ES -i EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVIT IES

......................................... 1

ES.2 KEY RESULTS OF THE A NALYSIS

.............................................................................. 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 Ele ctronic 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 ................................................................. 19ES

- ii 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 ......................................................... 21ES

- 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 Ha lide 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

........ 10ES

- 1 EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMIN ARY ANALYSIS ACTIVIT IES

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. Th is 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 preli minary 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 publ ic

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 pre liminary analyses. Arrows connecting analyses show the types of information that feed from one analysis to another.ES

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

ProcessES

- 3 ES.2 KEY RESULTS OF THE A NALYSIS

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 th e 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 ty pe 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 Fixture s 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 equip ment
characteristics and retail markets. This informatio n provides data and resource material throughout the analysis.

DOE reviews literature and interview s 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.ES

- 4 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 technol ogies 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 span ned a range of efficiency levels. DOE then developed a cost model that convert ed 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 Candid ate 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 d esigned 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 -b allast 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 e very equipment class that DOE consider s in this rulemaking.ES

- 6 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 developi ng 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 fro m 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.

S ee chapter 2 and chapter 7 of the preliminary TSD for detail s.

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 analyze s 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 ha s higher- than

- baseline efficiency w hile the net operating -cost benefit (in dollar s) 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 SYSTEMES

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

Representative Equipment Cl ass 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 shipm ents 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 model ing purchasing events for ballast replacement and fixture replacement and applying

estimated growth and replacement rate s.

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 hist orical 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 1000 W 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 FixturesES

- 10 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 modelES

- 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 c umulative energy savings are the sum of the annual NES over the time period of the analysis (2015–2044).

T able 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 (20 15– 2044)

CSL Equipment Class N ational E ner gy S avings 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.ES

- 13 Table ES.2.9 Cumulative N et P resent Value Results for Metal Halide Lamp Fixtures (20 15–2044)

CSL Equipment Class N et 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 int erviews 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 bal lasts , (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 anal ysis 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 environmenta l 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 SE EKS 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 ballast s in the market can operate at multiple voltages. DOE is planning an amendment that would require multiple input volt age 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 cont rol 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 conclude d that it cannot establish a separate standard that incorporates standby modeES

- 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 operat e 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 tempe rature 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 aft er 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 lampES

- 16 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 altern ative 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 req uirements 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 particu lar 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 feature s affecting efficiency) (42 U.S.C. 6295(q)) , DOE eliminated all but

one and define d equipment classes based on wattage

. Th i s class

- setting factor created fourES

- 17 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-voltag e, 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 meta l 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 circu it 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 commen t 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 a nd 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, DOEES

- 18 requests comment on the anticipated incremental costs an d 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 effi ciency of many manufacturers’ equipment offerings. DOE

identif ied 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 equatio n 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 maintenanc e 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 more

efficacious 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 significa nt energy.ES

- 19 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 ballast s can be increase d 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 cost s , as well as DOE’s

estimate s 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 o ther 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 dat a 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.ES

- 20 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 chap ter 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 prel iminary 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 tha t 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 rat ed 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 cl asses , 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 S hipments 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 D etermination

, 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. DOEES

- 21 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 sh ipments. 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,

groce ry, 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 Im pact 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 Air b orne Emission Reductions

DOE will co nduct 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 f rom reduced consumption of electricity. DOE will assess th is 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 (CO 2 ), sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), and mercury (Hg). DOE also plans on monetizing the emission reductions due to standards consistent with methods used in recent DOE standards rulemakings perta ining to commercial clothes washers and other consumer products and commercial equipment. For example, in the case of

CO 2 , the most recent interagency estimates of the potential global benefits resulting from

reduced CO 2 em issions 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.ES

- 22