer price. Sales tax 

mark-ups will be developed as described in section 7, Markups for Equipment Price 

Determination.

Installation, Maintenance, 

and Repair costs

These inputs represent the cost to customers of installing and maintaining the metal 

halide lamp fixture. 

Annual Operating Hours The annual operating hours are the estimated hours that a metal halide lamp fixture is in 

use over 1 year. Operating hours will be developed as described in section 6, EnergyUse and End-Use Load Characterization.

Product Energy 

Consumption Rate

The product energy consumption rate is the site-energy usage rate associated with 

operating the lamp system. This rate will be developed as described in section 6, 

Energy-Use and End-Use Load Characterization.

Electricity Prices Electricity prices used in the analysis are the average price per kilowatt-hour (i.e., 

$/kilowatt hour ($/kWh)) that customers pay. 

Electricity Price Trends Electricity price trends estimate the future cost of electricity. 

Lifetime Lifetime is the number of hours a fixture is in operation before the consumer retires the 

fixture or components of the fixture from service. 

Discount Rate The discount rate is the rate at which DOE discounts future expenditures to establish 

their present value. 

Analysis Period The analysis period is the time span over which DOE calculates the LCC.

8.1 Energy Prices 

DOE will survey residential, commercial, and industrial energy tariffs21 as a means for 

establishing marginal electricity prices for consumers of metal halide lamp fixtures. DOE will 

also use data from CBECS22 to estimate building energy use characteristics that affect electricity 

prices. If the tariff survey and EIA data demonstrate a large variability in electricity prices, DOE 

will conduct a sensitivity analysis to determine how high and low electricity price estimates 

might affect the economic feasibility of any amended energy conservation standards. DOE will 

use projections of national average energy prices—principally from the most recent EIA Annual 

Energy Outlook (AEO)

23—as inputs for future energy prices in the LCC analysis. 

Item 27 DOE welcomes input on the electricity prices used in this analysis. 

 

21

 Energy tariffs are the rules for calculating energy bills. DOE contractors maintain a database of hundreds of 

tariffs that can be used to calculate incremental energy bill impacts from energy savings at: http://tariffs.lbl.gov. 

22

 See www.eia.doe.gov/emeu/cbecs. 

23

 See http://www.eia.doe.gov/oiaf/aeo/. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
36

8.2 Life-Cycle Cost Discount Rates 

Calculation of consumer LCC requires use of an appropriate discount rate. DOE uses the 

discount rate to determine the present value of lifetime operating expenses. Because consumers 

of metal halide lamp fixtures are typically commercial and industrial entities, DOE will derive 

the discount rates for consumers of metal halide lamp fixtures by estimating the cost of capital of 

companies that purchase commercial equipment. The cost of capital is commonly used to 

estimate the present value of cash flows to be derived from a typical company project or 

investment. Most companies use both debt and equity capital to fund investments, so the cost of 

capital is the weighted-average cost of equity and debt financing. This corporate finance 

approach is referred to as the ―weighted-average cost of capital.‖ However, because the set of 

commercial or industrial companies purchasing metal halide fixtures may differ from those who 

purchase another product such as distribution transformers, each rulemaking requires 

development of its own targeted discount rates. 

DOE will publish the discount rates and documentation on the derivation of these 

discount rates in the preliminary analysis. It will invite interested parties to comment on 

consumer discount rates during the preliminary analysis comment period. DOE will make 

necessary changes to the preliminary analysis based on the comments it receives on the LCC and 

PBP analyses, and will reflect those changes in the NOPR. 

Item 28 DOE welcomes input on the planned approaches for estimating discount rates 

for consumers of the metal halide lamp fixtures covered under this rulemaking. 

8.3 Metal Halide Lamp Fixture Lifetimes 

DOE will use information from manufacturer product catalogues, various literature 

sources such as technical reports and conference proceedings, and input from manufacturers and 

other interested parties, to establish metal halide lamp fixtures lifetimes for use in the LCC and 

subsequent analyses. As DOE believes that fixture lifetime is highly dependent on ballast 

lifetime, DOE will also estimate metal halide lamp ballast lifetimes to further develop inputs to 

the LCC and subsequent analyses. Based on consideration of the comments received for the 

preliminary analysis, DOE will make necessary changes to the analysis. These changes will be 

reflected in the NOPR. 

Item 29 DOE welcomes comments on appropriate lifetimes for the metal halide lamp 

fixtures and the ballasts contained in those fixtures covered in this rulemaking. 

8.4 Installation, Maintenance, and Repair Costs 

Typically, DOE considers expected changes to installation, maintenance, and repair costs 

for covered equipment in a rulemaking due to new or amended standards. Often, small 

incremental changes in equipment efficiency would incur little or no change in installation, 

maintenance, and repair costs over baseline equipment. For equipment with significant energyEERE-2009-BT-STD-0018 DOC ID 1.2.001
37

efficiency improvements over the baseline, there may be increased installation, maintenance, and 

repair costs, because such equipment is more likely to incorporate technologies that are not 

widely available or used. 

DOE intends to handle each of these costs in its LCC analysis of metal halide lamp 

fixtures as follows: 

Installation costs—DOE does not expect that installation costs for metal halide 

lamp fixtures will change with more energy efficient metal halide ballast designs, 

as new regulations are not expected to change either the metal halide ballast 

lifetime or the labor costs for installing a standards-compliant fixture. 

Maintenance costs—DOE expects that more energy efficient ballasts could 

significantly affect the useful lifetime (i.e., longer) of the lamps operated by those 

ballasts. Longer-life lamps would be expected to defer maintenance of metal 

halide lamp fixtures since lamp failure is one of the largest maintenance factors of 

these fixtures. If fewer lamp replacements occur during the lifespan of the 

fixture, this could reduce total maintenance costs and labor costs for metal halide 

lamp fixtures. DOE does not expect that more energy efficient ballasts will 

significantly affect the useful lifetime (shorter or longer) of the fixture. 

Repair costs—Repair costs will not be part of the LCC analysis because DOE 

does not believe that metal halide lamp fixtures are subject to repair, as ballast 

failure generally causes a complete replacement of the fixture, rather than repair. 

Item 30 DOE welcomes comments on how to develop installation, maintenance, and 

(if applicable) repair costs for metal halide lamp fixtures. If the lamps operated by 

more-efficient ballasts would be affected, DOE invites comments on whether relamping practices (i.e., group re-lamping or spot re-lamping) would change as a result 

of energy conservation standards. 

9 SHIPMENTS ANALYSIS 

DOE develops shipment forecasts of products to calculate the national impacts of 

standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to 

develop shipments forecasts based on an analysis of key market drivers for metal halide lamp 

fixtures.

9.1 Base-Case Forecast 

To evaluate the various impacts of standards, DOE develops a base-case shipments 

forecast against which to compare standards-case shipments forecasts at higher efficiency levels 

(based on the CSLs). DOE will design the base-case forecast to depict what might happen to 

energy consumption and energy costs over time if energy conservation standards for the metal 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
38

halide lamp fixtures covered under this rulemaking are not adopted. In determining the base-case 

forecast, DOE will consider historical shipments, the mix of efficiencies currently sold in the 

absence of regulation, and how that mix might change over time. For these purposes, DOE seeks 

data on historical equipment shipments and the market shares of the different efficiency levels 

offered in each equipment class. 

Alternatively, DOE could base its shipments analysis on the shipments analysis from the 

HID Lamp Determination, selected national market reports, and/or historical sales data from the 

U.S. Census Bureau. The Census Bureau publishes limited information on the quantity and dollar 

value of metal halide lamp fixture shipments; however, those shipments are not broken down by 

equipment class. DOE is also interested in data on efficiency trends in the base case (i.e., the 

trends of consumers purchasing fixtures with ballasts that use less energy) that would enable 

DOE to represent these market trends in its analysis. 

DOE intends to develop shipment data within each metal halide lamp fixture equipment 

class, and to understand the breakdown of efficiency levels within each equipment class. 

However, this information may be difficult to collect, so DOE may ultimately need to consider 

other approaches, such as interviewing experts who work in the metal halide lamp fixture 

market. 

Item 31 DOE welcomes recommendations on sources of data for shipments of metal 

halide lamp fixtures by product class. In addition, DOE welcomes comments on how it 

might characterize long-term trends in the efficiency of metal halide lamp fixtures for 

the base-case shipments forecast.

9.2 Accounting Methodology 

DOE plans to determine annual shipments in the base case by accounting for new metal 

halide lamp fixture installation, metal halide lamp fixture replacements due to failure, and metal 

halide lamp fixture ballast retrofits. Each of these three impacts on the accounting methodology 

is discussed below: 

New construction means the new metal halide lamp fixtures that are installed each 

year in new or remodeled buildings, due to growth in the commercial and industrial 

sectors. DOE plans to determine a value for this input by using the National Energy 

Modeling System (NEMS) growth projections for the commercial and industrial 

equipment sectors. 

Replacements mean the new metal halide lamp fixtures that are installed each year to 

replace fixtures with failed ballasts. As previously stated, it is common practice to 

replace the fixtures entirely when ballasts fail. DOE plans to base this calculation on 

equipment sales and retirement rates. 

Retrofits means the metal halide lamp fixtures that replace existing functioning metal 

halide lamp fixtures before the end of their useful life. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
39

DOE intends to use an accounting model to prepare shipment scenarios for the base case 

and the standards-level cases. The model will keep track of the aging and replacement of 

metal halide lamp fixtures given a projection of future metal halide lamp fixture sales 

growth. 

Item 32 DOE welcomes comments on the accounting methodology described above for 

each type of metal halide lamp fixture covered in this rulemaking. 

9.3 Standards Impacts on Metal Halide Lamp Fixture Shipments 

DOE will develop a set of shipment forecasts for covered fixtures for each efficiency 

level analyzed and then develop CSLs. DOE will use these standards-level-case forecasts to 

evaluate the impacts of standards on fixtures shipments. DOE derives standards-level-case 

forecasts using the same data sets it uses for base-case forecasts. However, because the 

standards-level-case forecasts take into account the increase in purchase price and the decrease in 

operating costs caused by standards, forecasted shipments typically deviate from the base case. 

The magnitude of the difference between the standards-level-case and base-case shipment 

forecasts depends on the estimated purchase-price increase, as well as the operating-cost savings 

from the standard. Because the purchase price tends to have a larger impact than operating cost 

on equipment purchase decisions, standards-level-case forecasts typically do show an elasticity 

of demand, manifested as a drop in shipments relative to the base case. 

Market-pull programs, such as consumer rebate programs that encourage the purchase of 

more-efficient metal halide lamp fixtures or ballasts, also affect standards-case shipment 

forecasts. Regulatory efforts also affect shipment forecasts. As of 2008, the State of California 

requires similar efficiency requirements for pulse-start metal halide fixtures to those prescribed 

in EISA 2007. Furthermore, Arizona, California, New York, Oregon, Rhode Island, and 

Washington have restricted the sale of probe-start ballasts. To the extent that such programs 

exist, DOE will consider their impact on the forecast of both standards-case and base-case 

shipments. 

Item 33 DOE welcomes comments on how amended energy conservation standards 

might affect shipments of metal halide lamp fixtures. DOE also requests information 

about existing market-pull programs, such as consumer rebate programs, to promote 

the adoption of more-efficacious ballasts. 

10 NATIONAL IMPACT ANALYSIS 

The national impact analysis discusses DOE‘s assessment of the aggregate impacts of 

potential efficiency standards at the national level. Measures of impact that DOE will report 

include future NES from CSLs (i.e., the cumulative incremental energy savings from an 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
40

increased energy conservation standard relative to a base case of no change in the energy 

conservation national standard over a specified forecast period) and the NPV from CSLs (i.e., the 

cumulative incremental LCC from an increased energy conservation standard relative to the base 

case over a specified forecast period). 

10.1 Inputs to Forecasts 

Analyzing impacts of amended Federal energy conservation standards for metal halide 

lamp fixtures requires comparing projected energy consumption in the United States with and 

without amended energy conservation standards. The forecasts contain projections of unit energy 

consumption of new lamp fixtures, annual equipment shipments, the price of purchased 

equipment, and base-case and standards-case efficiencies. Derivations of the base-case shipments 

forecasts are discussed in section 9. Approaches to determine retail prices for equipment are 

described in section 7. Approaches to determine unit energy consumption are described in 

section 6. 

Section 8 discusses the rebound effect, another input to the NIA. Often, consumers that 

encounter lower operating costs associated with a more-energy-efficient product will use that 

product more often than a less-efficient product. The rebound effect analysis accounts for this 

increase in consumer use. Table 10.2 describes some of the major inputs DOE anticipates it will 

develop for the national impact analysis. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
41

Table 10.1 Inputs to the National Impact Analysis

Input Data Description of Data Sources

Shipments Annual shipments are developed as described in section 9, Shipment 

Analysis.

Stock of Metal Halide Lamp Fixtures This stock is calculated from the service life of fixtures developed as 

described in section 8, Life Cycle Cost Analysis, and annual shipments 

from metal halide fixtures developed as described in section 9, 

Shipment Analysis.

Effective Date of Standard The effective date of the standard is January 1, 2015.

Analysis Period This analysis period is 2015 to 2044 (30 years).

Base-Case Forecasted Efficiency Distribution of base-case shipments by efficiency level over time 

developed as described in section 9, Shipment Analysis. 

Standards-Case Forecasted Efficiency Distribution of shipments by efficiency level for each standards case 

over time as described in section 9, Shipment Analysis. 

Unit Energy Consumption (kWh/yr) This is the average energy consumption of a metal halide lamp fixture 

established as described in section 6, Energy-Use and End-Use Load 

Characterization.

Total Installed Cost Established as described in section 7, Markups for Equipment Price 

Determination, and section 8, Life Cycle Cost Analysis.

Electricity Price Forecast Established as described in section 8, Life Cycle Cost Analysis.

Electricity Site-to-Source Conversion Conversion varies yearly and is generated by EIA Annual Energy 

Outlook forecasts of electricity generation and electricity-related losses.

Heating, Ventilating, and AirConditioning (HVAC) Interaction 

Savings

Accounts for the additional energy saved through HVAC interactions. 

The methodology will be similar to that used in the 2000 Fluorescent 

Ballast Rule, 65 FR 56740 (Sept. 19, 2000).

Discount Rate The discount rate is the rate at which DOE discounts future expenditures 

to establish their present value. DOE will use 3- and 7-percent discount 

rates.

Present Year Future costs and savings will be discounted to the year 2009.

Rebound Effect The difference between the projected and actual savings due to 

increased efficiency. DOE will use 1 percent in the commercial and 

industrial sectors.24

Item 34 DOE welcomes comments on the data sources it anticipates using to develop 

inputs for the national impact analysis. 

Item 35 DOE welcomes comments from interested parties as to whether a moreefficient metal halide lamp fixture would be expected to be used more as a result of 

increased efficiency and whether such a rebound effect would be expected for this 

technology. 

 

24 Greening, L.A., D.L. Greene, and C. Difiglio,  ̳ ̳Energy efficiency and consumption—the rebound effect—a 

survey,‘‘ 28 Energy Policy (2000), pp. 389– 401. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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10.2 Calculation of National Energy Savings 

DOE intends to calculate national energy consumption for each year beginning with the 

expected effective date of the standards. It will calculate national electricity consumption for the 

base case and each standard level analyzed. DOE plans to perform this calculation using a 

spreadsheet model that effectively multiplies annual shipment forecasts by unit energy savings, 

thereby accounting for the stock of equipment affected by standards. 

In response to comments from interested parties who asked for a simple, transparent 

model, DOE developed NES spreadsheet models for its standards rulemakings starting in 1996. 

These models project energy savings and demonstrate how to account for the growth in 

efficiency over time.25 Although these models are specific to each product, their general 

framework is applicable to the entire metal halide lamp fixture market. DOE expects that the 

NES spreadsheet model will provide a stand-alone forecast of national energy savings and NPV 

for metal halide lamp fixtures. DOE will make any necessary changes to the preliminary analysis

based on the comments it receives. It will reflect those changes in the NOPR. 

Item 36 DOE welcomes comments from interested parties on the NES spreadsheet 

models it plans to use for estimating national impacts of amended energy conservation 

standards for metal halide lamp fixtures. 

10.3 Net Present Value of Consumer Savings 

 DOE calculates the national NPV of the consumer savings resulting from energy 

conservation standards in conjunction with the NES. It calculates annual energy expenditures 

from annual energy consumption by incorporating forecasted energy prices, using the shipment 

and average energy efficiency forecasts described in section 9, Shipment Analysis. DOE 

calculates annual equipment expenditures by multiplying the price per unit by the forecasted 

shipments. The difference between a base-case and a standards-case scenario gives the national 

energy bill savings and increased equipment expenditure in dollars. For the metal halide lamp 

fixture rulemaking, this differential will likely result in an NES offset against increased fixture 

expenditures. The difference each year between energy bill savings and increased equipment 

expenditures is the net savings (if positive) or net costs (if negative). DOE will discount these 

annual values to the present time and sum them to provide a net present value. Since the national 

cost of capital may differ from the consumer cost of capital, the discount rate used in the NIA 

can be different from the rate used in the LCC. According to U.S. Office of Management and 

Budget (OMB) guidance, DOE will conduct two NPV calculations, one using a real discount rate 

of 3 percent and another using a real discount rate of 7 percent.26 DOE will make any necessary 

changes to the analysis based on the comments it receives on the preliminary analysis. 

 

25

 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE‘s website at: 

www.eere.energy.gov/buildings/appliance_standards. 

26

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

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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11 LIFE-CYCLE COST SUBGROUP ANALYSIS 

At the NOPR stage of this rulemaking, DOE will conduct a LCC subgroup analysis. In 

this analysis, DOE assesses consumer impacts by dividing consumers into subgroups and 

accounting for variations in key inputs to the LCC analysis. A consumer subgroup comprises a 

subset of the population likely to be affected disproportionately by new or revised energy 

conservation standards (e.g., small businesses, ethnic minorities, low-income consumers, or 

seniors). The purpose of a subgroup analysis is to determine the extent of any such 

disproportional impact. DOE will work with industry and other interested parties early in the 

rulemaking process to identify any subgroups for consideration. 

In comparing potential impacts on the different consumer subgroups, DOE will evaluate 

variations in regional electricity prices, usage profiles, and installation costs that might affect the 

NPV of an energy conservation standard to certain consumer subgroups. To the extent possible, 

DOE will obtain estimates of the variability in each input and consider this variability when 

calculating consumer impacts. DOE will discuss this variability with interested parties and likely 

sources of information. 

Item 37 DOE welcomes comments from interested parties on what, if any, consumer 

subgroups should be considered when developing amended standards for metal halide 

lamp fixtures. 

12 MANUFACTURER IMPACT ANALYSIS 

DOE announced changes to the manufacturer impact analysis (MIA) approach in a report 

to Congress, ―Energy Conservation Standards Activities,‖ 27 on January 31, 2006 (as required by 

section 141 of the Energy Policy Act of 2005 (EPACT 2005)). 

Previously, DOE did not report MIA results during the preliminary analysis phase. Under 

this new approach, DOE will collect, evaluate, and report preliminary information on 

manufacturer impacts in the preliminary analysis.28 Such preliminary information includes the 

anticipated capital conversion costs by efficiency level and the corresponding anticipated 

impacts on employment. DOE will invite further input on these issues during manufacturer 

interviews for the preliminary analysis. 

DOE intends the MIA to provide an assessment of the potential impacts of energy 

conservation standards on manufacturers of metal halide lamp fixtures and ballasts. DOE will 

conduct a separate MIA for each of the fixture types covered under this rulemaking. However, if 

 

27

 The report to Congress is available on the DOE website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/schedule_setting.html. 

28

 Id. at 48. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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appropriate, DOE may combine all covered fixture types into a single MIA. In addition to 

financial impacts, a wide range of quantitative and qualitative effects may occur following 

adoption of a standard that may require changes to manufacturing practices. DOE will identify 

these potential effects through interviews with manufacturers and other experts. 

 For the NOPR, DOE will supplement the results of the preliminary MIA with more 

detailed analyses (sections 12.1 through 12.3). DOE will conduct an industry-wide cash-flow 

analysis using the Government Regulatory Impact Model (GRIM), identify and analyze 

subgroups of manufacturers whose businesses vary significantly from the industry as a whole, 

perform a competitive impacts assessment, and review the cumulative regulatory burden for the 

industry. 

12.1 Sources of Information for the Manufacturer Impact Analysis 

Many of the analyses described earlier provide important information that DOE will use 

as inputs for the MIA. Such information includes financial parameters developed in the market 

assessment (section 3.1), retail price forecasts (section 7), and shipments forecasts (section 9). 

DOE will supplement this information with information gathered during manufacturer 

interviews. 

DOE will conduct detailed interviews with manufacturers to gain insight into the range of 

potential impacts from amended standards. The interview process plays a key role in the MIA, 

because it provides an opportunity for directly affected parties to express their views on 

important issues. During the interviews, DOE will solicit information on the possible impacts of 

amended standards on manufacturing costs, equipment prices, sales, direct employment, capital 

assets, and industry competitiveness. Both qualitative and quantitative information are valuable 

in this analysis. DOE will schedule interviews well in advance to provide every opportunity for 

key individuals to participate. In addition, DOE will provide manufacturers with questionnaires 

before the interviews to facilitate information gathering. Although a written response to the 

questionnaire is acceptable, DOE prefers an interactive interview process, because it helps to 

clarify responses and provides the opportunity to identify additional issues. 

DOE will ask interview participants to identify confidential information, and then DOE 

will determine whether the information submitted is entitled to confidential treatment. DOE will 

consider the information gathered in the energy conservation standard decision-making process. 

DOE will also ask participants to identify any information they wish to have included in the 

public record, but do not want to have associated with their interview (thereby identifying that 

particular manufacturer). DOE will incorporate this information into the public record, but will 

report it without attribution. 

DOE will collate the interview results and prepare a summary of the major issues and 

outcomes. This summary will become part of the technical support document for this 

rulemaking. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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12.2 Industry Cash-Flow Analysis 

The industry cash-flow analysis will rely primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of new or more-stringent energy conservation standards on the 

industry that produces the equipment covered by the standard. 

The GRIM uses a number of factors—annual expected revenues; manufacturer costs such 

as costs of goods sold; selling, general, and administrative costs; taxes; and capital expenditures 

(both ordinary capital expenditures and those related to standards)—to determine annual cash 

flows associated with a new standard, beginning from the announcement of the standard and 

continuing for several years after its implementation. DOE compares the results against basecase projections that involve no new standards. The financial impact of new standards is the 

difference between the two sets of discounted annual cash flows. Other performance metrics, 

such as return on invested capital, are also available from the GRIM. 

 DOE will gather the inputs needed for the GRIM from two primary sources: (1) the 

analyses conducted to this point; and (2) interviews with manufacturers and other interested 

parties. Information gathered from previous analyses will include financial parameters, 

manufacturing costs, price forecasts, and shipment forecasts. Interviews with manufacturers and 

other interested parties will be essential in supplementing this information. 

12.1 Manufacturer Subgroup Analysis 

Average industry cost values may not reveal differential impacts among metal halide 

lamp fixture and ballast manufacturer subgroups. Smaller manufacturers, niche players, and 

manufacturers exhibiting a cost structure that differs significantly from the industry average may 

be affected differently by standards. Ideally, DOE would consider the impact on every firm 

individually. In highly-concentrated industries, this may be possible. In industries having 

numerous participants, however, DOE uses the results of the market and technology assessment 

to group manufacturers into subgroups, as appropriate. For metal halide lamp fixtures and 

ballasts, DOE does not intend to assess the impacts on every manufacturer individually, and, 

therefore is interested in feedback about potential subgroups. However, the detailed 

manufacturer subgroup impact analysis will calculate cash flows separately for each class of 

manufacturer. 

Item 38 DOE seeks comments on the subgroups of metal halide lamp fixtures and 

ballast manufacturers that it should consider in a manufacturer subgroup analysis. 

12.2 Competitive Impacts Analysis 

EPCA directs DOE to consider any lessening of competition likely to result from the 

imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General 

to determine in writing the impacts, if any, of any lessening of competition. (42 U.S.C. 

6295(o)(2)(B)(ii)) 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
46

DOE will make a determined effort to gather firm-specific financial information and 

impacts and report the aggregated impact of the amended standard on manufacturers. The 

competitive impacts analysis will focus on assessing the impacts on smaller manufacturers. DOE 

will base the assessment on manufacturing cost data and information collected from interviews 

with manufacturers. The manufacturer interviews will focus on gathering information that would 

help in assessing asymmetrical cost increases to some manufacturers, increased proportion of 

fixed costs potentially increasing business risks, and potential barriers to market entry (e.g., 

proprietary technologies). DOE will provide the Attorney General with a copy of the NOPR for 

consideration in his evaluation of the impact of standards on the lessening of competition. DOE 

will publish the Attorney General‘s letter and address any related comments in the final rule. 

12.3 Cumulative Regulatory Burden 

Other regulations may apply to the metal halide lamp fixtures and ballasts covered under 

this rulemaking, and to other equipment produced by metal halide lamp fixture and ballast 

manufacturers. Multiple regulations may result in a significant, cumulative regulatory burden on 

these manufacturers. DOE will consider the impact on these manufacturers of multiple, 

equipment-specific regulatory actions. 

Regulations that could impact the industry affected by this rulemaking include: 

Ongoing energy conservation standards rulemaking for fluorescent lamp ballasts;

Energy conservation standards for general service fluorescent lamps (GSFL) and 

incandescent reflector lamps (IRL) established by DOE on July 14, 2009 (74 FR 

34080);

New EPCA standards, prescribed in EPACT 2005, for medium-base compact 

fluorescent lamps and mercury vapor lamp ballasts (42 U.S.C 6295(bb)(1) and (ee));

New EPCA standards for general service incandescent lamps (GSIL) prescribed in 

EISA 2007 (42 U.S.C 6295(i)(1)); 

Existing and/or proposed State standards for metal halide lamp fixtures29; 

State building energy codes lighting requirements (e.g., American Society of Heating, 

Refrigerating, and Air-Conditioning Engineers (ASHRAE) Standard 90.1)30; 

Possible international standards; and 

Possible restriction of materials used in manufacturing such as the Restriction of 

Hazardous Substance (RoHS)31. 

Item 39 DOE welcomes comments on what other regulations or pending regulations it 

should consider in its examination of cumulative regulatory burden. 

 

29

 California Code of Regulations, Title 20, Section 1605.3(n)(2) 

30

 ASHRAE Standard 90.1-2007 is currently the latest version of the standards. Section 9 of ASHRAE 90.1-2007 

deals with lighting requirements. Available at: http://www.ashrae.org. 

31

 Guidance by EPA on RoHS is available at: http://www.epa.ie/whatwedo/resource/rohs/. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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13 UTILITY IMPACT ANALYSIS 

To estimate the impacts of amended energy conservation standards for metal halide lamp 

fixtures on the electric utility industry, DOE will use a variant of the EIA‘s National Energy 

Modeling System called NEMS-BT.32 NEMS is a large, multi-sectoral, partial-equilibrium 

model of the U.S. energy sector that EIA has developed over several years, primarily for the 

purpose of preparing the AEO. NEMS produces a widely-recognized reference-case forecast for 

the United States through 2030 and is available to the public. 

The utility impact analysis is a comparison between the NEMS-BT model results for the 

base case and standard cases. Outputs of the utility impact analysis usually parallel results that 

appear in the latest AEO, with some additions. Typical outputs of the utility impact analysis 

include forecasts of electricity sales, price, and avoided capacity. DOE plans to conduct the 

utility impact analysis as a scenario departing from the latest AEO reference case. In other words, 

DOE will model the anticipated energy savings impacts from amended energy conservation 

standards using NEMS-BT to generate forecasts that deviate from the AEO reference case.33

Item 40 DOE seeks input on its plans to use NEMS-BT to conduct the utility impact 

analysis on the equipment covered under this rulemaking. 

14 EMPLOYMENT IMPACT ANALYSIS 

DOE estimates the impacts of standards on employment for equipment manufacturers, 

relevant service industries, energy suppliers, and the economy in general. This analysis covers 

both direct and indirect employment impacts. Direct employment impacts are changes in the 

number of employees at the plants that produce the covered equipment, along with the affiliated 

distribution and service companies. DOE will evaluate direct employment impacts in the MIA 

(section 12). 

Indirect employment impacts may result from expenditures shifting between goods (the 

substitution effect) and changes in income and overall expenditure levels (the income effect) that 

occur due to standards. DOE defines indirect employment impacts from standards as net jobs 

eliminated or created in the general economy as a result of increased spending driven by 

increased equipment prices and reduced spending on energy. 

The combined direct and indirect employment impacts will be investigated in the 

employment impact analysis using the Pacific Northwest National Laboratory‘s ―Impact of 

 

32

 For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000, 

DOE/EIA-0581 (March 2000), available at: http://tonto.eia.doe.gov/ftproot/forecasting/05812000.pdf. EIA 

approves use of the name NEMS to describe only an official version of the model without any modification to code 

or data. Because this analysis entails some minor code modifications and the model is run under various policy 

scenarios that are variations on EIA assumptions, DOE refers to the model by the name NEMS-BT. (―BT‖ refers to 

DOE‘s Building Technologies Program, under whose aegis this work is performed.) 

33

 Several descriptions of NEMS-BT models from previous rulemakings, including residential furnaces and boilers, 

can be found on DOE‘s website at: 

www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/fb_fr_tsd/chapter_13.pdf. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
48

Sector Energy Technologies‖ (ImSET) model.34 The ImSET model was developed for DOE‘s 

Office of Planning, Budget, and Analysis to estimate the employment and income effects of 

energy-saving technologies in buildings, industry, and transportation. Compared with simple 

economic multiplier approaches, ImSET allows for more complete and automated analysis of the 

economic impacts of energy conservation investments. 

Item 41 DOE requests feedback on its approach to assessing employment impacts on 

the equipment covered under this rulemaking. 

15 ENVIRONMENTAL ASSESSMENT 

The intent of the environmental assessment is to quantify and consider the environmental 

effects of amended energy conservation standards for metal halide lamp fixtures. The primary 

environmental effects of these standards would be reduced power plant emissions resulting from 

reduced consumption of electricity. DOE will assess these environmental effects by using 

NEMS-BT to provide key inputs to its analysis. The portion of the environmental assessment 

that will be produced by NEMS-BT considers carbon dioxide (CO2), sulfur dioxide (SO2), 

nitrogen oxides (NOX), and mercury (Hg). After a brief discussion of general methodology, this 

section will address each of the relevant emissions. The next section (Chapter 16, Monetization 

of Emissions Reductions) explains how DOE plans to monetize the benefits associated with 

emissions reductions. 

The NEMS-BT is run similarly to the AEO2008 NEMS, except that metal halide lamp 

fixture energy use is reduced by the amount of energy saved due to each TSL. The inputs of 

national energy savings come from the NIA spreadsheet model; the output is the forecasted 

physical emissions at each TSL. The net benefit of the standard is the difference between 

emissions estimated by NEMS-BT at each TSL and the AEO Reference Case. NEMS-BT tracks 

CO2 emissions using a detailed module that provides results with broad coverage of all sectors 

and inclusion of interactive effects. DOE obtained the inputs of national energy savings from the 

NIA spreadsheet model. To assess the environmental impact on CO2 emissions, DOE analyzes 

forecasted physical emissions. The net benefit of the standard is the difference between 

emissions estimated by NEMS-BT and the AEO2008 Reference Case. 

Sulfur Dioxide

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that 

create uncertainty about the amended standards‘ impact on SO2 emissions. Title IV of the Clean 

Air Act sets an annual emissions cap on SO2 for all affected EGUs. SO2 emissions from 28 

eastern States and the District of Columbia (DC) are also limited under the Clean Air Interstate 

Rule (CAIR, published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005)), 

 

34 Roop, J. M., M. J. Scott, and R. W. Schultz,  ̳ ̳ImSET: Impact of Sector Energy Technologies,‘‘ PNNL–15273. 

(Pacific Northwest National Laboratory, Richland, WA)(2005). 

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49

which creates an allowance-based trading program that will gradually replace the Title IV 

program in those States and DC. (The recent legal history surrounding CAIR is discussed 

below.) The attainment of the emissions caps is flexible among EGUs and is enforced through 

the use of emissions allowances and tradable permits. The standard could lead EGUs to trade 

allowances and increase SO2 emissions that offset some or all SO2 emissions reductions 

attributable to the amended standard. As a result, DOE is not certain that there will be reduced 

overall SO2 emissions from the amended standards. The NEMS-BT modeling system that DOE 

plans to use to forecast emissions reductions currently indicates that no physical reductions in 

power sector emissions would occur for SO2. However, remaining uncertainty prevents DOE 

from estimating SO2 reductions from the standards at this time. 

Even though DOE is not certain that there will be reduced overall emissions from the 

standard, there may be an economic benefit from reduced demand for SO2 emission allowances. 

Electricity savings decrease the generation of SO2 emissions from power production, which can 

lessen the need to purchase SO2 emissions allowance credits, thereby decreasing the costs of 

complying with regulatory caps on emissions. However, DOE does not plan to monetize this 

particular benefit because the effect on the SO2 allowance price from any single energy 

conservation standard is likely small and highly uncertain. 

Nitrogen Oxides

NEMS-BT also has an algorithm for estimating NOx emissions from power generation. 

The impact of these emissions, however, will be affected by the CAIR, which the Environmental 

Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of NOx

in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005). 

Much like SO2 emissions, a cap on NOX emissions means that the amended metal halide 

lamp fixtures standards may have little or no physical effect on these emissions in the 28 eastern 

States and the DC covered by CAIR. Although CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent with the Court‘s July 11, 

2008, opinion in North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina 

v. EPA, 550 F.3d 1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce 

NOX emissions through participation in cap-and-trade programs for electric generating units, 

emissions from these sources are capped across the CAIR region. 

 Standards could produce an environmental-related economic benefit in the form of lower 

prices for emissions allowance credits. As with SO2 allowance prices, DOE does not plan to 

monetize this particular benefit because the effect on the NOX allowance price from any single 

energy conservation standard is likely small and highly uncertain. 

Note that DOE plans to use NEMS-BT to estimate the emissions reductions from 

possible standards in the 22 States where emissions are not capped. 

Mercury

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 Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC 

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the DC 

Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the DC Circuit‘s opinion on the CAMR. See 

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental 

Analysis. 

DOE plans to develop the emissions reductions for NOX and Hg directly from the 

NEMS-BT output for these emissions, similar to its approach for CO2 emissions. This 

methodology is only possible if the NEMS model available at the time of the environmental 

analysis, namely the NEMS-BT based on AEO2008, is modified to be consistent with current 

laws regarding NOX and Hg emissions in the power sector. 

Item 42 DOE seeks input on its plans to use NEMS-BT to conduct the environmental 

impact analysis on the equipment covered by this rulemaking. DOE is particularly 

interested in whether there are any other approaches to the Environmental Assessment that 

it should consider and the advantages and disadvantages for each approach. 

16 MONETIZATION OF EMISSIONS REDUCTIONS 

For those emissions for which real national emission reductions are anticipated (CO2, Hg, 

and NOX), only a range of estimated economic values based on environmental damage studies of 

varying quality and applicability is available. Therefore, DOE plans on reporting and weighing 

these values. According to U.S. Office of Management and Budget (OMB) guidance, DOE will 

then conduct two calculations, one using a real discount rate of 3 percent and another using a real 

discount rate of 7 percent.35

 

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

CO2 emissions, it is DOE‘s intent to use in its analysis the most current Social Cost of Carbon 

(SCC) values developed and/or agreed to by interagency reviews. The SCC is intended to be a 

monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, 

including, but not limited to, net agricultural productivity loss, human health effects, property 

damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to 

monetize the harms associated with climate change will raise serious questions of science, 

 

35

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

EERE-2009-BT-STD-0018 DOC ID 1.2.001
51

economics, and ethics. But with full regard for the limits of both quantification and monetization, 

the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. 

 

 At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions were $5, $10, $20, $34 and $56 per metric ton, 

and the estimate of the potential domestic benefits was approximately $1 per metric ton. All of 

these unit values represent emissions that are valued in 2008$ for emissions that occur in 2008. 

For emissions (or emission reductions) that occur in later years, these values are escalated in real 

terms by 3 percent per year, then discounted to the present using real discount rates of 7 percent 

and 3 percent. 

 DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE will investigate the potential monetary benefit of reduced SO2, NOx, and Hg 

emissions from the TSLs it considers. DOE‘s initial analysis will assume the presence of 

nationwide emission caps on SO2 and caps on NOx emissions in the 28 States and DC covered by 

the CAIR. In the presence of these caps, the NEMS-BT modeling system that DOE uses to 

forecast emissions reduction indicated that no physical reductions in power sector emissions 

would occur for SO2, but that the standards could put slight downward pressure on the prices of 

emissions allowances in cap-and-trade markets. Estimating this effect is very difficult because 

such factors as credit banking can change the trajectory of prices. From its modeling to date, 

DOE is unable to estimate a benefit from SO2 emissions reductions at this time. 

 Because the courts have decided to allow the CAIR rule to remain in effect for now, 

projected annual NOx allowances from NEMS–BT are relevant. The update to the AEO2008-

based version of NEMS-BT includes the representation of CAIR. As noted above, standards 

would not produce an economic impact in the form of lower prices for emissions allowance 

credits in the 28 eastern States and DC covered by the CAIR cap. New or amended energy 

conservation standards would reduce NOx emissions in those 22 States that are not affected by 

the CAIR. For the area of the United States not covered by the CAIR, DOE will estimate the 

monetized value of NOx emissions reductions resulting from each of the TSLs considered based 

on environmental damage estimates from the literature. Available estimates suggest a very wide 

range of monetary values for NOx emissions, ranging from $370 per ton to $3,800 per ton of NOx

from stationary sources, measured in 2001$ (equivalent to a range of $442 to $4,540 per ton in 

2008$). Refer to the OMB, Office of Information and Regulatory Affairs, ―2006 Report to 

Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, 

Local, and Tribal Entities,‖ for additional information. 

For Hg emissions reductions, DOE will estimate the national monetized values resulting 

from the TSLs considered based on environmental damage estimates from the literature. DOE 

conducted research and determined that the impact of mercury emissions from power plants on 

humans is considered highly uncertain. However, DOE identified two estimates of the 

environmental damage of mercury based on two estimates of the adverse impact of childhood 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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exposure to methyl mercury on intelligence quotient (IQ) for American children, and subsequent 

loss of lifetime economic productivity resulting from these IQ losses. The high-end estimate is 

based on an estimate of the current aggregate cost of the loss of IQ in American children that 

results from exposure to mercury of U.S. power plant origin ($1.3 billion per year in year 

2000$), which works out to $33.3 million per ton emitted per year (2008$). Refer to L. Trasande 

et al., ―Applying Cost Analyses to Drive Policy that Protects Children,‖ 1076 Ann. N.Y. Acad. 

Sci. 911 (2006) for additional information. The low-end estimate is $0.66 million per ton emitted 

(in 2004$) or $0.745 million per ton in 2008$. DOE derived this estimate from a published 

evaluation of mercury control using different methods and assumptions from the first study but 

also based on the present value of the lifetime earnings of children exposed. See Ted Gayer and 

Robert Hahn, ―Designing Environmental Policy: Lessons from the Regulation of Mercury 

Emissions,‖ Regulatory Analysis 05–01, American Enterprise Institute-Brookings Joint Center 

for Regulatory Studies, Washington, DC (2004). A version of this paper was published in the 

Journal of Regulatory Economics in 2006. The estimate was derived by back-calculating the 

annual benefits per ton from the net present value of benefits reported in the study. 

Particulate Matter

DOE acknowledges that particulate matter (PM) impacts are of concern due to human 

exposures that can impact health. But impacts of PM emissions reduction are much more 

difficult to estimate than other emissions reductions due to the complex interactions between 

PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human 

exposure to particulates. Human exposure to PM usually occurs at a significant distance from the 

power plants that are emitting particulates and particulate precursors. When power plant 

emissions travel this distance, they undergo highly complex atmospheric chemical reactions. 

Although the EPA does keep inventories of direct PM emissions of power plants, in its source 

attribution reviews, the EPA does not separate direct PM emissions from power plants from the 

particulates indirectly produced through complex atmospheric chemical reactions. This is in part 

because SO2 emissions react with direct PM emissions particles to produce combined sulfate 

particulates. Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to calculate and monetize the value of reduction in emissions of particulate matter 

as a result of these standards. 

Item 43 DOE invites comments on how to estimate such monetary values associated 

with emissions reductions or on any widely-accepted values that might be used in DOE’s 

analyses 

Item 44 DOE invites comment on how to estimate the benefits of reduced SO2 

emissions. 

Item 45 DOE invites comment on the estimated range ($370 to $3,800 each in 2001$) 

per ton of NOx for use in DOE’s analyses. 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Item 46 DOE invites comment on the estimated range ($0.745 to $33.3 million each in 

2008$) per ton of Hg for use in DOE’s analyses. 

Item 47 DOE invites comment on the estimated social cost of carbon for use in DOE’s 

analyses. 

Item 48 DOE seeks input on other environmental factors to consider in this 

rulemaking. 

17 REGULATORY IMPACT ANALYSIS 

DOE will prepare a regulatory impact analysis in the NOPR and final rule stages of this 

rulemaking. This analysis will address the potential for non-regulatory approaches to supplant or 

augment amended energy conservation standards to improve the efficiency of metal halide lamp 

fixtures on the market. DOE recognizes that voluntary and other non-regulatory efforts by 

manufacturers, utilities, and other interested parties can result in substantial efficiency 

improvements. DOE intends to analyze the likely effects of non-regulatory initiatives on product 

energy use, customer utility, and LCCs. DOE will try to base its assessment on the actual 

impacts of any such initiatives to date, but also will consider information presented on the 

impacts that any existing initiative might have in the future. 

If DOE determines that amended energy conservation standards for metal halide lamp 

fixtures would constitute a significant regulatory action, DOE will prepare and submit to OMB 

the assessment of costs and benefits required under section 6(a)(3) of Executive Order 12866, 

―Regulatory Planning and Review,‖ 58 FR 51735 (Oct. 4, 1993). 

APPENDIX A – LIST OF ITEMS FOR COMMENT 

This appendix lists all the items for comment contained in this framework document, and the 

page numbers on which those items can be found. 

Item 1 DOE welcomes comment on its approach of amending only minimum ballast efficiency 

requirements, and not lamp efficiency requirements, as part of the metal halide lamp 

fixture energy conservation standards rulemaking. ............................................................ 7

Item 2 DOE welcomes comments on the expansion of the scope of this rulemaking to potentially 

include all metal halide lamp fixtures that operate lamps rated to less than 150W and 

above 500W, in addition to those fixtures already covered by standards which operate 

lamps in the 150W to 500W range. .................................................................................... 7

Item 3 DOE welcomes comments on the expansion of the scope of this rulemaking to include all 

metal halide lamp fixtures currently excluded under 42 U.S.C. 6295(hh)(1)(B). .............. 7

Item 4 DOE welcomes comment on issues arising from the standby mode and off mode 

provisions from EISA 2007, including: (a) whether DOE should modify its test procedure 

for metal halide lamp ballasts, and if so, how; (b) whether metal halide lamp fixtures 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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consume energy in off mode, and if so, which ones; (c) which covered metal halide lamp 

fixtures use energy in standby mode; and (d) how DOE should incorporate standby mode 

energy consumption into its analysis for the energy conservation standard. ...................... 8

Item 5 DOE welcomes comments on the issue of whether it is necessary to update the metal 

halide lamp ballast test procedure, and if so, how. ............................................................. 8

Item 6 DOE welcomes input on estimates of market shares, equipment, features, and efficiency 

trends for the metal halide lamp fixtures covered in this rulemaking. .............................. 16

Item 7 DOE welcomes input on manufacturers of covered equipment as well as distribution 

channels used for sales of covered equipment. ................................................................. 16

Item 8 DOE welcomes comments on equipment classes for metal halide lamp fixtures and 

approaches to defining classes in accordance with the requirements of 42 U.S.C. 6295(q).

 22

Item 9 DOE seeks input on how ballast efficiency varies by lamp wattage and input voltage.

 22

Item 10 DOE seeks input on the rated lamp wattage bins identified for equipment classes. 

Specifically, DOE is interested in information that could be used to alter the number of 

bins or alter the wattages included in each bin. ................................................................ 22

Item 11 DOE welcomes comments on how to approach universal voltage systems that are 

gaining market share and becoming more readily available. ............................................ 22

Item 12 DOE welcomes comments on the preliminary technology options identified in this 

section and whether there are other technology options it should consider. In commenting 

on design options, please discuss their impacts on safety, performance, and consumer 

utility (if any). ................................................................................................................... 24

Item 13 DOE welcomes comments on how the above four screening criteria might apply to 

any additional technology option(s) that an interested party recommends to DOE. ........ 25

Item 14 DOE welcomes comments on the identification and selection of representative 

equipment classes for metal halide lamp fixtures. ............................................................ 27

Item 15 DOE welcomes comments on its approach to scaling from representative equipment 

classes to classes not directly analyzed in the engineering analysis. ................................ 28

Item 16 DOE welcomes comments on the selection of baseline models from the 

representative equipment classes. ..................................................................................... 29

Item 17 DOE seeks comments on its approach to calculating the cost-efficiency relationship 

for metal halide lamp ballasts used in metal halide lamp fixtures. ................................... 30

Item 18 DOE welcomes comments on commercially-available metal halide lamp ballasts for 

each baseline model with incrementally increasing ballast efficiency, all the way to the 

max-tech ballast. ............................................................................................................... 30

Item 19 DOE welcomes comments on how ballast efficiency varies with lamp wattage, 

voltage, or any other ballast parameter. ............................................................................ 30

Item 20 DOE seeks information on proprietary designs it should be aware of for the metal 

halide lamp ballasts under consideration in this rulemaking, and if such proprietary 

designs exist, how DOE can acquire the cost data necessary for evaluating these designs.

 31

Item 21 DOE welcomes comments on regulatory burdens and changes that should be 

considered in the engineering analysis of metal halide lamp fixtures. ............................. 31

Item 22 DOE welcomes comments on other engineering issues that could affect the 

engineering analysis. ......................................................................................................... 31

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Item 23 DOE welcomes comments on its use of the planned operating hours profile for metal 

halide lamp fixtures. DOE also welcomes comments on whether the end-use operating 

profiles are different for the various types of metal halide lamp fixtures covered under 

this rulemaking, and if so, how. ........................................................................................ 32

Item 24 DOE requests comments on the planned distribution path for the metal halide lamp 

fixtures covered under this rulemaking and whether DOE should consider any additional 

paths. DOE also requests information on the relative fraction of shipments expected for 

each path. .......................................................................................................................... 33

Item 25 DOE requests feedback on the overall markups for the metal halide lamp fixtures 

covered under this rulemaking for each path in the distribution chain. ............................ 33

Item 26 DOE seeks comments on other sources of relevant data that could be used to 

characterize markups for metal halide lamp fixtures. ....................................................... 33

Item 27 DOE welcomes input on the electricity prices used in this analysis. ......................... 35

Item 28 DOE welcomes input on the planned approaches for estimating discount rates for 

consumers of the metal halide lamp fixtures covered under this rulemaking. .................. 36

Item 29 DOE welcomes comments on appropriate lifetimes for the metal halide lamp fixtures 

and the ballasts contained in those fixtures covered in this rulemaking. .......................... 36

Item 30 DOE welcomes comments on how to develop installation, maintenance, and (if 

applicable) repair costs for metal halide lamp fixtures. If the lamps operated by moreefficient ballasts would be affected, DOE invites comments on whether re-lamping 

practices (i.e., group re-lamping or spot re-lamping) would change as a result of energy 

conservation standards. ..................................................................................................... 37

Item 31 DOE welcomes recommendations on sources of data for shipments of metal halide 

lamp fixtures by product class. In addition, DOE welcomes comments on how it might 

characterize long-term trends in the efficiency of metal halide lamp fixtures for the basecase shipments forecast. .................................................................................................... 38

Item 32 DOE welcomes comments on the accounting methodology described above for each 

type of metal halide lamp fixture covered in this rulemaking. ......................................... 39

Item 33 DOE welcomes comments on how amended energy conservation standards might 

affect shipments of metal halide lamp fixtures. DOE also requests information about 

existing market-pull programs, such as consumer rebate programs, to promote the 

adoption of more-efficacious ballasts. .............................................................................. 39

Item 34 DOE welcomes comments on the data sources it anticipates using to develop inputs 

for the national impact analysis. ....................................................................................... 41

Item 35 DOE welcomes comments from interested parties as to whether a more-efficient 

metal halide lamp fixture would be expected to be used more as a result of increased 

efficiency and whether such a rebound effect would be expected for this technology. ... 41

Item 36 DOE welcomes comments from interested parties on the NES spreadsheet models it 

plans to use for estimating national impacts of amended energy conservation standards 

for metal halide lamp fixtures. .......................................................................................... 42

Item 37 DOE welcomes comments from interested parties on what, if any, consumer 

subgroups should be considered when developing amended standards for metal halide 

lamp fixtures. .................................................................................................................... 43

Item 38 DOE seeks comments on the subgroups of metal halide lamp fixtures and ballast 

manufacturers that it should consider in a manufacturer subgroup analysis. ................... 45

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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Item 39 DOE welcomes comments on what other regulations or pending regulations it should 

consider in its examination of cumulative regulatory burden. .......................................... 46

Item 40 DOE seeks input on its plans to use NEMS-BT to conduct the utility impact analysis 

on the equipment covered under this rulemaking. ............................................................ 47

Item 41 DOE requests feedback on its approach to assessing employment impacts on the 

equipment covered under this rulemaking. ....................................................................... 48

Item 42 DOE seeks input on its plans to use NEMS-BT to conduct the environmental impact 

analysis on the equipment covered by this rulemaking. DOE is particularly interested in 

whether there are any other approaches to the Environmental Assessment that it should 

consider and the advantages and disadvantages for each approach. ................................. 50

Item 43 DOE invites comments on how to estimate such monetary values associated with 

emissions reductions or on any widely-accepted values that might be used in DOE‘s 

analyses ............................................................................................................................. 52

Item 44 DOE invites comment on how to estimate the benefits of reduced SO2 emissions. ... 52

Item 45 DOE invites comment on the estimated range ($370 to $3,800 each in 2001$) per ton 

of NOx for use in DOE‘s analyses. ................................................................................... 52

Item 46 DOE invites comment on the estimated range ($0.745 to $33.3 million each in 2008$) 

per ton of Hg for use in DOE‘s analyses. ......................................................................... 53

Item 47 DOE invites comment on the estimated social cost of carbon for use in DOE‘s 

analyses. ............................................................................................................................ 53

Item 48 DOE seeks input on other environmental factors to consider in this rulemaking. ..... 53

APPENDIX B – DEFINITIONS 

This appendix provides relevant definitions under the statute (42 U.S.C. 6291) that are 

applicable to the lighting products covered under this rulemaking. DOE takes the definitions 

from the statute and codifies them into the CFR. Please note that due to the recent enactment of 

EISA 2007 (Pub. L. 110-140; December 19, 2007), some terms may only be defined in the 

statute at the time this framework document is published, as they have not yet been codified into 

the CFR. 

STATUTORY DEFINITIONS 

“Ballast” 

42 U.S.C. 6291(58) 

The term ―ballast‖ means a device used with an electric discharge lamp to obtain 

necessary circuit conditions (voltage, current, and waveform) for starting and operating. 

“Ballast Efficiency” 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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42 U.S.C. 6291(59) 

(A) IN GENERAL.-- The term ―ballast efficiency‖ means, in the case of a high intensity 

discharge fixture, the efficiency of a lamp and ballast combination, expressed as a 

percentage, and calculated in accordance with the following formula: Efficiency = 

Pout/Pin. 

(B) EFFICIENCY FORMULA.-- For the purpose of subparagraph (A)--

(i) Pout shall equal the measured operating lamp wattage; 

(ii) Pin shall equal the measured operating input wattage; 

(iii) the lamp, and the capacitor when the capacitor is provided, shall constitute a 

nominal system in accordance with the ANSI Standard C78.43-2004; 

(iv) for ballasts with a frequency of 60 Hz, Pin and Pout

 shall be measured after 

lamps have been stabilized according to section 4.4 of ANSI Standard C82.6-

2005 using a wattmeter with accuracy specified in section 4.5 of ANSI Standard 

C82.6-2005; and 

(v) for ballasts with a frequency greater than 60 Hz, Pin and Pout shall have a basic 

accuracy of ±0.5 percent at the higher of--

(I) 3 times the output operating frequency of the ballast; or 

(II) 2 kHz for ballast with a frequency greater than 60 Hz. 

(C) MODIFICATION.-- The Secretary may, by rule, modify the definition of `ballast 

efficiency' if the Secretary determines that the modification is necessary or appropriate to 

carry out the purposes of this Act. 

“Electronic Ballast” 

42 U.S.C. 6291(60) 

The term ―electronic ballast‖ means a device that uses semiconductors as the primary 

means to control lamp starting and operation. 

“General Lighting Application” 

42 U.S.C. 6291(61) 

 The term ―general lighting application‖ means lighting that provides an interior or 

exterior area with overall illumination. 

“Metal Halide Ballast” 

42 U.S.C. 6291(62) 

EERE-2009-BT-STD-0018 DOC ID 1.2.001
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The term ―metal halide ballast‖ means a ballast used to start and operate metal halide 

lamps. 

“Metal Halide Lamp” 

42 U.S.C. 6291(63) 

The term ―metal halide lamp‖ means a high intensity discharge lamp in which the major 

portion of the light is produced by radiation of metal halides and their products of 

dissociation, possibly in combination with metallic vapors. 

“Metal Halide Lamp Fixture” 

42 U.S.C. 6291(64) 

The term ―metal halide lamp fixture‖ means a light fixture for general lighting 

application designed to be operated with a metal halide lamp and a ballast for a metal 

halide lamp. 

“Probe-Start Metal Halide Ballast” 

42 U.S.C. 6291(65) 

The term ―probe-start metal halide ballast‖' means a ballast that--

`(A) starts a probe-start metal halide lamp that contains a third starting electrode 

(probe) in the arc tube; and 

`(B) does not generally contain an igniter but instead starts lamps with high ballast 

open circuit voltage. 

“Pulse-Start Metal Halide Ballast” 

42 U.S.C. 6291(66) 

 (A) IN GENERAL.-- The term ―pulse-start metal halide ballast‖ means an electronic or 

electromagnetic ballast that starts a pulse-start metal halide lamp with high voltage 

pulses. 

(B) STARTING PROCESS.-- For the purpose of subparagraph (A)--

`(i) lamps shall be started by first providing a high voltage pulse for ionization of 

the gas to produce a glow discharge; and 

`(ii) to complete the starting process, power shall be provided by the ballast to 

sustain the discharge through the glow-to-arc transition.' 

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APPENDIX C – ENERGY INDEPENDENCE AND SECURITY ACT OF 2007 

 On December 19, 2007, the President signed into law the Energy Independence and 

Security Act of 2007 (EISA 2007) (P.L. 110-140). This legislation amended certain aspects of 

EPCA, including, in particular, setting mandatory efficiency standards for metal halide lamp 

fixtures. Among other things, the new standard for metal halide lamp fixtures establishes 

requirements for the efficiency of the ballasts installed in metal halide lamp fixtures. The entirety 

of EISA 2007 section 324, ―Metal Halide Lamp Fixtures,‖ is included here for reference. 

―SEC. 324. METAL HALIDE LAMP FIXTURES. 

(a) DEFINITIONS.-- Section 321 of the Energy Policy and Conservation Act (42 U.S.C. 6291) (as 

amended by section 322(a)(2)) is amended by adding at the end the following: 

`(58) BALLAST.-- The term `ballast' means a device used with an electric discharge lamp 

to obtain necessary circuit conditions (voltage, current, and waveform) for starting and 

operating. 

`(59) BALLAST EFFICIENCY.--

`(A) IN GENERAL.-- The term `ballast efficiency' means, in the case of a high intensity 

discharge fixture, the efficiency of a lamp and ballast combination, expressed as a 

percentage, and calculated in accordance with the following formula: Efficiency = 

Pout/Pin. 

`(B) EFFICIENCY FORMULA.-- For the purpose of subparagraph (A)--

`(i) Pout shall equal the measured operating lamp wattage; 

`(ii) Pin shall equal the measured operating input wattage; 

`(iii) the lamp, and the capacitor when the capacitor is provided, shall constitute a 

nominal system in accordance with the ANSI Standard C78.43-2004; 

`(iv) for ballasts with a frequency of 60 Hz, Pin and Pout

 shall be measured after 

lamps have been stabilized according to section 4.4 of ANSI Standard C82.6-

2005 using a wattmeter with accuracy specified in section 4.5 of ANSI Standard 

C82.6-2005; and 

`(v) for ballasts with a frequency greater than 60 Hz, Pin and Pout shall have a basic 

accuracy of ±0.5 percent at the higher of--

`(I) 3 times the output operating frequency of the ballast; or 

`(II) 2 kHz for ballast with a frequency greater than 60 Hz. 

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`(C) MODIFICATION.-- The Secretary may, by rule, modify the definition of `ballast 

efficiency' if the Secretary determines that the modification is necessary or 

appropriate to carry out the purposes of this Act. 

`(60) ELECTRONIC BALLAST.-- The term `electronic ballast' means a device that uses 

semiconductors as the primary means to control lamp starting and operation. 

`(61) GENERAL LIGHTING APPLICATION.-- The term `general lighting application' means 

lighting that provides an interior or exterior area with overall illumination. 

`(62) METAL HALIDE BALLAST.-- The term `metal halide ballast' means a ballast used to 

start and operate metal halide lamps. 

`(63) METAL HALIDE LAMP.-- The term `metal halide lamp' means a high intensity 

discharge lamp in which the major portion of the light is produced by radiation of metal 

halides and their products of dissociation, possibly in combination with metallic vapors. 

`(64) METAL HALIDE LAMP FIXTURE.-- The term `metal halide lamp fixture' means a light 

fixture for general lighting application designed to be operated with a metal halide lamp 

and a ballast for a metal halide lamp. 

`(65) PROBE-START METAL HALIDE BALLAST.-- The term `probe-start metal halide ballast' 

means a ballast that--

`(A) starts a probe-start metal halide lamp that contains a third starting electrode 

(probe) in the arc tube; and 

`(B) does not generally contain an igniter but instead starts lamps with high ballast 

open circuit voltage. 

`(66) PULSE-START METAL HALIDE BALLAST.--

`(A) IN GENERAL.-- The term `pulse-start metal halide ballast' means an electronic or 

electromagnetic ballast that starts a pulse-start metal halide lamp with high voltage 

pulses. 

`(B) STARTING PROCESS.-- For the purpose of subparagraph (A)--

`(i) lamps shall be started by first providing a high voltage pulse for ionization of 

the gas to produce a glow discharge; and 

`(ii) to complete the starting process, power shall be provided by the ballast to 

sustain the discharge through the glow-to-arc transition.'. 

(b) COVERAGE.-- Section 322(a) of the Energy Policy and Conservation Act (42 U.S.C. 6292(a)) 

is amended— 

(1) by redesignating paragraph (19) as paragraph (20); and 

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(2) by inserting after paragraph (18) the following: 

`(19) Metal halide lamp fixtures.'. 

(c) TEST PROCEDURES.-- Section 323(b) of the Energy Policy and Conservation Act (42 U.S.C. 

6293(b)) (as amended by section 301(b)) is amended by adding at the end the following: 

`(18) METAL HALIDE LAMP BALLASTS.-- Test procedures for metal halide lamp ballasts 

shall be based on ANSI Standard C82.6-2005, entitled `Ballasts for High Intensity 

Discharge Lamps--Method of Measurement'.'. 

(d) LABELING.-- Section 324(a)(2) of the Energy Policy and Conservation Act (42 U.S.C. 

6294(a)(2)) is amended— 

(1) by redesignating subparagraphs (C) through (G) as subparagraphs (D) through (H), 

respectively; and 

(2) by inserting after subparagraph (B) the following: 

`(C) METAL HALIDE LAMP FIXTURES.--

`(i) IN GENERAL.-- The Commission shall issue labeling rules under this section 

applicable to the covered product specified in section 322(a)(19) and to which 

standards are applicable under section 325. 

`(ii) LABELING.-- The rules shall provide that the labeling of any metal halide 

lamp fixture manufactured on or after the later of January 1, 2009, or the date that 

is 270 days after the date of enactment of this subparagraph, shall indicate 

conspicuously, in a manner prescribed by the Commission under subsection (b) 

by July 1, 2008, a capital letter `E' printed within a circle on the packaging of the 

fixture, and on the ballast contained in the fixture.'. 

(e) STANDARDS.-- Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) (as 

amended by section 310) is amended— 

(1) by redesignating subsection (hh) as subsection (ii); 

(2) by inserting after subsection (gg) the following: 

`(hh) METAL HALIDE LAMP FIXTURES.--

`(1) STANDARDS.--

`(A) IN GENERAL.-- Subject to subparagraphs (B) and (C), metal halide 

lamp fixtures designed to be operated with lamps rated greater than or 

equal to 150 watts but less than or equal to 500 watts shall contain--

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`(i) a pulse-start metal halide ballast with a minimum ballast 

efficiency of 88 percent; 

`(ii) a magnetic probe-start ballast with a minimum ballast 

efficiency of 94 percent; or 

`(iii) a nonpulse-start electronic ballast with--

`(I) a minimum ballast efficiency of 92 percent for wattages 

greater than 250 watts; and 

`(II) a minimum ballast efficiency of 90 percent for 

wattages less than or equal to 250 watts. 

`(B) EXCLUSIONS.-- The standards established under subparagraph (A) 

shall not apply to--

`(i) fixtures with regulated lag ballasts; 

`(ii) fixtures that use electronic ballasts that operate at 480 volts; or 

`(iii) fixtures that--

`(I) are rated only for 150 watt lamps; 

`(II) are rated for use in wet locations, as specified by the 

National Electrical Code 2002, section 410.4(A); and 

`(III) contain a ballast that is rated to operate at ambient air 

temperatures above 50°C, as specified by UL 1029-2001. 

`(C) APPLICATION.-- The standards established under subparagraph (A) 

shall apply to metal halide lamp fixtures manufactured on or after the later 

of--

`(i) January 1, 2009; or 

`(ii) the date that is 270 days after the date of enactment of this 

subsection. 

`(2) FINAL RULE BY JANUARY 1, 2012.--

`(A) IN GENERAL.-- Not later than January 1, 2012, the Secretary shall 

publish a final rule to determine whether the standards established under 

paragraph (1) should be amended. 

`(B) ADMINISTRATION.-- The final rule shall--

`(i) contain any amended standard; and 

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`(ii) apply to products manufactured on or after January 1, 2015. 

`(3) FINAL RULE BY JANUARY 1, 2019.--

`(A) IN GENERAL.-- Not later than January 1, 2019, the Secretary shall 

publish a final rule to determine whether the standards then in effect 

should be amended. 

`(B) ADMINISTRATION.-- The final rule shall-- 

`(i) contain any amended standards; and 

`(ii) apply to products manufactured after January 1, 2022. 

`(4) DESIGN AND PERFORMANCE REQUIREMENTS.-- Notwithstanding any other 

provision of law, any standard established pursuant to this subsection may contain 

both design and performance requirements.'; and 

(3) in paragraph (2) of subsection (ii) (as redesignated by paragraph (2)), by striking 

`(gg)' each place it appears and inserting `(hh)'. 

(f) EFFECT ON OTHER LAW.-- Section 327(c) of the Energy Policy and Conservation Act (42 

U.S.C. 6297(c)) is amended— 

(1) in paragraph (8)(B), by striking the period at the end and inserting `; and'; and 

(2) by adding at the end the following: 

`(9) is a regulation concerning metal halide lamp fixtures adopted by the California 

Energy Commission on or before January 1, 2011, except that--

`(A) if the Secretary fails to issue a final rule within 180 days after the deadlines 

for rulemakings in section 325(hh), notwithstanding any other provision of this 

section, preemption shall not apply to a regulation concerning metal halide lamp 

fixtures adopted by the California Energy Commission--

`(i) on or before July 1, 2015, if the Secretary fails to meet the deadline 

specified in section 325(hh)(2); or 

 `(ii) on or before July 1, 2022, if the Secretary fails to meet the deadline 

specified in section 325(hh)(3).'. 

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