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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM......................................................................................................... 1-1

1.3 OVERVIEW OF METAL HALIDE LAMP FIXTURES STANDARDS ...................... 1-2

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-4

1.5 STRUCTURE OF THE DOCUMENT............................................................................ 1-7

LIST OF TABLES

Table 1.4.1 Analyses Under the Process Rule ............................................................................ 1-5
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This preliminary technical support document (TSD) provides the analytical approaches, 

inputs and results associated with the U.S. Department of Energy’s (DOE’s) study of energy 

conservation standards for metal halide lamp fixtures. The preliminary TSD also serves to 

provide technical detail and is a compendium to the life-cycle cost (LCC) and payback period 

(PBP) and national impact analysis (NIA) spreadsheets that are posted on the DOE’s website for 

the preliminary analysis.a

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM

Part B of Title III of the Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 

6291–6309) established the energy conservation program for consumer products other than 

automobiles, covering major household appliances. Additional amendments to EPCA have given 

the U.S. Department of Energy the authority to regulate the energy efficiency of several 

products, including metal halide lamp fixtures, the products that are the focus of this document. 

Before DOE determines whether to adopt a proposed energy conservation standard, it 

first solicits comments on the proposed standard. DOE designs any new or amended standard to 

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

economically justified. (42 U.S.C. 6295(o)(2)(A)) To determine whether economic justification 

exists, DOE must review comments on the proposal and determine that the benefits of the 

proposed standard exceed its burdens to the greatest extent practicable, weighing the following 

seven factors: 

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

products subject to the standard; 

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

compared to any increases in the price, initial charges, or maintenance expenses for 

the products that are likely to result from the imposition of the standard; 

(3) the total projected amount of energy savings likely to result directly from 

imposition of the standard; 

(4) any lessening of the utility or the performance of the products likely to result from 

imposition of the standard; 

 

a The preliminary analysis can be found here: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_fixtures.html
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(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard; 

(6) the need for national energy conservation; and 

(7) other factors the Secretary considers relevant. 

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

1.3 OVERVIEW OF METAL HALIDE LAMP FIXTURES STANDARDS

The following summarizes the pertinent legislative and regulatory history for metal 

halide lamp fixtures (MHLFs). DOE is conducting its first rulemaking cycle to review and 

consider amendments to the energy conservation standards in effect for metal halide lamp 

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

(2) Final rule by January 1, 2012. —

(A)In general. —

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

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

(B) Administration. —

The final rule shall—

(i) contain any amended standard; and

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

On December 19, 2007, the President signed the Energy Independence and Security Act 

of 2007 (EISA 2007) which made numerous amendments to EPCA and directed DOE to 

undertake several new rulemakings for appliance energy conservation standards. (Pub. L. 110-

140) The MHLF provisions, section 324 of EISA 2007, amended EPCA by:

• inserting definitions pertaining to “metal halide ballast,”b “metal halide lamp,”c and 

“metal halide lamp fixtures”d (among others) into section 321 of EPCA (42 U.S.C. 

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

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

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

Standard C82.6-2005, Ballasts for High-Intensity Discharge (HID) Lamps-Methods of 

Measurement (42 U.S.C. 6293(b)(18));

 

b “Metal halide ballast” means “a ballast used to start and operate metal halide lamps.” (42 U.S.C. 6291(62)) c “Metal halide lamp” means “a high intensity discharge lamp in which the major portion of the light is produced by 

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

U.S.C. 6291(63))

d “Metal halide lamp fixture” means “a light fixture for general lighting application designed to be operated with a 

metal halide lamp and a ballast for a metal halide lamp.” (42 U.S.C. 6291(64))
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• amending section 324(a)(2) of EPCA by directing the Federal Trade Commission (FTC) 

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

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

• amending section 325 of EPCA by prescribing energy conservation standards for metal 

halide lamp fixtures, requiring that they contain ballasts that meet or exceed defined 

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

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

publish a final rule no later than January 1, 2012 to determine whether the energy 

conservation standards established by EISA 2007 for metal halide lamp fixtures should 

be amended. If such amendments to the standards are appropriate under the relevant 

statutory criteria, the final rule shall apply to products manufactured on or after January 

1, 2015. (42 U.S.C. 6295(hh)(2)(B)) The Secretary is further directed to conduct a second 

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

fixtures then in effect, which requires publication of a final rule by January 1, 2019. (42 

U.S.C. 6295(hh)(3))

The following statutory provisions are directly relevant to the energy conservation 

standards rulemaking for metal halide lamp fixtures. As amended by EISA 2007, EPCA 

regulates metal halide lamp fixtures designed to be operated with lamps rated greater than or 

equal to 150 watts (W), but less than or equal to 500 W by prescribing performance requirements 

for the MH lamp ballasts used in those metal halide lamp fixtures. Both MH lamps and ballasts 

are energy-using components of metal halide lamp fixtures. For this MH lamp wattage range, 

metal halide lamp fixtures must contain the following:

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

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

(iii)a nonpulse-start electronic ballast with—

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

and

(II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 250 

watts.

(U.S.C. 6295 (hh)(1)(A))

In addition to prescribing minimum efficiency requirements for the previously described 

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

exclude the following types of MH lamp fixtures from the statutorily prescribed energy 

conservation standards:

(i) fixtures with regulated lag ballasts;

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

(iii)fixtures that—

(I) are rated only for 150 watt lamps;

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

2002, section 410.4(A); and
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(III) contain a ballast that is rated to operate at ambient air temperatures above 50

degrees Celsius, as specified by Underwriters Laboratories (UL)1029–2001 

(“Standard for High-Intensity-Discharge Lamp Ballasts”).

(42 U.S.C. 6295 (hh)(1)(B))

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

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

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

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

the energy conservation standards analysis is applicable. 

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

halide lamp fixtures but are separate from the current standards rulemaking:

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

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

High Intensity Discharge (HID) lamps (including MH lamps) would be technologically 

feasible and economically justified, and would result in significant energy savings. (42 

U.S.C. 6317(a)(1)) DOE completed the HID determination and published a final rule (75 

FR 67975) on July 1, 2010 concluding that energy conservation standards for certain HID 

lamps are technologically feasible and economically justified.

• DOE completed a test procedure rulemaking for MH lamp ballasts, as required by EPCA 

through amendments from EISA 2007. (42 U.S.C. 6293(b)(18)) The final rule test 

procedure for MH lamp ballasts was published in the Federal Register on March 10, 

2010. 75 FR 10950.

• The FTC is directed to conduct a labeling rulemaking as part of the requirements set forth 

by EISA 2007 for metal halide lamp fixtures.(42 U.S.C. 6294(a)(2)(C)) To this end, the 

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

part 305, “Rule Concerning Disclosures Regarding Energy Consumption and Water Use 

of Certain Home Appliances and Other Products Required Under the Energy Policy and 

Conservation Act (‘Appliance Labeling Rule’).” 73 FR 39221. On October 23, 2008, the 

FTC published in the Federal Register additional amendments to 16 CFR part 305 for 

metal halide lamp fixtures in the form of technical corrections. 73 FR 63066. Both final 

rules fulfilled the FTC’s obligations under EISA 2007 pertaining to labeling requirements 

for metal halide lamp fixtures and MH lamp ballasts.

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS

DOE considers stakeholder participation a very important part of the standards-setting 

process. DOE encourages the participation of all stakeholders during the comment period of each 

rulemaking stage. Beginning with the rulemaking framework document for metal halide lamp 

fixtures (the framework document) and during subsequent comment periods, interactions among 

stakeholders provide a balanced discussion of the information that is required for the standards 

rulemaking.

In conducting the energy conservation standard rulemaking, DOE involves stakeholders 

through formal public notifications (i.e., Federal Register notices). For this MHLF energy 
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conservation standards rulemaking, DOE will employ the procedures set forth in DOE’s Process 

Rule (Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products, 61 FR 36974, July 15, 1996, 10 CFR Part 430, Subpart C, Appendix A) to 

the extent they are appropriate for developing energy conservation standards for the metal halide 

lamp fixtures covered under this rulemaking.

Before DOE determines whether to establish or amend energy conservation standards for 

metal halide lamp fixtures, it must first solicit comments on a proposed standard. (42 U.S.C. 

6295(o)(2)(B)(i)). DOE must design each new or amended standard for these products to achieve 

the maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in significant energy savings. (42 U.S.C. 6295(o)(2)(A) 

and (3)) To determine whether a proposed standard complies with these requirements, DOE 

must, after receiving comments on the proposed standard, determine whether the benefits of the 

standard exceed its burdens to the greatest extent practicable, weighing the seven factors 

described above.

Subsequent to the publication of the framework document, the standards rulemaking 

process involves preliminary analyses followed by two additional formal, major public notices, 

which are published in the Federal Register. The preliminary analyses are designed to publicly 

vet the models and tools used in the rulemaking and to facilitate public participation before the 

proposed rule stage. After the preliminary analyses are vetted, DOE issues the first major notice, 

the notice of proposed rulemaking (NOPR), which presents a discussion of comments received in 

response to the preliminary analyses of the impacts of standards on consumers, manufacturers, 

and the nation; DOE’s weighing of the impacts; and the proposed standards. The third notice is 

the final rule, which presents a discussion of comments received in response to the NOPR; the 

revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards 

adopted by DOE; and the effective dates of the standards.

Table 1.4.1 Analyses Under the Process Rule

Preliminary Analysis NOPR Final Rule*

Market and technology assessment Revised ANOPR analyses Revised analyses

Screening analysis Life-cycle cost sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use characterization Utility impact analysis

Product price determination Employment impact analysis

Life-cycle cost and payback period analyses Environmental assessment

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice concerning 

the impact of any lessening of competition that is likely to result from the imposition of the standard. (42 U.S.C. 

6295(o)(2)(B)(v))

In December 2009, DOE published a rulemaking framework document for metal halide 

lamp fixtures, which describes the procedural and analytical approaches DOE anticipated using 

to evaluate the establishment of energy conservation standards for metal halide lamp fixtures. A 
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PDF copy of the framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/mh_ecs_framewor

k.pdf

DOE held a public meeting on January 26, 2010 (hereafter “public meeting”), to discuss 

procedural and analytical approaches to the rulemaking, and to inform and facilitate 

stakeholders’ involvement in the rulemaking process. The analytical framework presented at the 

public meeting described rulemaking analyses, such as the engineering analysis and the LCC and 

PBP analyses, the methods proposed for conducting them, and the relationships among the 

various analyses. See Table 1.4.1 for all the analyses discussed at the public meeting to be 

undertaken in each of the formal public rulemaking documents. PDF copies of the slides and 

other material associated with the public meeting are available at 

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

ework_pub_mtg.html

During the public meeting and the framework document comment period, interested 

parties, including manufacturers, trade associations, environmental advocates, and other 

interested parties submitted several comments about the MHLF rulemaking. The major issues 

discussed were: (1) the rulemaking’s scope of coverage; (2) the development of equipment

classes; (3) test procedures; (4) a system approach and ballast efficiency metric; (5) the 

methodology for the engineering analyses; (6) life-cycle cost analysis; (7) efficiency levels; and

(8) energy savings. Interested part comments submitted during the framework document

comment period elaborated upon the issues raised at the public meeting. A detailed discussion of 

stakeholder comments is available in chapter 2 of this preliminary TSD.

As part of the information gathering and sharing process, DOE organized and held 

interviews with metal halide lamp ballast manufacturers and fixture manufacturers who operate 

in the U.S. MHLF market. DOE had five objectives for these interviews: (1) solicit feedback on 

the scope of coverage for the rulemaking; (2) solicit feedback on the engineering analysis 

(including methodology, prices, and ballast technologies); (3) solicit feedback on topics related 

to the preliminary manufacturer impact analysis; (4) provide an opportunity early in the 

rulemaking process to express specific concerns to DOE; and (5) foster cooperation between 

manufacturers and DOE. During the manufacturer interviews, DOE discussed these and other

issues regarding market data, distribution channels, anticipated consumer responses to standards, 

production and product mix, conversion costs, and cumulative regulatory burden. Appendix 12A 

contains a complete copy of the interview guide.

DOE incorporated the information gathered at the meetings into its engineering analysis 

(chapter 5) and the preliminary manufacturer impact analysis (chapter 12). Following the 

publication of the preliminary analysis, DOE intends to hold additional meetings with 

manufacturers as part of the consultative process for the manufacturer impact analysis conducted 

during the NOPR phase.

For the LCC, PBP and national impact analyses (NIA), DOE developed spreadsheets 

using Microsoft Excel®. The LCC and PBP spreadsheets calculate the economic impacts of 

replacing products with standard-compliant ones. The NIA spreadsheets calculate the national 

energy savings (NES) and national net present values (NPVs) at various energy efficiency levels
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and include a model that forecasts the impacts of energy conservation standards at various levels 

on product shipments. These spreadsheets are available on the DOE website at

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

ures.html

1.5 STRUCTURE OF THE DOCUMENT

This preliminary TSD outlines the analytical approaches used in this rulemaking. The 

TSD consists of 14 chapters, two reports, and appendices.

Chapter 1 Introduction: provides an overview of the appliance standards 

program and how it applies to the rulemaking for metal halide lamp 

fixtures, and outlines the structure of the document

Chapter 2 Analytical Framework: describes the rulemaking process, provides an 

overview of each analysis, and discusses comments received during 

the framework document public meeting comment period.

Chapter 3 Market and Technology Assessment: characterizes the MHLF market 

and the technologies available for increasing ballast efficiency and 

outlines product classes

Chapter 4 Screening Analysis: determines which technology design options are 

viable for consideration in the engineering analysis

Chapter 5 Engineering Analysis: describes DOE’s approach to the engineering 

analysis and discusses how manufacturer costs and selling prices relate 

to ballast efficiency

Chapter 6 Energy Use Characterization: discusses the sources and methods for 

developing energy use estimates for metal halide lamp fixtures

Chapter 7 Markups Analysis: discusses the methods DOE used for establishing 

markups from manufacturer selling price to installed customer prices.

Chapter 8 LCC and PBP Analyses: discusses the economic effects of standards 

and compares the LCC and PBP of metal halide lamp fixtures with and 

without higher energy conservation standards

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards

Chapter 10 National Impact Analysis: describes the national forecast of energy 

consumption, efficiency of new metal halide lamp fixtures, and annual 

MHLF sales in the absence or presence of new standards
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Chapter 11 Life-Cycle Cost Sub-Group Analysis: discusses the methods to be 

used to study the effects of standards on a subgroup of MHLF 

consumers and compares the LCC and PBP of product with and 

without higher efficiency standards for these consumers

Chapter 12 Manufacturer Impact Analysis: discusses the methods to be used to 

study the effects of standards on the finances and profitability of metal 

halide lamp fixtures, and presents preliminary manufacturer impact 

analysis results

Chapter 13 Utility Impact Analysis: discusses the methods to be used to study the 

effects of standards on electric utilities

Chapter 14 Employment Impact Analysis: discusses the methods to be used to 

analyze the effects of standards on national employment

Chapter 15 Environmental Assessment for metal halide lamp fixtures: discusses 

the methods to be used to study the effects of standards on two 

pollutants, sulfur dioxide (SO2) and nitrogen oxides (NOx), as well as 

carbon emissions

Chapter 16 Regulatory Impact Analysis for metal halide lamp fixtures: discusses 

the methods to be used to determine the impact of non-regulatory 

alternatives to energy conservation standards

Appendix 3A U.S. Code and Code of Federal Regulations

Appendix 5A Test Data for metal halide lamp fixtures: lists the test data used for 

the MHLF engineering analysis

Appendix 8A User Instructions for Life-Cycle Cost and Payback Period 

Spreadsheet

Appendix 10A User Instructions for Shipments and NIA Spreadsheet

Appendix 12A Preliminary Manufacturer Interview Guide

Appendix EA-SCC Social Cost of Carbon for Regulatory Impact Analysis Under 

Executive Order 12866