ES-i 

EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES ......................................... 1

ES.2 KEY RESULTS OF THE ANALYSIS .............................................................................. 3

ES.2.1 Determination of Scope .................................................................................... 3

ES.2.2 Market and Technology Assessment ................................................................ 3

ES.2.3 Screening Analysis............................................................................................ 4

ES.2.4 Engineering Analysis ........................................................................................ 4

ES.2.5 Energy Use Characterization ............................................................................ 5

ES.2.6 Markups Analysis ............................................................................................. 6

ES.2.7 Life-Cycle Cost and Payback Period Analyses ................................................ 7

ES.2.8 Shipments Analysis ........................................................................................... 8

ES.2.9 National Impact Analysis ................................................................................ 10

ES.2.9.1 National Energy Savings Analysis................................................ 11

ES.2.9.2 Net Present Value Analysis .......................................................... 12

ES.2.10 Preliminary Manufacturer Impact Analysis .................................................... 13

ES.2.11 Other Analyses ................................................................................................ 13

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT ............................................. 14

ES.3.1 Test Procedure – ANSI C82.6 ........................................................................ 14

ES.3.2 Test Procedure – Input Voltage ...................................................................... 14

ES.3.3 Standby Mode Energy Consumption .............................................................. 14

ES.3.4 Scope of Coverage .......................................................................................... 15

ES.3.5 Lamp-ballast System Approach ...................................................................... 15

ES.3.6 California Title 20 System Approach ............................................................. 15

ES.3.7 Fixture-level System Approach ...................................................................... 16

ES.3.8 Technology Options ........................................................................................ 16

ES.3.9 Technology Options – Electronic vs. Magnetic Ballasts ................................ 16

ES.3.10 Dimming ......................................................................................................... 16

ES.3.11 Equipment Classes .......................................................................................... 16

ES.3.12 Equipment Classes – Input Voltage ................................................................ 17

ES.3.13 Equipment Classes – Number of Lamps ......................................................... 17

ES.3.14 Equipment Classes – Electronic Configuration and Circuit Type .................. 17

ES.3.15 Equipment Classes – Fixture Application....................................................... 17

ES.3.16 Screening Analysis.......................................................................................... 17

ES.3.17 Representative Wattages and Fixtures ............................................................ 18

ES.3.18 Candidate Standard Levels ............................................................................. 18

ES.3.19 CSLs – Proprietary Designs ............................................................................ 18

ES.3.20 CSLs – Wattage Bins vs. Equation-based Approach ...................................... 18

ES.3.21 CSLs – High Frequency Electronic Ballast .................................................... 18

ES.3.22 Probe-Start Lumen Maintenance .................................................................... 18

ES.3.23 Maximum Technological Feasibility .............................................................. 19

ES.3.24 Manufacturer Production Costs ...................................................................... 19

ES.3.25 Normalized Input Power ................................................................................. 19

ES.3.26 Cumulative and Future Regulation ................................................................. 19
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ES.3.27 Operating Profiles for Energy Use Characterization ...................................... 19

ES.3.28 Lighting Controls and Fixture Operating Profiles .......................................... 20

ES.3.29 Price Markups ................................................................................................. 20

ES.3.30 Average Equipment Lifetimes and Failure Distributions ............................... 20

ES.3.31 Historical Shipments Data .............................................................................. 20

ES.3.32 Shipment Trends ............................................................................................. 20

ES.3.33 LCC Subgroups ............................................................................................... 21

ES.3.34 Trial Standard Levels ...................................................................................... 21

ES.3.35 Impact on Manufacturers ................................................................................ 21

ES.3.36 Valuing Airborne Emission Reductions ......................................................... 21
ES-iii

LIST OF TABLES

Table ES.2.1 Equipment Classes for Metal Halide Lamp Fixtures .................................................3

Table ES.2.2 Summary of Baselines and Candidate Standard Levels for Metal Halide 

Lamp Fixture Representative Equipment Classes ...................................................5

Table ES.2.3 Summary of Manufacturer Selling Prices for Metal Halide Lamp Fixture 

Representative Equipment Classes ..........................................................................5

Table ES.2.4 Average Annual Metal Halide Lamp Fixture Operating Hours by Sector ................5

Table ES.2.5 Annual Energy Consumption by Metal Halide Lamp Fixture Equipment 

Class .........................................................................................................................6

Table ES.2.6 Markups for Fixtures .................................................................................................7

Table ES.2.7 Life-Cycle Cost and Payback Period Results for Metal Halide Lamp 

Fixtures ....................................................................................................................8

Table ES.2.8 Cumulative National Energy Savings for Metal Halide Lamp Fixtures 

(2015–2044) ...........................................................................................................12

Table ES.2.9 Cumulative Net Present Value Results for Metal Halide Lamp Fixtures 

(2015–2044) ...........................................................................................................13

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Metal Halide Lamp Fixture 

Rulemaking Process .................................................................................................2

Figure ES.2.1 Metal Halide Lamp Fixture Distribution Channel ...................................................7

Figure ES.2.2 Base-Case Forecasted Shipments for 70 W Metal Halide Lamp Fixtures ..............9

Figure ES.2.3 Base-Case Forecasted Shipments for 250 W Metal Halide Lamp Fixtures ............9

Figure ES.2.4 Base-Case Forecasted Shipments for 400 W Metal Halide Lamp Fixtures ............9

Figure ES.2.5 Base-Case Forecasted Shipments for 1000 W Metal Halide Lamp Fixtures ........10
ES-1

EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

 Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that are technologically feasible and economically 

justified, and that would achieve the maximum improvement in energy efficiency. This executive 

summary highlights the activities associated with this preliminary analysis that DOE conducted 

when considering new energy conservation standards for metal halide lamp fixtures. The 

executive summary also describes key results from DOE’s preliminary analysis and delineates 

issues on which DOE seeks comment. These issues are highlighted in the public meeting 

presentation and are further discussed in chapter 2 of the preliminary technical support document 

(TSD). 

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and relate to each other. Key inputs are the types of data and 

other information required by analyses. DOE obtains some key information from public 

databases and collects other inputs from interested parties or persons having special knowledge 

and expertise. Key outputs are analytical results that feed directly into the standards-setting 

process. The issues on which DOE seeks comment from interested parties derive from the key 

results that are generated by the preliminary analyses. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 
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Figure ES.1.1 Flow Diagram of Analyses for the Metal Halide Lamp Fixture Rulemaking 

Process
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ES.2 KEY RESULTS OF THE ANALYSIS 

 The following sections describe in detail the key analyses DOE performed. 

ES.2.1 Determination of Scope 

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 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. 6295(hh)(2)(A). Significant additional energy savings may be 

possible by expanding ballast efficiency regulations to cover fixtures that operate lamps rated 

outside the current wattage limitation and to metal halide lamp fixtures specifically exempted by 

Energy Independence Security Act of 2007 (EISA 2007). See chapter 2 of the preliminary TSD 

for details concerning the existing scope of energy conservation standards and DOE’s rationale 

for expansion. 

ES.2.2 Market and Technology Assessment 

A market and technology assessment characterizes the relevant product markets and 

technology options, including prototype designs. See chapter 3 of the preliminary TSD for 

details. 

 DOE generally divides covered equipment into equipment classes by the type of energy 

used, capacity, or other performance-related features that affect efficiency. Different energy 

conservation standards may apply to different equipment classes. (42 U.S.C. 6295(q)) Table 

ES.2.1 describes all of the equipment classes DOE is considering in this rulemaking.

Table ES.2.1 Equipment Classes for Metal Halide Lamp Fixtures 

Equipment Classes Rated Lamp Wattage

1 ≥50 W and <150 W

2 ≥150 W and ≤250 W

3 >250 W and ≤500 W

4 >500 W

DOE addresses (1) manufacturer market share and characteristics, (2) existing regulatory 

and non-regulatory initiatives for improving product efficiency, and (3) trends in equipment

characteristics and retail markets. This information provides data and resource material 

throughout the analysis. 

DOE reviews literature and interviews manufacturers to develop an overall understanding 

of the metal halide lamp fixture industry. Industry publications—including trade journals, 

literature from manufacturers, government agencies, and trade organizations—provide the bulk 

of the information, which includes: (1) manufacturers and their market share, (2) shipments by 

equipment type, (3) equipment information, and (4) industry trends. 
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 DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. The technologies initially identified include all those DOE 

believes are technologically feasible. 

ES.2.3 Screening Analysis

 DOE develops an initial list of options for enhancing efficiency from the technologies 

that the technology assessment identified as feasible. In consultation with interested parties, DOE 

reviews the list to assess whether the technologies are practicable to manufacture, install, and 

service; would adversely affect product utility or availability; or would have adverse impacts on 

health and safety. In the subsequent engineering analysis, DOE further examines the technology 

options that it did not remove from consideration in the screening analysis. See chapter 4 of the 

preliminary TSD for details.

ES.2.4 Engineering Analysis 

The engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups to 

convert manufacturer production cost (MPC) to manufacturer selling price (MSP) (see chapter 

5). 

The engineering analysis analyzed the four equipment classes for the metal halide lamp 

fixture market covered in this rulemaking. For each equipment class, DOE chose representative 

wattages and fixture types to represent the entire equipment class. DOE also chose appropriate 

baseline metal halide lamp ballasts and identified more efficient replacements. For each 

candidate ballast and fixture design, DOE calculated the MSP and measured the ballast 

efficiency, and used the values to generate cost-efficiency points for each equipment class. To 

calculate MSP, DOE generated a bill of materials (BOM) by disassembling multiple 

manufacturers’ fixtures and ballasts that spanned a range of efficiency levels. DOE then 

developed a cost model that converted the BOM pricing into MPCs. By applying derived 

manufacturer markups to the MPCs, DOE calculated the MSPs. Some manufacturers supplied 

limited MSP information that allowed for calibration of assumptions. See chapter 5 of the 

preliminary TSD for details.

Table ES.2.2 presents the ballast efficiency identified for each baseline and candidate 

standard level (CSL) in the engineering analysis. Table ES.2.3 presents the MSP for each of 

these more efficient options. 
ES-5

Table ES.2.2 Summary of Baselines and Candidate Standard Levels for Metal Halide

Lamp Fixture Representative Equipment Classes

Equipment Class (Rated Lamp Wattage) Ballast Efficiency (%)

Baseline CSL1 CSL2 CSL3 CSL4

≥50 W and <150 W 72.3 76.1 89.3 91.1

≥150 W and ≤250 W 88.0 90.5 91.5 93.2 93.6

>250 W and ≤500 W 88.0 90.0 91.7 92.7 93.9

>500 W 91.9 92.6 93.3

Table ES.2.3 Summary of Manufacturer Selling Prices for Metal Halide Lamp Fixture

Representative Equipment Classes

Equipment Class (Rated Lamp Wattage) Manufacturer Selling Prices ($)

Baseline CSL1 CSL2 CSL3 CSL4

≥50 W and <150 W 51.53 52.23 54.69 61.12

≥150 W and ≤250 W 106.38 112.49 119.17 137.88 134.41

>250 W and ≤500 W 135.72 148.24 156.72 184.63 204.44

>500 W 254.00 263.18 267.68

ES.2.5 Energy Use Characterization

The energy use characterization, which assesses the potential energy savings resulting 

from amended efficiency standards, provides the basis for developing the energy savings used in 

the life-cycle cost (LCC) and subsequent analyses. Metal halide lamp ballasts are designed to 

operate metal halide lamps, which are not subject to the energy efficiency standards being 

developed in this rulemaking. However, because metal halide ballasts are not intended to operate 

without lamps, the input power of the complete lamp-and-ballast system was required for the 

energy use analysis. DOE determined the annual energy usage of the lamp-and-ballast systems in 

metal halide lamp fixtures using information on input power (i.e., the rate of energy they 

consume) and the way consumers use them (i.e., operating hours per year). Table ES.2.4

summarizes the average annual operating hours used for the energy use characterization, 

organized by market sector. 

Table ES.2.4 Average Annual Metal Halide Lamp Fixture Operating Hours by Sector

Sector Average Annual Operating Hours

hrs/year

Commercial 3,720

Industrial 4,748

Outdoor Stationary 4,098

The engineering analysis references rated lamp wattage and measured ballast efficiency, 

which were used to calculate system input power for the representative equipment types. Table 

ES.2.5 shows the average annual electricity use in kilowatt-hours (kWh) for each efficiency level 

in every equipment class that DOE considers in this rulemaking. 
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Table ES.2.5 Annual Energy Consumption by Metal Halide Lamp Fixture Equipment

Class

Representative 

Equipment Class

CSL Annual Energy Use by Sector

kWh

Commercial Industrial Outdoor

Stationary

70 W Fixture Baseline 360.2 459.7 396.8

1 342.2 436.8 377.0

2 291.5 372.0 321.1

3 285.8 364.7 314.8

250 W Fixture Baseline 1,057.0 1,348.9 1,164.4

1 1,027.8 1,311.6 1,132.3

2 1,016.6 1,297.3 1,119.9

3 997.5 1,273.0 1,098.9

4 993.8 1,268.2 1,094.8

400 W Fixture Baseline 1,691.2 2,158.3 1,863.1

1 1,653.6 2,110.3 1,821.7

2 1,622.9 2,071.2 1,787.9

3 1,605.4 2,048.8 1,768.6

4 1,584.9 2,022.6 1,746.0

1000 W Fixture Baseline 4,048.5 5,166.7 4,460.0

1 4,017.9 5,127.6 4,426.3

2 3,987.8 5,089.1 4,393.1

 For more details on the energy use characterization, see chapter 2 and chapter 6 of the 

preliminary TSD.

ES.2.6 Markups Analysis

 A markups analysis converts the original equipment manufacturer (OEM) selling price

derived from the engineering analysis to end-user prices. In developing markups, DOE 

determined the distribution channel for metal halide lamp fixtures and the markup associated 

with each party in the distribution channel, as well as the appropriate sales tax. 

The distribution channel describes how most fixtures pass from the fixture OEM to the 

end-user. The fixture OEM sells a fixture to an electrical wholesaler (distributor), after which it 

passes to a contractor, and finally to the end-user. 
ES-7

 Figure ES.2.1 Metal Halide Lamp Fixture Distribution Channel

 DOE developed separate markups for baseline equipment and for the cost increase 

associated with improvements required to produce more efficient equipment. Table ES.2.6

summarizes the markups developed for metal halide lamp fixtures. 

Table ES.2.6 Markups for Fixtures

Markup Baseline Incremental

Wholesaler, Contractor 1.39 1.19

Sales Tax* 1.07 1.07 * Weighted national average.

 See chapter 2 and chapter 7 of the preliminary TSD for details. 

ES.2.7 Life-Cycle Cost and Payback Period Analyses 

An energy conservation standard usually results in an increase in purchase price and a 

decrease in operating expenses. DOE analyzes the net effect of amended standards on consumers 

by evaluating the net LCC using the cost-efficiency relationship derived in the engineering 

analysis, as well as the energy costs derived from the energy use characterization analysis. 

New standards typically increase the installed cost of equipment and decrease operating 

cost. Therefore, there is a point when the equipment has higher-than-baseline efficiency while

the net operating-cost benefit (in dollars) since the time of purchase is equal to the incremental 

first cost of purchasing the higher efficiency equipment. The length of time required for 

equipment to reach this cost-equivalence point is known as the payback period (PBP). 

 Inputs to the LCC calculation include the installed cost to the consumer, operating 

expenses, lifetime of the equipment, and a discount rate. Chapter 2 of this preliminary TSD 

summarizes the LCC and PBP analyses; chapter 8 provides a detailed description of these 

analyses and the results. Table ES.2.7 presents the key findings. 

OEM FIXTURE 

MANUFACTURER

ELECTRICAL WHOLESALER

CONTRACTOR

END-USER OF LIGHTING SYSTEM
ES-8

Table ES.2.7 Life-Cycle Cost and Payback Period Results for Metal Halide Lamp Fixtures

Representative 

Equipment Class

Purchasing Event CSL LCC

$ 

LCC 

Savings

$

PBP*

yrs

70 W Fixture Fixture Installation Baseline 2131.13

1 2107.65 23.47 0.60

2 2220.76 -89.64 N/A

3 2239.10 -107.97 N/A

250 W Fixture Fixture Installation Baseline 3476.447

1 3453.01 23.44 4.04

2 3457.38 19.07 7.35

3 3748.36 -271.91 N/A

4 3728.47 -252.03 N/A

400 W Fixture Fixture Installation Baseline 4392.67

1 4376.90 15.77 8.00

2 4358.68 33.99 7.04

3 4705.44 -312.76 N/A

4 4758.23 -365.56 N/A

1000 W Fixture Fixture Installation Baseline 9586.17

1 9569.16 17.01 6.57

2 9538.11 48.06 4.33

* Negative PBP values indicate standards that reduce operating costs and installed costs. Entries of “N/A” indicate 

standards that do not reduce operating costs.

ES.2.8 Shipments Analysis 

Shipment forecasts are needed to calculate the national impacts of amended standards on 

energy use, the net present value (NPV) of consumer costs and savings, and future manufacturer 

cash flows for each representative equipment class under consideration. DOE followed a threestep process to forecast metal halide lamp fixture shipments. First, DOE correlated historical 

shipments of metal halide lamp shipment data provided by the National Electrical Manufacturers 

Association (NEMA) and fixture shipments from the U.S. Census Bureau to estimate the total 

historical shipments of fixtures. Second, DOE calculated an installed stock for each fixture type 

based on individual average service lifetime. Third, DOE developed annual shipping projections 

by modeling purchasing events for ballast replacement and fixture replacement and applying 

estimated growth and replacement rates. 

 Chapter 2 and chapter 9 of the preliminary TSD provide additional detail on the 

shipments analysis. 

Figure ES.2.2 through Figure ES.2.5 present the base case shipments forecasts from 

2015–2044 for the metal halide lamp fixture equipment classes under consideration, modeled 

from the 2009 installed stock based on 1990–2008 historical shipments. DOE assumed that 

consumers would not voluntarily purchase some of the “larger” CSLs because incremental costs 

for efficiency gains are not economically justified at those levels. Thus, CSL3, CSL3/4, and 

CSL2 in the 70W, 250W/400W, and 1000W fixture classes are assumed to have no shipments in 

the base case shipments scenario.
ES-9

Figure ES.2.2 Base-Case Forecasted Shipments for 70 W Metal Halide Lamp Fixtures 

Figure ES.2.3 Base-Case Forecasted Shipments for 250 W Metal Halide Lamp Fixtures 

Figure ES.2.4 Base-Case Forecasted Shipments for 400 W Metal Halide Lamp Fixtures 
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Figure ES.2.5 Base-Case Forecasted Shipments for 1000 W Metal Halide Lamp Fixtures

ES.2.9 National Impact Analysis 

The national impact analysis (NIA) estimates the following national impacts from 

possible candidate standard levels: (1) national energy savings (NES), (2) monetary value of the 

energy savings due to standards, (3) increased total installed costs of the considered equipment 

due to standards, and (4) the net present value (NPV) of energy savings (difference between 

value of energy savings and increased total installed costs). DOE prepared a spreadsheet model 
ES-11

to forecast energy savings and national consumer economic costs and savings resulting from new 

standards. Chapter 2 of the preliminary TSD summarizes the methodology for the NIA; TSD 

chapter 10 provides additional detail on the analysis. 

ES.2.9.1 National Energy Savings Analysis 

DOE calculated annual NES as the difference between national energy usage in the base 

case (without amended energy conservation standards) and in each higher efficiency standard 

case. DOE estimated energy consumption and savings based on site energy and converted the 

electricity consumption and savings to source energy in units of quadrillion British Thermal 

Units (quads). The cumulative energy savings are the sum of the annual NES over the time 

period of the analysis (2015–2044). 

Table ES.2.8 shows the cumulative NES results under the “shift” scenario, which reflects 

the upper bound of energy savings, and the “roll-up” scenario, which reflects the lower bound. 

Energy savings for individual equipment classes illustrate the approximate relative energy 

savings of each fixture type under a CSL. Because more consumers move to fixtures with higher 

ballast efficiencies in the shift scenario than in the roll-up scenario, the shift scenario results in 

greater energy savings.

When an equipment class does not have fixtures at a selected CSL, the energy savings 

from the next-lowest CSL where the equipment class does have fixtures is used. For example, in 

the 70W equipment class, since there are only 3 CSLs, the NES value from CSL3 is also used for 

CSL4.
ES-12

Table ES.2.8 Cumulative National Energy Savings for Metal Halide Lamp Fixtures (2015–

2044) 

CSL Equipment Class National Energy Savings

quads

Shift Scenario Roll-up Scenario

1 70 W Fixture 0.059 0.052

250 W Fixture 0.211 0.209

400 W Fixture 0.273 0.269

1000 W Fixture 0.123 0.119

TOTAL 0.666 0.648

2 70 W Fixture 0.207 0.206

250 W Fixture 0.293 0.290

400 W Fixture 0.495 0.490

1000 W Fixture 0.241 0.241

TOTAL 1.236 1.226

3 70 W Fixture 0.223 0.223

250 W Fixture 0.430 0.429

400 W Fixture 0.622 0.618

1000 W Fixture 0.241 0.241

TOTAL 1.516 1.512

70 W Fixture 0.223 0.223

4 250 W Fixture 0.457 0.457

400 W Fixture 0.768 0.768

1000 W Fixture 0.241 0.241

TOTAL 1.689 1.689

ES.2.9.2 Net Present Value Analysis

DOE calculated NPV as the difference between total savings in operating costs and 

increases in total installed costs in the base case and standards case. DOE calculated savings over 

the life of the equipment using discount rates of 7 and 3 percent to discount future costs and 

savings to the present. 

Table ES.2.9 shows the total cumulative NPV results and NPV values for individual 

equipment classes under the shift and roll-up scenarios. An NPV greater than zero shows that the 

CSL would reduce customer expenditures relative to the base case in present value terms. An 

NPV less than zero indicates that the CSL would result in a net increase in customer 

expenditures in present value terms.

In similar fashion to Table ES.2.8, when an equipment class does not have fixtures at a 

selected CSL, the net present value from the next-lowest CSL where the equipment class does 

have fixtures is used. 
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Table ES.2.9 Cumulative Net Present Value Results for Metal Halide Lamp Fixtures

(2015–2044) 

CSL Equipment Class Net Present Value

billion 2010$ 

Shift Scenario Roll-up Scenario

7 Percent 

Discount Rate

3 Percent 

Discount Rate

7 Percent 

Discount Rate

3 Percent 

Discount Rate

1 70 W Fixture 0.098 0.212 0.122 0.261

250 W Fixture 0.216 0.534 0.258 0.623

400 W Fixture 0.087 0.321 0.134 0.421

1000 W Fixture 0.090 0.249 0.084 0.233

TOTAL 0.492 1.316 0.598 1.583

2 70 W Fixture -0.475 -0.959 -0.469 -0.946

250 W Fixture 0.094 0.338 0.172 0.507

400 W Fixture 0.213 0.684 0.320 0.911

1000 W Fixture 0.271 0.675 0.271 0.675

TOTAL 0.102 0.738 0.295 1.148

3 70 W Fixture -0.583 -1.157 -0.583 -1.157

250 W Fixture -3.436 -7.007 -3.442 -7.019

400 W Fixture -4.043 -8.126 -4.026 -8.092

1000 W Fixture 0.271 0.675 0.271 0.675

TOTAL -7.791 -15.615 -7.780 -15.594

4 70 W Fixture -0.583 -1.157 -0.583 -1.157

250 W Fixture -3.178 -6.485 -3.178 -6.485

400 W Fixture -4.772 -9.493 -4.772 -9.493

1000 W Fixture 0.271 0.675 0.271 0.675

TOTAL -8.262 -16.460 -8.262 -16.460

ES.2.10 Preliminary Manufacturer Impact Analysis

A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of 

energy conservation standards on manufacturers, including effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs. Potential impacts 

might lead to changes in manufacturing practices for metal halide lamp fixtures. DOE identified 

potential impacts through interviews with manufacturers and other interested parties. 

 

 During preliminary interviews, manufacturers identified seven major areas of concern: 

(1) system approach, (2) absence of American National Standards Institute (ANSI) standards for 

electronic ballasts , (3) testing burden, (4) technology shift, (5) impacts on profitability, (6) 

conversion costs, and (7) product innovation. See chapter 12 of the preliminary TSD for details.

ES.2.11 Other Analyses

The remaining chapters of the preliminary TSD address the following analyses, which will be 

performed for the notice of proposed rulemaking (NOPR): 

• The life-cycle cost analysis for subgroups evaluates the effects of energy conservation 

standards on various national subgroups (chapter 11). 
ES-14

• The utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 13).

• The employment impact analysis examines the effects of energy conservation standards 

on national employment (chapter 14). 

• The environmental assessment examines the effects of energy conservation standards on 

various airborne emissions. 

• The regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards. 

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is interested in receiving comment on all aspects of this preliminary analysis. DOE 

especially invites comment or data to improve DOE’s analysis, including information that will 

respond to the following questions and concerns that were raised in response to the framework 

document and in preparation of the preliminary TSD. 

ES.3.1 Test Procedure – ANSI C82.6

Manufacturers have suggested using the updated version ANSI C82.6 for the metal halide 

lamp ballast test procedure (currently under revision). DOE requests comment on expected 

changes to ANSI C82.6 and the status of the revised version of the document. DOE also seeks 

comment on any other appropriate changes to the existing test procedure for metal halide lamp 

ballasts.

ES.3.2 Test Procedure – Input Voltage 

Market research and information provided by manufacturers show that the vast majority 

of available metal halide lamp ballasts in the market can operate at multiple voltages. DOE is 

planning an amendment that would require multiple input voltage ballasts be tested at each input 

voltage. The reported efficiency value would be equal to the average of the tested efficiency at 

each input voltage. This amendment could more accurately assess the performance of the ballast 

in practice as ballasts are frequently operated at input voltages other than the highest possible. 

DOE requests comment on this planned amendment to the test procedure. 

ES.3.3 Standby Mode Energy Consumption

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

devices, which could consume energy in standby mode. One example of this ballast design is a 

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

circuitry remains on and active even when the ballast is not driving any lamps. However, through 

research and testing, DOE has yet to encounter such a ballast that it could purchase. DOE 

tentatively concluded that it cannot establish a separate standard that incorporates standby mode 
ES-15

energy use. DOE invites comments on the issue of standby mode and ballast designs that 

incorporate it. 

ES.3.4 Scope of Coverage 

 In chapter 2, DOE considers extending the scope of energy conservation standards to the 

following list of metal halide lamp fixtures:

(1) all metal halide lamp fixtures that operate lamps rated to greater than or equal to 50 

W and less than 150 W; 

(2) all metal halide lamp fixtures that operate lamps rated higher than 500 W; and

(3) 150-W-only fixtures rated for wet location use and containing a ballast rated to 

operate in ambient air temperature higher than 50 °C. 

DOE is considering exempting the following metal halide lamp fixtures:

(1) fixtures that use regulated lag ballasts; and

(2) fixtures that use electronic ballasts that operate at 480 volts. 

 DOE invites comment on its rationale for extending coverage and also its proposed scope 

of energy conservation standards, including exemptions. 

ES.3.5 Lamp-ballast System Approach 

In a lamp-ballast system approach, fixture would be rated based on the efficacy of the 

lamp and ballast combination. A table of standard lamps would allow fixture manufacturers that 

do not include lamps with the fixture to indicate compliance with standards. This approach could 

be more acceptable to the fixture industry as shipping fixtures with lamps would not be a 

requirement. DOE invites comment on: 

(1) the specific values that could be included in a table of standard lamps, 

(2) examples of systems that could benefit from this approach, 

(3) the manufacturer impacts and feasibility of a lamp-ballast system standard in addition 

to a lamp-specific standard that could result from the ongoing HID lamps rulemaking, 

and

(4) the potential for a standards complaint fixture to be relamped with a different lamp 

that reduces system efficacy after the first lamp failure and the impact on energy savings. 

ES.3.6 California Title 20 System Approach 

California Title 20 outlines a system approach in which either a highly efficiency ballast 

should be sold in a fixture, or a less efficient ballast in combination with occupancy sensors, 

dimming, or reduced wattage lamps should be used. DOE may consider a federal design standard 

similar to California’s Title 20 and requests comments on the feasibility of this action and the 

expected consumer preferences for occupancy sensors, dimming, or reduced wattage lamp 
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pairings. DOE also seeks comment on the expected change in lumen output and initial efficacy 

when moving from regular to reduced wattage versions of lamps. 

ES.3.7 Fixture-level System Approach

Based on information gathered through research and discussions with fixture 

manufacturers, DOE believes that the alternative proposed metrics, TER and FTE, are not 

appropriate for amending metal halide lamp fixture standards. Therefore, DOE preliminarily 

determined to evaluate amending energy conservation standards for metal halide lamp fixtures 

by amending performance requirements for ballasts included in covered fixtures and by using 

ballast efficiency as the relevant metric. DOE requests comments on its decision not to use TER 

and FTE as metrics used to calculate metal halide lamp fixture minimum performance 

requirements. 

ES.3.8 Technology Options 

DOE identified several technology options to improve the efficiency of a metal halide 

lamp fixture. DOE invites comment on these options, discussed in preliminary TSD chapter 3. 

Specifically, DOE requests information on the feasibility, performance improvement, and cost of 

the technology options, as well as any recent developments in their technical maturity.

ES.3.9 Technology Options – Electronic vs. Magnetic Ballasts 

DOE understands that electronic ballasts can offer benefits over magnetic ballasts, 

sometimes including efficiency, but that electronic ballasts are less tolerant of high heat buildup, 

which can limit their placement in fixtures. DOE requests comment on thermal issues 

surrounding electronic ballasts and on how to appropriately model heat buildup in a fixture. DOE 

is also aware that electronic metal halide ballasts have lower tolerances of voltage transients than 

magnetic ballasts do. DOE requests comment on typical applications in which transients over 

6kV are a particular concern. Additionally, DOE requests comment on specific sources of 

reliability concerns (relative to magnetic ballasts) for electronic ballasts.

ES.3.10 Dimming

DOE understands that metal halide lamps are often dimmed using bi-level capacitors in 

conjunction with relays, motion sensors, or photocells. DOE requests comment on the cost of 

employing these methods to save energy. 

ES.3.11 Equipment Classes

 DOE considered seven potential class-setting factors: (1) wattage, (2) voltage, (3) number 

of lamps per ballast, (4) starting method, (5) electronic configuration, (6) circuit type, and (7) 

fixture application. Using the statutory criteria (i.e., type of energy consumed, capacity, or other 

performance-related features affecting efficiency) (42 U.S.C. 6295(q)), DOE eliminated all but 

one and defined equipment classes based on wattage. This class-setting factor created four
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equipment classes, summarized in Table ES.2.1. DOE seeks comment on these equipment 

classes. 

ES.3.12 Equipment Classes – Input Voltage 

 Input voltage, in particular the ability to operate at 480 V may have an effect on ballast 

efficiency. DOE requests comment on whether, why, and to what degree quad-input-voltage, 

quint-input-voltage, and dedicated 480 V ballasts have different characteristic efficiencies. DOE 

further requests comment on whether it would be appropriate to establish a separate equipment 

classes for ballasts operating above 300 V and, if so, why quint-input-voltage ballasts belong in 

one class or the other. 

ES.3.13 Equipment Classes – Number of Lamps

While a majority of available ballasts only operate one lamp, a limited number are 

designed for two lamps. The limited catalog information available shows little to no change in 

efficiency between a one-lamp and two-lamp metal halide ballast. Therefore, DOE preliminarily 

decided not to set equipment classes based on number of lamps. DOE seeks further comment 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.

ES.3.14 Equipment Classes – Electronic Configuration and Circuit Type

Because electronic ballasts can provide the utility included in any magnetic circuit type, 

can be used as substitutes in all applications, and are generally more efficient than magnetic 

ballasts, DOE is not setting separate equipment classes based on electronic configuration 

(magnetic vs. electronic) or on circuit type. DOE seeks comment on electronic configuration and 

circuit types and the need for additional separation of metal halide lamp fixture equipment 

classes by this feature.

ES.3.15 Equipment Classes – Fixture Application 

DOE’s research has tentatively determined that the same efficiencies can be achieved in 

all applications (including outdoor and indoor) by the same or similar products. DOE also found 

that electronic ballasts have been successfully applied to a variety of both indoor and outdoor 

applications where temperature and other limiting conditions could hinder their implementation. 

DOE also believes defining product types and applications for equipment classes is difficult and 

subjective. DOE seeks comment on the different applications for metal halide lamp fixtures and 

the need for additional separation of equipment classes by this feature. 

ES.3.16 Screening Analysis

 DOE determined that none of the technology options identified should be screened out. 

DOE requests comment on whether interested parties agree that amorphous steel and electrical 

components more efficient than those currently incorporated into metal halide ballasts are 

technologically feasible and practicable to manufacture technology options. In addition, DOE 
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requests comment on the anticipated incremental costs and efficiency improvements from 

implementing these options.

ES.3.17 Representative Wattages and Fixtures

DOE requests comment on its selection of representative wattages and fixtures for each 

equipment class.

ES.3.18 Candidate Standard Levels 

DOE tested the ballast efficiency of many manufacturers’ equipment offerings. DOE

identified the most prevalent ballast efficiency values in the range of available equipment and

established CSLs based on those fixtures. DOE requests comment on the CSLs identified in the 

preliminary analysis. 

ES.3.19 CSLs – Proprietary Designs

 DOE does not regard a standard level that can be met by only one proprietary design to 

be economically justified. DOE believes that no CSL in this rulemaking requires the use of a 

proprietary technology. DOE requests comment on this conclusion. 

ES.3.20 CSLs – Wattage Bins vs. Equation-based Approach 

 DOE has preliminarily chosen to set standards using bins for all equipment classes, but 

requests comment on whether any particular wattage bin would require the use of an equation to 

accurately represent the relationship between wattage and efficiency.

ES.3.21 CSLs – High Frequency Electronic Ballast

DOE uses a high frequency electronic ballast as a representative unit for CSL4 in the 

>250 W and ≤500 W class. DOE requests comment on the appropriateness of using high 

frequency electronic ballasts as representative units, particularly with respect to lamp and ballast 

compatibility concerns.

ES.3.22 Probe-Start Lumen Maintenance

DOE is aware manufacturers market pulse-start lamps and ballasts as holding several 

advantages over their probe-start counterparts, chiefly among them better lumen maintenance 

over the life of the lamp. DOE is considering normalizing input power across starting methods to 

reflect the fact that a consumer could replace less-efficacious fixtures of a given wattage with 

either (1) fewer more-efficacious fixtures of that same wattage or (2) the same number of moreefficacious fixtures of reduced wattage. DOE requests comment on typical mean lumen 

differences between pulse-start and probe-start lamps operating at 70, 250, 400, and 1000 W. 

DOE also requests comment on setting a design standard that prohibits probe-start ballasts in 

new fixtures, if differences in lumen maintenance and efficacy suggest doing so would save 

significant energy. 
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ES.3.23 Maximum Technological Feasibility

 Within a given equipment class, no working equipment or prototypes appear to exist that 

have a distinguishably higher ballast efficiency than commercially available fixtures. Therefore, 

the highest CSL presented, which represents the most efficient tier of commercially available 

fixtures, is the “max-tech” level that DOE determined for this preliminary rulemaking. DOE 

requests comment on whether the efficiency of magnetic and electronic ballasts can be increased 

beyond that commercially available, and the associated costs and design pathways required. 

DOE also requests specific comment on whether 1000 W electronic metal halide ballasts are 

technologically feasible and the potential for this technology to emerge in the future. 

ES.3.24 Manufacturer Production Costs

To estimate MPCs for metal halide lamp fixtures, DOE conducted a teardown analysis 

for many high-volume fixtures and ballasts. Given the large number of available fixtures and 

ballasts and the fact that DOE was unable to tear down certain ballasts due to physical 

restrictions (potting), DOE used scaling techniques to estimate the MPC for those fixtures and 

ballasts that it did not tear down. DOE then calculated MSPs by applying manufacturer markups. 

DOE requests comment on its estimates of manufacturer production costs, as well as DOE’s 

estimates for the manufacturer markup. 

ES.3.25 Normalized Input Power

 Input power values were normalized by dividing rated lamp wattage by efficiency, 

instead of using tested input wattage values directly. DOE requests comment on the use of 

normalized input power in its analysis. 

ES.3.26 Cumulative and Future Regulation 

 DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or 

amended DOE standards and other regulatory actions affecting the same equipment. DOE will 

analyze and consider the impact on manufacturers of multiple, product-specific regulatory 

actions in the NOPR. DOE invites comment on regulations applicable to ballast and fixture 

manufacturers that contribute to their cumulative regulatory burden. 

ES.3.27 Operating Profiles for Energy Use Characterization

To characterize the country’s average use of metal halide lamp fixtures for a typical year, 

DOE developed annual operating hours by sector using data published in the U.S. Lighting 

Market Characterization: Volume I, the Commercial Building Energy Consumption Survey, and 

the Manufacturer Energy Consumption Survey. DOE assumed that all fixture equipment classes

analyzed (Table ES.2.1) could be used in the three evaluated sectors (i.e., commercial, industrial, 

and outdoor stationary), and applied average annual operating hours based on each sector (Table 

ES.2.4). DOE welcomes comment on the basis and assignment of these end-use operating 

profiles for the ballast types covered under this rulemaking. See chapter 2 of the preliminary 

TSD for details.
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ES.3.28 Lighting Controls and Fixture Operating Profiles 

 DOE is considering the use of occupancy-based and daylight-based dimming controls as 

an efficiency level for metal halide lamp fixtures, but so far could not find comprehensive data 

relating ballast efficiency to light output. DOE invites comment on this issue, as well as details 

on the use of lighting controls for metal halide lamp fixtures in the commercial, industrial, and 

outdoor sectors. See chapter 2 of the preliminary TSD for details.

ES.3.29 Price Markups

 In the framework document, DOE solicited comment on typical metal halide lamp fixture 

pricing and distributor and contractor markups. Unable to obtain any detailed pricing or markup 

data for the preliminary analyses, DOE developed wholesaler markups using financial data from 

U.S. Securities and Exchange Commission form 10-K reports for publicly-owned companies. 

DOE seeks comment on typical markups, as well as metal halide lamp fixture pricing data that it

could use to verify the price markups it developed for the preliminary analysis. See chapter 2 of 

the preliminary TSD for details.

ES.3.30 Average Equipment Lifetimes and Failure Distributions

 For the LCC/PBP analyses and shipment projections, DOE assumed metal halide lamp 

fixture lifetimes of 20 years for interior fixtures and 25 years for exterior fixtures. DOE assumed 

lifetimes for metal halide ballasts of 30,000 hours for electronic designs and 50,000 hours for 

magnetic designs. DOE also used median rated lifetimes for lamps. These average values suggest 

that a majority of failures occur later in the service lifetime. DOE seeks comment on its assumed 

lifetimes for fixtures, ballasts, and lamps, and how they may vary within the representative 

equipment classes, as well as the distribution of failures around the average values. In particular, 

DOE seeks comment on how many years beyond their average lifetimes that equipment can 

remain in service. See chapter 2 of the preliminary TSD for details.

ES.3.31 Historical Shipments Data

 For this rulemaking, DOE used publicly available HID lamp fixture shipments from the 

U.S. Census from 1993–2001, lamp shipment data from the 2010 HID Lamps Determination, 

confidential NEMA lamp shipment data (2002–2008), and market trend information from 

manufacturers to develop historical shipment data for metal halide lamp fixtures from 1990–

2008. DOE requests comment on this approach, as well as actual fixture shipment data to 

validate its methodology. See chapter 2 of the preliminary TSD for details.

ES.3.32 Shipment Trends

DOE modeled metal halide lamp fixture purchasing events (e.g., replacement and new 

construction) and applied growth rate, and replacement rate assumptions to develop annual 

shipment projections. DOE based future metal halide lamp fixture shipments on shipments of 

metal halide lamps from the 2010 HID Lamps Determination; DOE assumes that these trends 

integrate various regulatory and non-regulatory initiatives in the lighting marketplace. DOE
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requests comment on the magnitude and timing of its forecasted metal halide lamp fixture 

shipment trends (e.g., rising and declining shipments, plateaus, etc.) as well as the effects of 

current regulatory initiatives on future metal halide lamp fixture shipments. See chapter 2 of the 

preliminary TSD for details.

ES.3.33 LCC Subgroups

Some groups might be adversely affected by the amended energy conservation standards 

for metal halide lamp fixtures. DOE will consider the subgroups: medium to high-end retail, 

grocery, big-box retail, schools, community centers, sport facilities including clubs, industrial, 

warehousing, various types of facilities with outdoor area lighting, and owners of streets and 

roadways (e.g., property owners, municipalities, and state and federal departments of 

transportation). DOE welcomes additional suggestions for its LCC subgroup analysis. See 

chapter 2 of the preliminary TSD for details.

ES.3.34 Trial Standard Levels

 For the NOPR, DOE will develop trial standard levels (TSLs) based on the candidate 

standard levels for metal halide lamp fixtures. DOE is considering several criteria in developing 

the TSLs, including, but not limited to, combinations of efficiency levels, minimum LCC, 

maximum NPV, and maximum technologically-feasible efficiency. From the list of TSLs 

developed, DOE will select one as its proposed standard for the NOPR. DOE invites comment 

on the criteria it should use as the basis for selection of TSLs. 

ES.3.35 Impact on Manufacturers

 DOE requests comment on its identification of key issues and requests data and 

information from interested parties that can assist in evaluating the potential impact on 

manufacturers.

ES.3.36 Valuing Airborne Emission Reductions

DOE will conduct an environmental assessment as part of the NOPR, which will be the 

next phase of the standards rulemaking. The primary environmental effect of energy 

conservation standards for metal halide lamp fixtures is to reduce power plant emissions 

resulting from reduced consumption of electricity. DOE will assess this environmental effect by 

using the National Energy Modeling System – Building Technologies (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). DOE also plans on monetizing the emission reductions due to standards consistent 

with methods used in recent DOE standards rulemakings pertaining to commercial clothes 

washers and other consumer products and commercial equipment. For example, in the case of 

CO2, the most recent interagency estimates of the potential global benefits resulting from 

reduced CO2 emissions in 2010 were $4.9, $22.1, $36.3, and $67.1 per metric ton in 2009$. DOE 

invites comment on the approaches for monetizing the emission savings due to energy 

conservation standards. 
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