Roadway

Energy Efficienc

Email: metal_halide_la

Energy Conservation Standards Notice of 

Rulemaking for Metal Halide Lam

High‐Bay Magnetic Ballast Downli

Sports Light

Low‐Bay

Wall‐Pack Floodlight Post‐Top 

Canopy 
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.– Say your name for the record – there will be a complete transcrip

meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar conversa

– Webinar participants turn phone on mute; ‘raise your hand’ to be 

to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Agenda

9:00 – 9:10 am Welcome, Introductions, Opening Statements

9:10 – 10:00 am Overview, Scope, Market and Technology Assessm

Analysis

10:00 – 11:00 am Engineering Analysis11:00 – 11:15 am Break11:15 – 11:45 am Energy Use, Markup Analysis, Life‐Cycle Cost and P

Analysis

11:45 am – 12:15 pm Shipments, National Impact Analysis12:15 – 1:15 pm Lunch1:15 – 1:45 pm Manufacturer Impact Analysis

1:45 – 2:15 pm LCC Subgroup Analysis , Employment Impact Anal

Analysis and Monetization of Emissions, Regulator

2:15 – 2:45 pm Proposed Standard

2:45 – 3:00 pm Closing Remarks
4

Listening Via the Webcast• The Department is broadcasting this meeting live ove

Internet.

• DOE is providing the webcast to accommodate stakeh

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
5

Purpose of the Public Meeting

• Purpose

‐ To invite comment on proposed energy conservation standard lev

‐ To present methodologies and characterize results of the rulema

‐ To discuss specific issues related to each analysis;

‐ To seek input from interested parties on methodologies, assumpt

sources, and results from the analyses; and

‐ To describe next steps in the rulemaking.

• Comments from Participants

‐ Participants are invited to provide summary comments or statem

additional issues for discussion.
6

Issues for DiscussionIssue box numbering corresponds to the list of issues include

NOPR notice, available at:

http://www.regulations.gov/#!docketDetail;D=EERE‐2009‐BT‐STD‐0018The deadline for submitting comments is October 21, 2013.

Issue Box: DOE welcomes comments, data, and informatio

concerning the standards it is considering for MHLF. Issues

that correspond to those raised in DOE’s published materia

will be numbered in accordance with that material. Wheth

invited by an issue box or not, comments are welcome on a

part of DOE’s analysis.
7

How to Submit Written Comments

• In all correspondence, please refer to the MHLF rulemaking by

– Metal Halide Lamp Fixtures Energy Conservation Standard R

– Docket Number EERE‐2009‐BT‐STD‐0018, and

– Regulatory Identification Number (RIN) 1904‐AC00.

• Email: MHLF‐2009‐STD‐0018@ee.doe.gov

• Comment period closes: October 21, 2013, 11:59 PM EDT

Postal: Courier:

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program, Mailstop EE‐2J

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energ

Building Technologies Pro950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945
8

Opening Remarks

Meeting participants are invited to provide opening remark

statements at this time.
9

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
10

Metal Halide Lamp Fixture Rulemaking Schedu

Milestone 

Framework Document 

Notice of Public Meeting and Availability of the Preliminary

Technical Support Document 

Notice of Proposed Rulemaking (NOPR) 

Final Rule (projected) 

2009 2010 2011 2012 2013 2014 
11

EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors w

energy conservation standards:

EPCA Factors DOE Analysi

1. Economic impact on customers and

manufacturers

Life‐Cycle Cost An

Manufacturer Impact 

2. Lifetime operating cost savings compared

to increased cost for the product Life‐Cycle Cost An

3. Total projected energy savings National Impact An

4. Impact on utility or performance Engineering Ana

Screening Analy

5. Impact of any lessening of competition Manufacturer Impact 

6. Need for national energy conservation National Impact An7. Other factors the Secretary considers

relevant

Environmental Asse

Utility Impact Ana

Employment Impact 
12

• Metal halide lamp fixture (MHLF) means a light fixture for a gene

application designed to be operated with a metal halide lamp an

• EISA 2007 prescribed the current energy conservation standards 

halide lamp fixtures sold on or after January 1, 2009. (42 U.S.C. 6

Current Standards

Ballast Type Operated Lamp Rated Wattage Range Minimum 

Pulse‐start 150 and 500 W 

Magnetic Probe‐start 150 and 500 W 

Nonpulse‐start Electronic 150 and 250 W 

Nonpulse‐start Electronic >250 and 500 W 

• Excludes from the standards fixtures:

– With regulated‐lag ballasts;

– With electronic ballasts that operate at 480 volts; and

– That are rated only for 150 W lamps, rated for use in wet locations, 

a ballast that is rated to operate at temperatures above 50 °C.
13

• DOE considered additional metal halide lamp fixtures for cover

authority of 42 U.S.C. 6295(hh)(2)(A).

• This NOPR proposes to maintain the exemptions from EISA for 

– With regulated‐lag ballasts; and

– With electronic ballasts that operate at 480 volts.

• This NOPR proposes to expand coverage to include fixtures:

– That are designed to operate ballasts rated from 50 W to 2000 W

– That are rated only for 150 W lamps, rated for use in wet location

ballast that is rated to operate at temperatures above 50°C.

Scope of Coverage: Criteria

Issue 2: DOE seeks comment on the exclusion of dedicated 

V electronic ballasts in the scope of this rulemaking.

Issue 1: DOE seeks comment on the appropriateness of

continuing the exemption of regulated‐lag ballasts.
14

System Approach

DOE considered three system approaches as alternatives to regulat

ballast efficiency:• Lamp and ballast system approach

― Could be burdensome due to compatibility and compliance issues

― Could require utilities to keep larger stock; and

― Once original lamp fails, lamps could be replaced with lower effica

• Whole fixture systems approach

― Has potential to save more energy, but current metrics are inadeq

assessing the fixtures included in this rulemaking.

• California Title 20 approach

― Risks reducing energy savings and complicating compliance and en

and

― Requiring dimming or controls does not ensure energy savings an

functionality is not widely available for metal halide technology.
15

Test Procedure

Proposed Changes to Test Procedure

• Specify input voltage at which to test based

on ballast wattage;

• Specify the instrumentation required to

test high‐frequency electronic ballasts; and

• Record and round input and output wattage

to the nearest tenth of a watt, and calculate

efficiency to the nearest tenth of a percent.

Issue 8: DOE seeks comment on the appropriateness of DO

testing metal halide lamp fixtures at a single input voltage,

based on the lamp wattage operated by the ballast.

Issue 7: DOE seeks comment on the appropriateness of the

proposed amendments to the test procedure, especially th

specification of input voltage, high‐frequency test

instrumentation, and rounding requirements.

Ballast Wattage 

<150 W ≥150 W 

When designated

voltage based on

wattage is unavailable
16

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses;
17

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
18

Equipment Classes: Criteria• DOE establishes separate energy conservation standards for ea

equipment class.

• DOE divides covered equipment into classes by:

– the type of energy used;

– the capacity of the equipment; and

– Any other performance‐related features that require differ

standard levels, such as features affecting consumer utility.
19

Equipment Classes: Input Voltage• DOE proposes separate equipment classes for ballasts tested a

and ballasts tested at all other voltages in accordance with the 

procedures.

• Impact on Efficiency

– Dedicated 480 V ballasts (tested at 480 V) are less efficient than q

voltage ballasts tested at the most common voltages (120 V or 27

• Consumer Utility

– Input voltage represents a feature affecting consumer utility as ce

applications demand specific input voltages.

Issue 13: DOE seeks comment on the appropriateness of

separate equipment classes for ballasts tested at 480 V (in

accordance with the test procedure).
20

Equipment Classes: Application• DOE proposes separate equipment classes for indoor and outd

fixtures.

• Effect on Cost‐Efficiency Relationship

– While the efficiency potential is the same for indoor and outdoor 

added protection required for outdoor fixtures adds an incremen

the fixture.

– These incremental costs affect the cost‐efficiency relationship of f

outdoor applications.

• Consumer Utility

– Currently there is a market reluctance to use electronic metal hal

in outdoor applications, particularly due to concerns with the ele

ballast’s ability to withstand voltage transients and more extreme

temperatures.

– It is technologically feasible to address the transient concerns wit

external surge protection device or internal transient protection o

ballast, and the temperature concerns with thermal management 

the fixture.
21

Equipment Classes: Indoor/Outdoor Definition• DOE proposes that outdoor fixtures be defined as those that:

– are rated for use in wet locations; and

– have 10 kV of voltage transient protection.

• Fixtures that do not meet these requirements will be defined as 

fixtures.

Wet Locations: DOE proposes to define the wet location rating as 

by the National Electrical Code 2011, section 410.10(A) or Under

Laboratories (UL) 1598 Wet Location Listed.

10 kV Voltage Transient Protection: DOE proposes to use the 10 k

pulse withstand requirement from ANSI C136.2‐2004 as a charac

unique to outdoor fixtures.

Issue 9: DOE seeks comment on the appropriateness of pl

indoor and outdoor fixtures into separate equipment class
22

Equipment Classes: Power‐Efficiency Relations• In general, as lamp wattage increases, ballast efficiency increas

• DOE empirically developed relationships between ballast effici

the rated lamp wattage.

• Using an equation has the benefit over the binned approach (c

efficiency standard across each wattage range) used in the pre

analysis because it allows for fair treatment of all wattages wit

equipment class.

Lamp Wattage

Power‐EfficiencyRelationship

~

Ballast Efficiency
23

Equipment Classes: Lamp Wattage• DOE proposes to establish separate equipment classes for met

fixtures by wattage ranges.

• Impact on Efficiency

– Overall, ballast efficiency increases with wattage.

– EISA 2007 required ballasts from 150 to 500 W to be 88% efficien

market adjusted to these numbers and disrupted the expected tr

• Consumer Utility

– Certain applications require more light than others, so wattage o

by application and thus directly affects consumer utility.

• DOE proposes to separate equipment classes by wattage range

for different equations to be used for each wattage range, as op

one single equation spanning all wattages, because:

– Wattage/efficiency relationships can differ significantly by wattag

– Different wattages often serve separate applications and have un

efficiency relationships.
24

Equipment Classes

*150 W fixtures previously exempted by EISA 2007 be included in the >100 W and the 

ranges, while 150 W fixtures subject to EISA 2007 standards continue to be included in 

W range.

Issue 16: DOE seeks comment on the appropriateness of 

equipment classes proposed in this NOPR.

Rated Lamp Wattage Tested at 480 V All Othe

≥50 W and ≤100 W Indoor Outdoor Indoor O

>100 W and ≤150 W* Indoor Outdoor Indoor O

>150 W* and ≤250 W Indoor Outdoor Indoor O

>250 W and ≤500 W Indoor Outdoor Indoor O

>500 and ≤2000 W Indoor Outdoor Indoor O
25

Screening Analysis

Ballast Type Design Options

Magnetic

Improved Core Steel

Copper Wiring

Increased Stack Height

Increased Conductor Cross‐Sectio

Electronic Ballast

Electronic Improved Components

Mag

Di

Cap

Tran

Improved Circuit Design Integrat

Issue 18: DOE seeks comment on the appropriateness of 

design options selected by the screening analysis in this N

• DOE screened out amorphous steel, and the remaining technolog

were then designated as design options.
26

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
27

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
28

Engineering Analysis: Methodology

Determine

Representative

Equipment Classes

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis



Choose representative equipment classes to strea

and analysis based primarily on their high market v

Define characteristics of baseline models in each eclass which will serve as reference points to assess 

to energy conservation standards.

Identify more efficacious substitutes for each base

based on design options.

Develop efficiency levels (ELs) that span the range 

from the baseline to the maximum technologically 

efficiency for that class.

Generate manufacturer production costs (MPCs) f

fixtures, and then apply derived markups to calculmanufacturer selling prices (MSPs).

Scale results to equipment classes not analyzed. Scale To Classes

Not Analyzed


29

Representative Equipment Classes

• Due to their low shipment volume, DOE doe

directly analyze the equipment classes cont

fixtures with ballasts tested at 480 V.

• The above 10 equipment classes are the rep

equipment classes analyzed.

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes Rated Lamp Wattage Not Tested at 

≥50 W and ≤100 W Indoor 

>100 W and <150 W Indoor ≥150 W and ≤250 W Indoor >250 W and ≤500 W Indoor 

>500 and ≤2000 W Indoor 
30

Baseline Units

• DOE first selects representative wattages, w

typically the most common wattage within 

equipment class.

• The baseline model typically represents the 

common, least efficient model for each rep

wattage.

• When applicable, the baseline model just m

existing energy conservation standards.

• The baseline serves as a reference point fro

DOE measures impacts due to potential am

energy conservation standards.

• In some cases, DOE selects more than one 

a representative wattage to ensure conside

different customer economics.

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes
31

Baseline Units

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Wattage Range Rep. Wattage

Baseline B

Ballast Type

≥50 W and ≤100 W 70 W

Magnetic Pulse‐star

Electronic Pulse‐star

>100 W and <150 W 150 W Magnetic Pulse‐star

≥150 W and ≤250 W 250 W Magnetic Pulse‐star

>250 W and ≤500 W 400 W Magnetic Pulse‐star

>500 and ≤2000 W 1000 W Magnetic Probe‐star

Issue 22: DOE seeks comment on the addition 

electronic 70 W baseline ballast.

Determine

Representative

Equipment Classes
32

More Efficient Units

• DOE selects metal halide lamp fixtures with hig

efficiency ballasts as replacements for each ba

model in each representative equipment class

• These higher efficiencies are identified by:

– Examining test data to select commercially ava

ballasts to represent higher efficiency levels; o

– Filling in large gaps of efficiency present in tes

as between commercially available magnetic a

electronic ballasts) through estimating efficien

increases due to the use of the design options

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes
33

Efficiency Levels

• DOE develops ELs based on:

– the design options associated with the equip

studied; and

– the maximum technologically feasible (max‐t

available for that class.

• DOE’s efficiency levels are based on catalog d

independent test data collected from comme

available equipment, and manufacturer inpu

• DOE plotted ballast efficiency versus rated la

for both standard‐ and high‐efficiency produc

multiple manufacturers.

– After regression analysis, DOE found several 

that best modeled the observed trend betwe

wattage and ballast efficiency.

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes
34

Proposed Energy Conservation Standard Equat

a) (Power‐law equation) Minimum Ballast Efficiency = ஼భ ሺଵା஼మ∗௉಴b) (Linear equation) Minimum Ballast Efficiency = ܥଵ ∗ܲ൅ܥଶc) (Constant equation) Minimum Ballast Efficiency = ܥ

where P is the rated lamp power, and C represents coefficients deter

that vary based on equipment class

0.7

0.75

0.8

0.85

0.9

0.95

1

0 200 400 600 800 1000

Ballast Efficiency

Lamp Rated Wattage

Example Equation Types

a) eqb) eqc) eq
35

Efficiency Levels: Graph 50 W to 500 W

65.0%70.0%75.0%80.0%85.0%90.0%95.0%

100.0%

50 100 150 200 250 300 350 400 450 500

Ballast Efficiency

Lamp Rated Wattage
36

Efficiency Levels: Graph 500 W to 2000 W

90.0%90.5%91.0%91.5%92.0%92.5%93.0%93.5%94.0%

500 600 700 800 900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1

Ballast Efficiency

Lamp Rated Wattage

Issue 24: DOE seeks comment on the appropriateness the efficiency levels proposed in this NOPR and wheth

not an adjustment is needed for sources of variation n

currently captured by this methodology.
37

Ballast Efficiency Levels

Representative Wattages

70 W 150 W 250 W 400 W 

Baseline Commercially available magnetic

Com

EL1

Commercially

available

magnetic

Modeled

magnetic

Commercially

available

magnetic

Modeled

magnetic

EL2 Modeled magnetic– max tech magnetic

Com

ma

EL3 Commercially available low‐frequency electronicEL4 Commercially available low‐frequency electronic—max tech

Comm. avail.

high‐frequencyelectronic – maxtech

* A design standard banning probe‐start ballasts in new fixtures is considered in the N
38

Input Power Representations• DOE found that as metal halide lamps age, they require higher 

• While electronic ballasts have the capability to sense that the l

has increased and then decrease the output current in order to 

constant wattage throughout the lamp life, the wattage of mag

increases up to 11% over lamp life.

• To accurately reflect the energy use of fixtures, DOE assumed t

magnetic ballasts’ 11% wattage increase occurs in a linear fash

life of the ballast. This was modeled by multiplying the rated la

by 1.055 when calculating input power normalized to rated lam

all magnetic ballasts.

Issue 21: DOE seeks comment on the analysis method of apply

percent increase when calculating the representative input pow

magnetic ballasts to account for the increase in wattage over a 

lifetime.
39

Design Standard

• DOE is permitted to set both design and performance standards for 

U.S.C. 6295(hh)(4)

• Pulse‐start metal halide lamps have increased lumen maintenance 

higher efficacies than probe‐start lamps. Because of EISA requireme

start ballasts are only currently available for new fixtures from 500 

• A review of catalogs indicates that 1000 W pulse‐start MH lamps ha

greater mean lumen output than 1000 W probe‐start MH lamps. Be

minimal ballast efficiency differences for probe‐ and pulse‐start bal

in mean lumens must be achieved through a design standard.

• This NOPR therefore considers both performance‐based efficiency 

and a design standard that bans probe‐start ballasts in new fixtures 

wattages.

Issue 26: DOE seeks comment on the determination to include a 

standard that would prohibit the sale of probe‐start ballasts in ne

fixtures, the proposed methods of analyzing these levels, and the 

for loss of utility through prohibition of the sale of probe‐start ba

sold fixtures.
40

Price Analysis

• DOE developed prices using:

– Teardown data;– Retail prices from online distributors; and

– Aggregated manufacturer‐supplied prices.

• Adjustments from the preliminary analysis 

– Adjusting material prices to better reflect cur

trends based on manufacturer input and com

pricing;

– Adding incremental costs to fixtures utilizing 

ballasts based on application characteristics; 

– Modifying the application of manufacturer m

align better with existing fixture componentmanufacturing channels.

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes
41

Price Analysis: Incremental Fixture Costs

• Indoor and outdoor fixtures can achieve the same ballast efficienc

• However, electronically ballasted fixtures have different MPCs dep

whether they are intended for use indoors or outdoors.

150175200225250275300325350

86 88 90 92 

Total Fixture MSP ($)

Ballast Efficiency (%

400 W Indoor vs. Outdoor C

Magnetic ballasts Elec

Electronic Ballast Cost

Adders

Indoor Outdoor

Thermal

Management

20% fixture

MPC increase

20% fixture

MPC increase

Voltage

Transient

Protection

‐‐

$18.99 fixture

MPC increase

120 V

Auxiliary

Power

Functionality

$0.75 ballast

MPC increase

‐‐
42

Price Analysis

Issue 28: DOE seeks comment on the appropriateness of t

derived MSPs presented in this NOPR.

Issue 27: DOE seeks comment on the applicability and

appropriateness of the adder to MPC of electronic ballasts 

120 V auxiliary power functionality and the adders to the 

of fixtures with electronic ballasts for thermal managemen

and transient protection.
43

Scaling to Equipment Classes Not Analyzed

Issue 25: DOE seeks comment on the proposa

scaling factor of 0.6 percent to the efficiency l

quad‐volt ballasts to determine the appropria

480 V ballasts.

• DOE did not analyze 480 V input voltage balla

thus making it necessary to develop a scaling 

for this input voltage.

• DOE compared quad‐voltage ballasts to their 

counterparts using catalog data over all repre

wattages at various efficiencies.

• The average reduction to ballast efficiency fou

was 0.6%, thus DOE proposes applying this sca

to the efficiency levels for the quad‐volt ballas

determine appropriate values for the 480 V ba

Select Baseline

Units

Select More

Efficient Units

Determine

Efficiency Levels

Conduct Price

Analysis

Scale To Classes

Not Analyzed

Determine

Representative

Equipment Classes
44

Trial Standard Levels (TSL)

TSLs Considered in the NOPR

TSL 5 Maximum technologically feasible efficiency levels

TSL 4 Maximum energy savings with positive NPVTSL 3 Maximum energy savings with maximum positive NPV – sa

levels for indoor and outdoor equipment classes

TSL 2 Maximum technologically feasible magnetic ballast EL for e

class

TSL 1 EL1 for equipment classes with positive NPV
45

EL/TSL Mapping

Low FrequencyElectronic

Modeled Magnetic Commercially‐ Available Magnetic

TSL 1 TSL 2 TSL 3 TSL 4 

≥50 to ≤100 W

indoor EL1 EL2 EL2 EL2 

outdoor EL1 EL2 EL2 EL3 

>100 to <150 W

indoor EL1 EL2 EL4 EL4 

outdoor EL1 EL2 EL4 EL4 

≥150 to ≤250 W

indoor EL1 EL2 EL2 EL2 

outdoor EL1 EL2 EL2 EL2 

>250 to ≤500 W

indoor EL1 EL2 EL2 EL2 

outdoor EL1 EL2 EL2 EL2 

>500 to ≤2000 W

indoor EL1+DS† EL2+DS EL2+DS EL2+DS 

outdoor EL1+DS EL2+DS EL2+DS EL2+DS 

† DS is a design standard that bans the use of probe-start ballasts in new MHLF.

Issue 39: DOE seeks comment on the appropriateness of

proposed trial standard levels.
46

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
47

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
48

Energy Use Analysis

Equipment

Class

Annual Energy Use (kWh)*

Baseline EL1 EL2 EL3 

70 W 441 / 461 414 / 433 396 / 414 342 / 357 

150 W 879 / 878 848 / 846 824 / 822 733 / 732 

250 W 1,349 / 1,347 1,319 / 1,317 1,298 / 1,295 1,205 / 1,20

400 W 2,159 / 2,154 2,111 / 2,107 2,076 / 2,072 1,938 / 1,93

1000 W 7,025 / 5,163 6,582 / 4,837 6,539 / 4,806

*Values are given as Indoor / Outdoor

• Annual energy use is calculated by multiplying annua

operating hours by per‐unit energy consumption.
49

Markups Analysis• Indoor fixtures all pass through distribution channel 

• Outdoor fixture markups calculated as a weighted av

distribution channels A, B, and C.

Distribution

Channel

[Outdoor]

Percentage

Baseline

Markup

Incremental

Markup

A 60% 1.39 1.19

B 20% 1.13 1.13

C 20% 1.00 1.00
50

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
51

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
52

LCC‐PBP Analysis Results – TSL 3

Equipment

Class Location Efficiency Level LCC Savings ($) Net Cost (%) Net Ben

(%) 

70W

Indoor 2 38.41 0 100 

Outdoor 2 46.44 0 100 

150 W

Indoor 4 10.14 23 77 

Outdoor 4 112.51 26 74 

250 W

Indoor 2 13.12 31 69 

Outdoor 2 13.75 15 85 

400 W

Indoor 2 28.23 18 82 

Outdoor 2 30.47 7 93 

1000 W

Indoor 2 + DS* 502.21 0 100 

Outdoor 2 + DS* 409.02 0 100 

• LCC savings are positive for all equipment classes, an

majority of customers experience net benefits from 

proposed standard.

* DS denotes design standard
53

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
54

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
55

Shipments Analysis Results• DOE updated shipments based on interested party c

and revised inputs.

• Shipments decline over the analysis period.

0

1,000,0002,000,0003,000,0004,000,0005,000,0006,000,0007,000,0008,000,0009,000,000

10,000,000

2010 2015 2020 2025 2030 2035 2040 2045

Metal Halide Lamp Fixture Shipments

Year

Historic and Future Shipment Projections

PreliminaryAnalysisShipmentsHighLow

 ‐

100,000200,000300,000400,000500,000600,000700,000800,000900,000

2015 2020 2025 2030 2035 2040 2045

Annual Shipments

Year

70 Watt Base‐Case Shipments

Indoor‐LowIndoor‐HighOutdoor‐LowOutdoor‐High
56

National Impact Analysis

• NES increases, then decreases due to other technolog

fluorescent, etc.) being installed instead of MHLF.

• Similar to NES, NPV increases over time, then levels o

decreases due to diminishing shipments and discount

0.0000.0050.0100.0150.0200.0250.0300.035

2015 2020 2025 2030 2035 2040 2045

Annual Quads

Annual FFC Energy Savings (quads)
57

Public Meeting Slides Topics

1 Overview; Scope; Test Procedures;2 Market & Technology; Screening;3 Engineering;4 Energy Use; Markups Analysis;5 Life‐Cycle Cost & Payback Period Analysis;6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses
58

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis NOPR Final Rule

Market &Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use

Analysis

ShipmentsAnalysis

MarkupsAnalysis

Life‐CycleCost andPaybackPeriod Analysis

ManufacturerImpactAnalysis
59

MIA Overview• Purpose

‐ To assess the impacts of standards on manufacturers;

‐ To identify and estimate impacts on manufacturer sub‐group

may be more severely affected than the industry as a whole

‐ To examine the direct employment impacts, manufacturing c

and the cumulative regulatory impact on the industry.

• Methodology

‐ Analyze industry cash flow and industry net present value (IN

through use of the Government Regulatory Impact Model (G

‐ Interview manufacturers to refine inputs to the GRIM, devel

group analyses, and address qualitative issues.
60

MIA Methodology

• Phase 1

‐ DOE creates an industry profile to characterize the market an

important issues that require further investigation.

• Phase 2

‐ DOE prepares an industry cash‐flow model and an interview

questionnaire to guide subsequent discussions with manufac

• Phase 3

‐ DOE interviews manufacturers and assesses the impacts of st

both quantitatively (using the GRIM) and qualitatively (impa

competition, manufacturing capacity, employment, and regu

burden).

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews& industrywide / subgroupanalyses

Assess direct employment, competition, cumulative burdens

Phase 1 Phase 2 Phase 3
61

MIA Key Issues• Ability to Recoup Investments

‐ Higher standards could hasten the switch to SSL technologie

the amount of time MHLF manufacturers have to recoup the

investments required to comply with standards.

• Efficiency Metric Used

‐ A ballast only efficiency metric could overlook some opportu

energy savings from lamps, fixtures, or combined lamp and 

systems.

• Maintenance of 150 Watt Exemption

‐ Manufacturers believe DOE should maintain the exemption 

only fixtures because electronic ballasts are currently less re

outdoor locations and in wet environments.

‐ Regulating 150 W fixtures could cause consumers to revert b

175 W fixtures because of a significant price increase of the 

fixtures and negate any potential energy savings.
62

MIA Scenarios Analyzed• DOE modeled four different scenarios*

‐ Two shipment scenarios (low‐shipment & high‐shipment sce

‐ Two markup scenarios (flat markup & preservation of operat

markup scenario)

• Least severe for manufacturers – high‐shipment & fl

markup scenario

‐ Manufacturers fully pass through additional costs to their co

and there is a less severe decline in metal halide fixture ship

• Most severe for manufacturers – low‐shipment &

preservation of operating profit markup scenario

‐ Manufacturers maintain the same level of operating profits 

terms in the standards case as in the base case and the decl

metal halide fixture shipments is more severe.

*Each scenario DOE modeled uses one shipment scenario and one marku
63

MIA INPV Results (Ballast Manufacturers)• High‐Shipment & Flat Markup Scenario (Least Severe

• Low‐Shipment & Preservation of Operating Profit Ma

Scenario (Most Severe)

Units Base Case

TSL

1234

INPV (2012$ millions) 123 123 126 127 127 

Change in INPV

(2012$ millions) ‐ 0.8 3.3 4.5 4.7 

(%) ‐ 0.7% 2.7% 3.7% 3.8% 

Product Conversion Costs (2012$ millions) ‐ 9 12 13 14 Capital Conversion Costs (2012$ millions) ‐ 10 17 16 14 Total Conversion Costs (2012$ millions) ‐ 19 30 29 28 

Units Base Case

TSL

1234

INPV (2012$ millions) 103 86 77 77 79 

Change in INPV

(2012$ millions) ‐ (17.1) (26.8) (25.9) (24.8

(%) ‐ ‐16.6% ‐25.9% ‐25.0% ‐24.0

Product Conversion Costs (2012$ millions) ‐ 9 12 13 14 Capital Conversion Costs (2012$ millions) ‐ 10 17 16 14 Total Conversion Costs (2012$ millions) ‐ 19 30 29 28 
64

MIA INPV Results (Fixture Manufacturers)• High‐Shipment & Flat Markup Scenario (Least Severe

• Low‐Shipment & Preservation of Operating Profit Ma

Scenario (Most Severe)

Units Base Case

TSL

1234

INPV (2012$ millions) 630 667 694 695 703 

Change in INPV

(2012$ millions) ‐ 37.0 63.9 64.8 73.6 

(%) ‐ 5.9% 10.2% 10.3% 11.7% 

Product Conversion Costs (2012$ millions) ‐ 3 3 9 13 Capital Conversion Costs (2012$ millions) ‐ 0 0 6 10 Total Conversion Costs (2012$ millions) ‐ 3 3 15 23 

Units Base Case

TSL

1234

INPV (2012$ millions) 540 534 532 523 516 

Change in INPV

(2012$ millions) ‐ (6.1) (8.1) (17.3) (23.8

(%) ‐ ‐1.1% ‐1.5% ‐3.2% ‐4.4% 

Product Conversion Costs (2012$ millions) ‐ 3 3 9 13 Capital Conversion Costs (2012$ millions) ‐ 0 0 6 10 Total Conversion Costs (2012$ millions) ‐ 3 3 15 23 
65

MIA Small Business Impacts

• DOE identified five metal halide ballast small business

manufacturers.

‐ Three small businesses specialize in high‐efficiency electronic b

currently meet the standards proposed in the NOPR.

‐ Standards could cause the other two ballast manufacturers to 

the number of products offered or exit the MHLF market entir

• DOE identified 54 metal halide fixture small business

manufacturers.

‐ Approximately two‐thirds of these small businesses primarily s

architectural or specialty lighting market. Because these produ

command a higher price and margin, DOE believes these fixtu

manufacturers should be able to pass on any necessary conve

their customers.

‐ Standards could cause the remaining third of fixture manufact

reduce the number of products offered or exit the MHLF mark
66

MIA Issues for Comment

Issue 43: DOE requests comment on the potential impacts new and amended standards on the small metal halide bal

and metal halide lamp fixture manufacturers.
67

LCC Subgroup Analysis• DOE examined three subgroups for the LCC Subgrou

1. Utilities

– Maintenance costs 1.5 times those of the general p

2. Transportation Facility Owners

– Higher operating hours

3. Warehouse Owners

– Lower operating hours

• Results are consistent with the main LCC‐PBP analysi

– Results are robust with respect to variations in maintenanc

and the specified operating hours
68

Employment Analysis• DOE examined the effect of the proposed standard w

the general economy.

Analysis

Period Year TSL

Net National Change in Jobs (Jo

Low Shipments High Shipmen

2017

1 10 82 ‐30 ‐36

3 76 734 170 1685 352 346

2020

1 376 3922 511 5303 791 8274 1,091 1,1425 2,336 2,445
69

Emissions Analysis and Monetization of Emissi

TSL 3 Total Emissions Results

Emission Type Low Shipments Hig

Shipm

Carbon Dioxide/CO2 ‐ (Mt) 48.5 65

Nitrogen Oxides/NOX ‐ (kt) 65.6 89

Mercury/Hg ‐ (t) 0.1 0.

Nitrous Oxide/N2O ‐ (kt) 0.9 1.

Methane/CH4 ‐ (kt) 213.8 288

Sulfur Dioxide/SO2 ‐ (kt) 65.0 86

• Cumulative emissions reductions for equipment sold 

30 year analysis period. The benefits of carbon dioxi

nitrogen oxides (NOX) emissions are monetized using 

dollar per ton conversions.

– Ch. 17 of the NOPR TSD contains the monetized values for all TSLs

the approach for monetizing emissions.
70

Regulatory Impact Analysis• Regulatory Impact Analysis ‐ DOE analyzed 6 non‐reg

alternatives to a standard which include:

1. No New Regulatory Action

2. Customer Rebates

3. Customer Tax Credits

4. Manufacturer Tax Credits

5. Voluntary Energy Efficiency Programs

6. Bulk Government Purchases

— See Ch. 18 of the NOPR TSD for further details
71

Potential Updates for Final Rule• In addition to time‐dependent updates such as elect

prices and sales tax, there are four parameters DOE 

considering updating for the Final Rule.

1. Shipments

— Newly‐released NEMA data indicate HID lamp shipments are lo

currently modeled

— Translates to a slightly lower starting point for MHLF shipments

2. Outdoor Operating Hours

— Very small shift from total aggregate HID use to just MH lamp u

3. Labor Rates

— Use additional sources besides RSMeans (such as Sweets) when 

labor rates

— Minor change in some values – based on comment from HID ru

4. Discount Rates

— Small change restricting the scope of companies whose data is 

calculating discount rates
72

Proposed Energy Conservation Standards‐ TSL 

Rated Lamp Wattage Test Input Voltage Minimum Standard Equatio

(%)

≥50 W and ≤100 W 480 V 99.4/(1+2.5P^(‐0.55))†

≥50 W and ≤100 W All others 100/(1+2.5P^(‐0.55))

>100 W and <150 W* 480 V 99.4/(1+0.36P^(‐0.30))

>100 W and <150 W* All others 100/(1+0.36P^(‐0.30))

≥150 W* and ≤250 W 480 V For ≥150 W and ≤200 W: 88.0 For >200 W and ≤250 

≥150 W* and ≤250 W All others For ≥150 W and ≤200 W: 88.0 For >200 W and ≤250 

>250 W and ≤500 W 480 V 91.0

>250 W and ≤500 W All others 91.5

>500 W and ≤2000 W 480 V For >500 W to <1000 W: 0.994(3.210^(‐3)P + 89.9) For ≥1000 W to ≤200

utilize a pro

>500 W and ≤2000 W All others For >500 W to <1000 W: 3.210^(‐3)P + 89.9 For ≥1000 W to ≤200

utilize a pro

*150 W fixtures previously exempted by EISA 2007 are included in the >100 W and the 

ranges, while 150 W fixtures subject to EISA 2007 standards continue to be included in 

W range.

†P is defined as the rated wattage of the lamp that the fixture is designed to operate.
73

• Energy

– Cumulative energy savings 0.80 – 1.1 quadrillion FFC* Btus (qu

equipment purchased during the 30 year analysis period.

• Cost Savings

– Cumulative national net present value (NPV) = $0.95 billion (7

rate (DR)), $3.2 billion (3% DR).

– Estimated average life‐cycle cost savings are approximately $3

operating a 400 W metal halide lamp in indoor and outdoor a

• Environmental Benefit

– Energy saved in the form of electricity would result in cumulat

greenhouse gas emission reductions of 48.5‐65.0 Mt of CO2 fo

purchased during the 30 year analysis period.

– Estimated net present monetary value of the CO2 emissions re

between $0.33 and $4.7 billion.

Summary of Proposed Rule Impacts* FFC denotes full fuel cycle energy
74

Proposed Energy Conservation Standards‐ TSL 

Issue 42: DOE seeks comment on the appropriateness of

choosing TSL 3 energy conservation standards.
75

How to Submit Written Comments

• In all correspondence, please refer to the MHLF rulemaking by

– Metal Halide Lamp Fixtures Energy Conservation Standard R

– Docket Number EERE‐2009‐BT‐STD‐0018, and

– Regulatory Identification Number (RIN) 1904‐AC00.

• Email: MHLF‐2009‐STD‐0018@ee.doe.gov

• Comment period closes: October 21, 2013, 11:59 PM EDT

Postal: Courier:

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program, Mailstop EE‐2J

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energ

Building Technologies Pro950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945
76

Questions?