After a regulatory action has been completed, Executive Order 12866 requires agencies 

to identify the substantive changes between the draft submitted to Office of Information 

and Regulatory Affairs (OIRA) for review and the action subsequently announced, and to 

identify those changes made at the suggestion or recommendation of OIRA. The 

document below provides more information.
[6450-01-P] 

DEPARTMENT OF ENERGY

10 CFR Part 431 

[Docket Number EERE–2009–BT–STD–0018] 

RIN: 1904-AC00

Energy Conservation Program: Energy Conservation Standards for Metal Halide 

Lamp Fixtures 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Final rule. 

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended,

prescribes energy conservation standards for various consumer products and certain 

commercial and industrial equipment, including metal halide lamp fixtures (MHLFs). 

EPCA also requires the U.S. Department of Energy (DOE) to determine whether morestringent standards would be technologically feasible and economically justified, and 

would save a significant amount of energy. In this final rule, DOE is adopting morestringent energy conservation standards for MHLFs. It has determined that the new and 

amended energy conservation standards for this equipment would result in significant 

conservation of energy, and are technologically feasible and economically justified.

1 
DATES: The effective date of this rule is [INSERT DATE 60 DAYS AFTER DATE of 

PUBLICATION IN THE FEDERAL REGISTER]. Compliance with the new and 

amended standards established for MHLFs in today’s final rule is required by [INSERT 

DATE 3 YEARS AFTER DATE OF PUBLICATION IN THE FEDERAL 

REGISTER].

The incorporation by reference of certain publications listed in this rule is

approved by the Director of the Federal Register on [INSERT DATE 60 DAYS AFTER 

DATE OF PUBLICATION IN THE FEDERAL REGISTER].

ADDRESSES: The docket, which includes Federal Register notices, public meeting 

attendee lists and transcripts, comments, and other supporting documents/materials, is 

available for review at regulations.gov. All documents in the docket are listed in the 

regulations.gov index. However, some documents listed in the index, such as those 

containing information that is exempt from public disclosure, may not be publicly 

available.

A link to the docket webpage can be found at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16. 

The regulations.gov webpage will contain simple instructions on how to access all 

documents, including public comments, in the docket. 

For further information on how to review the docket, contact Ms. Brenda Edwards 

at (202) 586-2945 or by email: Brenda.Edwards@ee.doe.gov. 

2 
 

FOR FURTHER INFORMATION CONTACT:

Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, 

S.W., Washington, DC, 20585-0121. Telephone: (202) 287-1604. Email: 

metal_halide_lamp_fixtures@ee.doe.gov. 

Mr. Ari Altman, U.S. Department of Energy, Office of the General Counsel, GC71, 1000 Independence Avenue, S.W., Washington, DC, 20585-0121. Telephone: (202) 

287-6307. Email: ari.altman@hq.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Summary of the Final Rule and Its Benefits

A. Benefits and Costs to Customers

B. Impact on Manufacturers

C. National Benefits

D. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for MHLFs

3. Compliance Date

III. Issues Affecting the Scope of This Rulemaking

A. Additional MHLFs for Which DOE is Setting Standards

1. EISA 2007 Exempted MHLFs

a. MHLFs with Regulated-Lag Ballasts

b. MHLFs with 480 V Electronic Ballasts

c. Exempted 150 W MHLFs

2. Additional Wattages

3. General Lighting

4. High-Frequency Electronic Ballasts

5. Outdoor Fixtures

3 
6. Hazardous Locations

7. Summary of MHLFs for Which DOE is Setting Standards

B. Alternative Approaches to Energy Conservation Standards: System Approaches

C. Standby Mode and Off Mode Energy Consumption

IV. General Discussion

A. Test Procedures

1. Current Test Procedures

2. Test Input Voltage

a. Average of Tested Efficiency at All Possible Voltages

b. Posting the Highest and Lowest Efficiencies

c. Test at Single Manufacturer-Declared Voltage

d. Test at Highest Rated Voltage

e. Test on Input Voltage Based on Wattage and Available Voltages

3. Testing High-frequency Electronic Ballasts

4. Rounding Requirements

B. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

C. Energy Savings

1. Determination of Savings

2. Significance of Savings

D. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Customers

b. Savings in Operating Costs Compared to Increase in Price

c. Energy Savings

d. Lessening of Utility or Performance of Equipment

e. Impact of Any Lessening of Competition

f. Need for National Energy Conservation

g. Other Factors

2. Rebuttable Presumption

V. Methodology and Discussion

A. Market and Technology Assessment

1. General

2. Equipment Classes

a. Input Voltage

b. Lamp Wattage

c. Fixture Application

d. Electronic Configuration

e. Circuit Type

f. Summary

B. Screening Analysis

C. Engineering Analysis

1. Approach

2. Representative Equipment Classes

3. Representative Wattages

4. Representative Fixture Types

4 
5. Ballast Efficiency Testing

6. Input Power Representations

7. Baseline Ballast Models

a. 70 W Baseline Ballast

b. 1000 W Baseline Ballast

c. 1500 W Baseline Ballast

d. Summary of Baseline Ballasts

8. Selection of More-Efficient Units

a. Higher-Efficiency Magnetic Ballasts

b. Electronic Ballasts

9. Efficiency Levels

10. Design Standard

11. Scaling to Equipment Classes Not Analyzed

12. Manufacturer Selling Prices

a. Manufacturer Production Costs

b. Empty Fixture Costs

c. Incremental Costs for Electronically Ballasted MHLFs

d. Costs Associated with the Design Standard

e. Manufacturer Markups

D. Markups to Determine Equipment Price

1. Distribution Channels

2. Estimation of Markups

3. Summary of Markups

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analyses

1. Equipment Cost

2. Installation Cost

3. Annual Energy Use

4. Energy Prices

5. Energy Price Projections

6. Replacement Costs

7. Equipment Lifetime

8. Discount Rates

9. Analysis Period Fixture Purchasing Events

G. National Impact Analysis- National Energy Savings and Net Present Value 

Analysis

1. Shipments

a. Historical Shipments

b. Fixture Stock Projections

c. Base Case Shipment Scenarios

d. Standards-Case Efficiency Scenarios

2. Site-to-Source Energy Conversion

H. Customer Subgroup Analysis

I. Manufacturer Impact Analysis

1. Manufacturer Production Costs

2. Shipment Projections

3. Markup Scenarios

5 
4. Production and Capital Conversion Costs

5. Other Comments from Interested Parties

a. Compliance Period

b. Alternative Technologies

c. Opportunity Cost of Investments

d. Replacement Ballast Market

e. Potential Impact on Metal Halide Lamp Manufacturers

6. Manufacturer Interviews

J. Employment Impact Analysis

K. Utility Impact Analysis

L. Emissions Analysis

M. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

VI. Other Issues for Discussion

A. Proposed Standard Levels in August 2013 NOPR

B. Reported Value

C. Three-Year Compliance Date

VII. Analytical Results

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Customers

a. Life-Cycle Cost and Payback Period

b. Customer Subgroup Analysis

c. Rebuttable Presumption Payback

2. Economic Impacts on Manufacturers

a. Industry Cash-Flow Analysis Results

b. Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Subgroups of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Significance of Energy Savings

b. Net Present Value of Customer Costs and Benefits

c. Impacts on Employment

4. Impact on Utility or Performance of Equipment

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

C. Conclusions

1. Trial Standard Level 5

2. Trial Standard Level 4

3. Trial Standard Level 3

4. Trial Standard Level 2

D. Final Standard Equations

6 
E. Backsliding

VIII. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

b. Manufacturer Participation

c. Metal Halide Ballast and Fixture Industry Structure

d. Comparison Between Large and Small Entities

2. Description and Estimate of Compliance Requirements

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

4. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

M. Congressional Notification

IX. Approval of the Office of the Secretary

I. Summary of the Final Rule and Its Benefits

Title III, Part B1 of the Energy Policy and Conservation Act of 1975 (EPCA or 

the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles.2 Pursuant to 

EPCA, any new or amended energy conservation standard that DOE prescribes for 

1 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

2 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

7 

 
certain equipment, such as metal halide lamp fixtures (MHLFs or “fixtures”3

), shall be 

designed to achieve the maximum improvement in energy efficiency that DOE

determines is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, the new or amended standard must result in significant 

conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other 

statutory provisions discussed in this notice, DOE is adopting new and amended energy 

conservation standards for MHLFs. The new and amended standards, which are the 

minimum allowable ballast efficiencies4 based on fixture location, ballast type, and rated 

lamp wattage, are shown in Table I.1. These new and amended standards apply to all 

equipment listed in Table I.1 and manufactured in, or imported into, the United States on 

or after the compliance date in the DATES section of this notice (additionally, see section 

II.B.3. of this notice for more information on the compliance date determination).

Table I.1. Energy Conservation Standards for MHLFs

Designed to be 

Operated with Lamps 

of the Following Rated 

Lamp Wattage

Indoor/

Outdoor

Test Input 

Voltage†

Minimum Standard Equation‡

% 

≥50 W and ≤100 W Indoor 480 V (1/(1+1.24*×P^(-0.351))) - 0.0200

≥50 W and ≤100 W Indoor All others 1/(1+1.24*×P^(-0.351))

≥50 W and ≤100 W Outdoor 480 V (1/(1+1.24*×P^(-0.351))) - 0.0200

≥50 W and ≤100 W Outdoor All others 1/(1+1.24*×P^(-0.351))

3 The scope of this rulemaking encompasses entire MHLFs, including the metal halide lamps and metal 

halide ballasts the fixtures contain. Therefore, the ratings of individual components are often discussed at a 

system level. For example, when referring to the rated wattages or available input voltages of the lamps and 

ballasts a fixture is designed to operate with, this final rule frequently uses shorthand such as “100 W 

ballast” for a ballast operating a lamp rated at 100 watts or “480 V fixture” for a fixture housing a ballast 

with a dedicated input voltage of 480 volts.

4 DOE is proposing to continue using a ballast efficiency metric for regulation of MHLFs, rather than a 

system or other approach. See section III.B for further discussion.

Comment [AGA1]: Change requested by OIRA.

Comment [AGA2]: Change requested by OIRA.

Comment [AGA3]: Change requested by OIRA.

8 

 
Designed to be 

Operated with Lamps 

of the Following Rated 

Lamp Wattage

Indoor/

Outdoor

Test Input 

Voltage†

Minimum Standard Equation‡

% 

>100 W and <150 W* Indoor 480 V (1/(1+1.24*×P^(-0.351))) - 0.0200

>100 W and <150 W* Indoor All others 1/(1+1.24*×P^(-0.351))

>100 W and <150 W* Outdoor 480 V (1/(1+1.24*×P^(-0.351))) - 0.0200

>100 W and <150 W* Outdoor All others 1/(1+1.24*×P^(-0.351))

≥150 W** and ≤250 W Indoor 480 V 0.880

≥150 W** and ≤250 W Indoor All others

For ≥150 W and ≤200 W: 0.880

For >200 W and ≤250 W:

1/(1+0.876*×P^(-0.351))

≥150 W** and ≤250 W Outdoor 480 V 0.880

≥150 W** and ≤250 W Outdoor All others

For ≥150 W and ≤200 W: 0.88

For >200 W and ≤250 W:

1/(1+0.876*×P^(-0.351))

>250 W and ≤500 W Indoor 480 V

For >250 W and <265 W: 0.880 

For ≥265 W and ≤500 W: 

(1/(1+0.876*×P^(-0.351))))) – 0.0100

>250 W and ≤500 W Indoor All others 1/(1+0.876*×P^(-0.351))

>250 W and ≤500 W Outdoor 480 V

For >250 W and <265 W: 0.880 

For ≥265 W and ≤500 W: 

(1/(1+0.876*×P^(-0.351))))) – 0.0100

>250 W and ≤500 W Outdoor All others 1/(1+0.876*×P^(-0.351))

Comment [AGA2]: Change requested by OIRA.

9 
Designed to be 

Operated with Lamps 

of the Following Rated 

Lamp Wattage

Indoor/

Outdoor

Test Input 

Voltage†

Minimum Standard Equation‡

% 

>500 W and ≤1000 W Indoor 480 V

>500 W and ≤750 W: 0.900

>750 W and ≤1000 W:

0.000104*×P + 0.822

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and ≤1000 W Indoor All others

For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 

0.000104*×P+0.832

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and ≤1000 W Outdoor 480 V

>500 W and ≤750 W: 0.900

>750 W and ≤1000 W:

0.000104*×P + 0.822

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and ≤1000 W Outdoor All others

For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 

0.000104*×P+0.832

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

*Includes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 

watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and 

containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 

1029–2007. 

**Excludes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 

150 watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and 

containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 

1029–2007. 

†Tested input voltage is specified in 10 CFR 431.324

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

A. Benefits and Costs to Customers

Table I.2 presents DOE’s evaluation of the economic impacts of today’s standards 

on customers of MHLFs, as measured by the average life-cycle cost (LCC) savings and 

the median payback period. The average LCC savings are positive for a majority of users 

for all equipment classes.

Comment [AGA2]: Change requested by OIRA.

10 
Table I.2 Impacts of Today’s Standards on Customers of MHLFs*

Representative Equipment Class Representative 

Wattage

Average LCC 

Savings

2012$

Median Payback 

Period

years

70≥50 W and ≤100 W (indoor, 

magnetic baseline) 70 W 27.00 4.5

70≥50 W and ≤100 W (outdoor, 

magnetic baseline) 70 W 34.88 4.5

>100 W and <150 W** (indoor) 150 W 24.63 7.3

>100 W and <150 W** (outdoor) 150 W 30.70 8.1

≥150 W† and ≤250 W (indoor) 250 W 4.51 14.2

≥150 W† and ≤250 W (outdoor) 250 W 6.74 17.4

400>250 W and ≤500 W (indoor) 400 W 7.95 15.0

400>250 W and ≤500 W (outdoor) 400 W 13.15 18.4

>500 W and ≤1000 W (indoor) 1000 W 1221.54 0.8

>500 W and ≤1000 W (outdoor) 1000 W 1631.94 0.8

1500 W (indoor) N/A (baseline) N/A (baseline)

1500 W (outdoor) N/A (baseline) N/A (baseline)

* On average, indoor and outdoor fixtures have 20- and 25-year lifetimes, respectively.

** Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

† Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for 

use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2001.

B. Impact on Manufacturers

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the base year through the end of the analysis period (2014 to 2046). 

Using a real discount rate of 8.9 percent, DOE estimates that the base case INPV for 

manufacturers of MH ballasts ranges from $67 million in the low-shipment scenario to 

$74 million in the high-shipment scenario in 2012$. Under today’s standards, DOE 

expects that ballast manufacturers may lose up to 26.7 percent of their INPV, which is 

approximately $17.9 million, in the low-shipment, preservation of operating profit 

markup scenario.

For MHLF, using a real discount rate of 9.5 percent, DOE estimates that the base 

case INPV for manufacturers of MHLFs ranges from $346 million in the low-shipment 

11 
scenario to $379 million in the high-shipment scenario in 2012$. Under today’s 

standards, DOE expects that MHLF manufacturers may lose up to 1.0 percent of their 

INPV, which is approximately $3.6 million, in the low-shipment, preservation of 

operating profit markup scenario. 

When adding these two MH industries together (MHLF and MH ballast), DOE 

estimates that the combined base case INPV for manufacturers of MHLFs and MH 

ballasts ranges from $413 million in the low-shipment scenario to $453 million in the 

high-shipment scenario in 2012$. Under today’s standards, DOE expects that all MH 

manufacturers (MHLF and MH ballast manufacturers) may lose up to 5.2 percent of their 

INPV, which is approximately $21.5 million, in the low-shipment, preservation of 

operating profit markup scenario.

Additionally, based on DOE’s interviews with manufacturers of MHLFs and 

ballasts, DOE does not expect any plant closings or significant loss of employment.

C. National Benefits5

DOE’s analyses indicate that today’s standards would save a significant amount 

of energy. The lifetime savings for MHLFs purchased in the 30-year period that begins in 

the year of compliance with new and amended standards (2017–2046) amount to 0.39–

0.49 quads.

5 All monetary values in this section are expressed in 2012 dollars and are discounted to 2013. Value ranges 

correspond with estimates for the low and high shipment scenarios.

12 

 
The cumulative net present value (NPV) of total customer costs and savings of

today’s standards for MHLFs ranges from $0.29 billion (at a 7-percent discount rate, low 

shipments scenario) to $1.1 billion (at a 3-percent discount rate, high shipments 

scenario). This NPV expresses the estimated total value of future operating cost savings 

minus the estimated increased equipment costs for equipment purchased in 2017–2046. 

 

In addition, today’s standards would have significant environmental benefits. The 

energy savings would result in cumulative greenhouse gas emission reductions of 

approximately 22.5–27.8 million metric tons (Mt)6 of carbon dioxide (CO2), 105.9–132.4 

thousand tons of methane, 0.5–0.6 thousand tons of nitrous oxide (N2O), 37.5–47.2

thousand tons of sulfur dioxide (SO2), 28.2–35.0 tons of nitrogen oxides (NOX) and 0.05–

0.06 tons of mercury (Hg).3 Through 2030, the estimated energy savings would result in 

cumulative emissions reductions of 6.3 – 6.8 Mt of CO2.

The value of the CO2 reductions is calculated using a range of values per metric 

ton of CO2 (otherwise known as the Social Cost of Carbon or SCC) developed by a recent 

interagency process.7 The derivation of the SCC values is discussed in section V.M. 

Using discount rates appropriate for each set of SCC values, DOE estimates that the net 

6 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are presented in short tons. 3 DOE calculated emissions reductions relative to the Annual Energy Outlook (AEO) 2013 Reference case, 

which generally represents current legislation and environmental regulations for which implementing 

regulations were available as of December 31, 2012. 7

Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency Working Group on Social Cost of Carbon, United 

States Government. May 2013 (Revised November 2013). 

www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf. 

13 

 
present monetary value of the CO2 emissions reductions is between $0.15 billion and 

$2.55 billion. DOE also estimates that the net present monetary value of the NOX

emissions reductions is $17.34 million at a 7-percent discount rate, and $44.20 million at 

a 3-percent discount rate.8

Table I.3 summarizes the national economic costs and benefits expected to result 

from today’s standards for MHLFs. 

8

DOE is currently investigating valuation of avoided Hg and SO2 emissions.

14 

 
Table I.3 Summary of National Economic Benefits and Costs of MHLF Energy 

Conservation Standards*

Category Present Value

million 2012$ Discount Rate

Benefits

Operating Cost Savings

754 7%

1,636 3%

CO2 Reduction Monetized Value ($11.8/t case)** 146 5%

CO2 Reduction Monetized Value ($39.7/t case)** 682 3%

CO2 Reduction Monetized Value ($61.2/t case)** 1,088 2.5%

CO2 Reduction Monetized Value ($117/t case)** 2,106 3%

NOX Reduction Monetized Value (at $2639/ton)** 17 7%

37 3%

Total Benefits† 1,453 7%

2,355 3%

Costs

Incremental Installed Costs

465 7%

721 3%

Net Benefits

Including CO2 and NOX† Reduction Monetized Value

988 7%

1,634 3%

* This table presents the primary (low shipments scenario) estimate of costs and benefits associated with 

fixtures shipped in 2017−2046. These results include benefits to customers which accrue after 2047 from 

the equipment purchased in 2017−2046. The results account for the incremental variable and fixed costs 

incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.

** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios 

of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 

3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC 

distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an 

escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis.

† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC 

with a 3-percent discount rate.

The benefits and costs of today’s standards, for equipment sold in 2017-2046, can 

also be expressed in terms of annualized values. The annualized monetary values are the 

sum of (1) the annualized national economic value of the benefits from operating the 

equipment (consisting primarily of operating cost savings from using less energy, minus 

increases in equipment purchase and installation costs, which is another way of 

15 
representing customer NPV), plus (2) the annualized monetary value of the benefits of 

emission reductions, including CO2 emission reductions.9

Although adding the value of customer savings to the values of emission 

reductions provides a valuable perspective, two issues should be considered. First, the 

national operating cost savings are domestic U.S. customer monetary savings that occur 

as a result of market transactions, while the value of CO2 reductions is based on a global 

value. Second, the assessments of operating cost savings and CO2 savings are performed 

with different methods that use different time frames for analysis. The national operating 

cost savings is measured for the lifetime of MHLFs shipped in 2017–2046. The SCC 

values, on the other hand, reflect the present value of all future climate-related impacts 

resulting from the emission of one metric ton of carbon dioxide in each year. These 

impacts continue well beyond 2100. 

Estimates of annualized benefits and costs of today’s standards are shown in 

Table I.4. The results under the primary estimate are as follows. Using a 7-percent 

discount rate for benefits and costs other than CO2 reduction, for which DOE used a 3-

percent discount rate along with the average SCC series that uses a 3-percent discount 

rate, the cost of the standards in today’s rule is $46 million per year in increased 

9 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total 

customer costs and savings, for the time-series of costs and benefits using discount rates of 3 and 7 percent 

for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates, as shown in Table I.3. From the present value, DOE then calculated the fixed annual 

payment over a 30-year period (2017 through 2046) that yields the same present value. The fixed annual 

payment is the annualized value. Although DOE calculated annualized values, this does not imply that the 

time-series of cost and benefits from which the annualized values were determined is a steady stream of 

payments. 

16 

 
equipment costs, while the benefits are $74 million per year in reduced equipment 

operating costs, $38 million in CO2 reductions, and $1.71 million in reduced NOX

emissions. In this case, the net benefit amounts to $68 million per year. Using a 3-percent 

discount rate for all benefits and costs and the average SCC series, the cost of the 

standards in today’s rule is $40 million per year in increased equipment costs, while the 

benefits are $91 million per year in reduced operating costs, $38 million in CO2

reductions, and $2.07 million in reduced NOX emissions. In this case, the net benefit 

amounts to $91 million per year.

17 
Table I.4 Annualized Benefits and Costs of New and Amended Standards for 

MHLFs

Discount 

Rate

Primary (Low) Net 

Benefits Estimate*

High Net Benefits 

Estimate*

million 2012$/year

Benefits

Operating Cost Savings

7% 74 92

3% 91 119

CO2 Reduction at ($11.8 case)** 5% 11 13

CO2 Reduction at ($39.7/t case)** 3% 38 46

CO2 Reduction at ($61.2/t case)** 2.5% 56 68

CO2 Reduction at ($117.0/t case)** 3% 117 142

NOX Reduction at ($2639/ton)**

7% 1.71 1.95

3% 2.07 2.46

Total Benefits†

7% plus CO2

range

87 to 194 107 to 236

7% 114 140

3% 131 168

3% plus CO2

range

104 to 211 135 to 264

Costs

Incremental Product Costs

7% 46 52

3% 40 48

Net Benefits

Total†

7% plus CO2

range

41 to 148 54 to 184

7% 68 87

3% 91 120

3% plus CO2

range

64 to 171 87 to 216

* This table presents the annualized costs and benefits associated with fixtures shipped in 2017–2046. 

These results include benefits to consumers which accrue after 2046 from the fixtures purchased from 

2017–2046. The results account for the incremental variable and fixed costs incurred by manufacturers due 

to the standard, some of which may be incurred in preparation for the rule. The Primary (Low) and High 

Benefits Estimates utilize projections of energy prices from the AEO2013 Reference case and High 

Estimate, respectively. The Primary (Low) and High Benefits Estimates are also based on projected fixture 

shipments in the Low Shipments, Roll-up and High Shipments, Roll-up scenarios, respectively. In addition, 

the Primary (Low) estimate uses incremental equipment costs that assume fixed equipment prices 

throughout the analysis period. The High estimate uses incremental equipment costs that reflect a declining 

trend for equipment prices, using AEO price trends (deflators). The methods used to derive projected price 

trends are explained in section V.F.1. 

18 
** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios 

of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5-

percent, 3-percent, and 2.5-percent discount rates, respectively. The fourth case represents the 95th

percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series used by 

DOE incorporate an escalation factor. The value for NOX is the average of the low and high values used in 

DOE’s analysis.

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to 

average SCC with 3-percent discount rate. In the rows labeled “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values 

are added to the full range of CO2 values.

D. Conclusion

Based on the analyses culminating in this final rule, DOE found the benefits to the 

nation of the standards (energy savings, customer LCC savings, positive NPV of 

customer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC 

increases for some users of this equipment). DOE has concluded that the standards in 

today’s final rule represent the maximum improvement in energy efficiency that is 

technologically feasible and economically justified, and would result in significant 

conservation of energy.

II. Introduction

The following section briefly discusses the statutory authority underlying today’s 

final rule, as well as some of the relevant historical background related to the 

establishment of standards for MHLFs. 

19 
A. Authority

Title III, Part B10 of the Energy Policy and Conservation Act of 1975 (EPCA or 

the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy 

Conservation Program for Consumer Products Other Than Automobiles, a program 

covering most major household appliances (collectively referred to as “covered 

equipment”)11, which includes the types of MHLFs that are the subject of this

rulemaking. (42 U.S.C. 6292(a)(19)) EPCA, as amended by the Energy Independence 

and Security Act of 2007 (EISA 2007) prescribes energy conservation standards for this 

equipment (42 U.S.C. 6295(hh)(1)), and directs DOE to conduct a rulemaking to 

determine whether to amend these standards. (42 U.S.C. 6295(hh)(2)(A)) DOE notes that 

under 42 U.S.C. 6295(hh)(3)(A), the agency must conduct a second review of energy 

conservation standards for MHLFs and publish a final rule no later than January 1, 2019.

Pursuant to EPCA, DOE’s energy conservation program for covered equipment 

consists essentially of four parts: (1) testing; (2) labeling; (3) the establishment of federal 

energy conservation standards; and (4) certification and enforcement procedures. The 

Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE 

implements the remainder of the program. Subject to certain criteria and conditions, DOE 

is required to develop test procedures to measure the energy efficiency, energy use, or 

estimated annual operating cost of covered equipment. (42 U.S.C. 6293) Manufacturers 

of covered equipment must use the prescribed DOE test procedure as the basis for 

10 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 11 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).

20 

 
certifying to DOE that their equipment complies with the applicable energy conservation 

standards adopted under EPCA and when making representations to the public regarding 

the energy use or efficiency of that equipment. (42 U.S.C. 6293(c) and 6295(s)) 

Similarly, DOE must use these test procedures to determine whether the equipment 

complies with standards adopted pursuant to EPCA. Id. DOE test procedures for MHLFs

currently appear at title 10 of the Code of Federal Regulations (CFR) section 431.324. 

DOE must follow specific statutory criteria for prescribing new or amended 

standards for covered equipment. As indicated above, any new or amended standard for 

covered equipment must be designed to achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, DOE may not adopt any standard that would not result in

the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not 

prescribe a standard: (1) for certain equipment, including MHLFs, if no test procedure 

has been established for the equipment, or (2) if DOE determines by rule that the new or

amended standard is not technologically feasible or economically justified. (42 U.S.C. 

6295(o)(3)(A)-(B)) In deciding whether a new or amended standard is economically 

justified, DOE must determine whether the benefits of the standard exceed its burdens. 

(42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving 

comments on the proposed standard, and by considering, to the greatest extent 

practicable, the following seven factors:

1. The economic impact of the standard on manufacturers and customers of the 

equipment subject to the standard;

21 
2. The savings in operating costs throughout the estimated average life of the 

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

charges, or maintenance expenses for the covered equipment that are likely to result from 

the imposition of the standard;

3. The total projected amount of energy, or as applicable, water, savings likely to 

result directly from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered equipment likely 

to result from the imposition of the standard;

5. The impact of any lessening of competition, as determined in writing by the 

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

6. The need for national energy and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII))

 

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any new or amended standard 

that either increases the maximum allowable energy use or decreases the minimum 

required energy efficiency of covered equipment. (42 U.S.C. 6295(o)(1)) Also, the 

Secretary may not prescribe an amended or new standard if interested persons have 

established by a preponderance of the evidence that the standard is likely to result in the 

unavailability in the United States of any covered equipment type (or class) of 

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

that are substantially the same as those generally available in the United States. (42 

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

22 
Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the customer of 

purchasing equipment complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the customer

will receive as a result of the standard, as calculated under the applicable test procedure. 

See 42 U.S.C. 6295(o)(2)(B)(iii).

Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a 

standard for a type or class of covered equipment that has two or more subcategories. 

DOE must specify a different standard level than that which applies generally to such 

type or class of equipment for any group of covered equipment that has the same function 

or intended use if DOE determines that equipment within such group (A) consumes a 

different kind of energy from that consumed by other covered equipment within such 

type (or class); or (B) has a capacity or other performance-related feature that other 

equipment within such type (or class) does not have and such feature justifies a higher or 

lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related 

feature justifies a different standard for a group of equipment, DOE must consider such 

factors as the utility to the customer of such a feature and other factors DOE deems 

appropriate. Id. Any rule prescribing such a standard must include an explanation of the 

basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2)) 

Federal energy conservation requirements generally supersede state laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

23 
6297(a)–(c)) DOE may, however, grant waivers of federal preemption for particular state 

laws or regulations, in accordance with the procedures and other provisions set forth 

under 42 U.S.C. 6297(d)). 

Finally, pursuant to the amendments contained in section 310(3) of EISA 2007, 

any final rule for new or amended energy conservation standards promulgated after July 

1, 2010, are required to address standby mode and off mode energy use. (42 U.S.C. 

6295(gg)(3)) Specifically, when DOE adopts a standard for covered equipment after that 

date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 

6295(o)), incorporate standby mode and off mode energy use into the standard, or, if that 

is not feasible, adopt a separate standard for such energy use for that equipment. (42 

U.S.C. 6295(gg)(3)(A)-(B)) DOE’s current test procedures and standards for MHLFs 

address standby mode and off mode energy use. However, in this rulemaking, DOE only 

addresses active mode energy consumption as the equipment included in the scope of 

coverage only consumes energy in active mode.

B. Background

1. Current Standards

EISA 2007 prescribed the current energy conservation standards for MHLFs 

manufactured on or after January 1, 2009. (42 U.S.C. 6295(hh)(1)) The current standards 

are set forth in Table II.1. EISA 2007 excludes from the standards: MHLFs with 

regulated-lag ballasts, MHLFs with electronic ballasts that operate at 480 volts (V); and 

MHLFs that (1) are rated only for 150 watt (W) lamps; (2) are rated for use in wet 

24 
locations; and (3) contain a ballast that is rated to operate at ambient air temperatures 

higher than 50 °C.

Table II.1 Federal Energy Efficiency Standards for MHLFs*

Ballast Type Operated Lamp Rated Wattage 

Range Minimum Ballast Efficiency

Pulse-start ≥150 and ≤500 W 88%

Magnetic Probe-start ≥150 and ≤500 W 94%

Nonpulse-start Electronic ≥150 and ≤250 W 90%

Nonpulse-start Electronic ≥250 and ≤500 W 92%

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

2. History of Standards Rulemaking for MHLFs

DOE is conducting this rulemaking to review and consider amendments to the 

energy conservation standards in effect for MHLFs, as required under 42 U.S.C. 

6295(hh)(2) and (4). On December 30, 2009, DOE published a notice announcing the 

availability of the framework document, “Energy Conservation Standards Rulemaking 

Framework Document for Metal Halide Lamp Fixtures,” and a public meeting to discuss 

the proposed analytical framework for the rulemaking. 74 FR 69036. DOE also posted 

the framework document on its website; this document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16. 

The framework document described the procedural and analytical approaches that DOE 

anticipated using to evaluate energy conservation standards for MHLFs, and identified 

various issues to be resolved in conducting this rulemaking.

DOE held a public meeting on January 26, 2010, during which it presented the 

contents of the framework document, described the analyses it planned to conduct during 

25 
the rulemaking, sought comments from interested parties on these subjects, and in 

general, sought to inform interested parties about, and facilitate their involvement in, the 

rulemaking. At the meeting and during the period for commenting on the framework 

document, DOE received comments that helped identify and resolve issues involved in 

this rulemaking.

DOE then gathered additional information and performed preliminary analyses to 

help develop potential energy conservation standards for MHLFs. On April 1, 2011, DOE 

published in the Federal Register an announcement (the preliminary analysis notice) of 

the availability of the preliminary technical support document (the preliminary TSD) and 

of another public meeting to discuss and receive comments on the following matters: (1) 

the equipment classes DOE planned to analyze; (2) the analytical framework, models, 

and tools that DOE was using to evaluate standards; (3) the results of the preliminary 

analyses performed by DOE; and (4) potential standard levels that DOE could consider. 

76 FR 1812 (April 1, 2011). In the preliminary analysis notice, DOE requested comment 

on these issues. The preliminary TSD is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16. 

The preliminary TSD summarized the activities DOE undertook in developing 

standards for MHLFs, and discussed the comments DOE received in response to the 

framework document. It also described the analytical framework that DOE uses in this 

rulemaking, including a description of the methodology, the analytical tools, and the 

relationships among the various analyses that are part of the rulemaking. The preliminary 

26 
TSD presented and described in detail each analysis DOE performed up to that point, 

including descriptions of inputs, sources, methodologies, and results.

The public meeting announced in the preliminary analysis notice took place on 

April 18, 2011. At this meeting, DOE presented the methodologies and results of the 

analyses set forth in the preliminary TSD. Interested parties discussed the following 

major issues at the public meeting: (1) alternative approaches to performance 

requirements and the various related efficiency metrics; (2) the possibility of including

design standards; (3) amendments to the test procedures for metal halide (MH) ballasts to 

account for multiple input voltages; (4) the cost and feasibility of utilizing electronic 

ballasts in MHLFs; (5) equipment class divisions; (6) overall pricing methodology; (7) 

lamp lifetimes; (8) cumulative regulatory burden; (9) shipments; and (10) the possibility 

of merging the MHLF and the high-intensity discharge (HID) lamp rulemakings.

In August 2013, DOE published a notice of proposed rulemaking (NOPR) in the 

Federal Register proposing new and amended energy conservation standards for MHLFs. 

In conjunction with the NOPR, DOE also published on its website the complete TSD for 

the proposed rule, which incorporated the analyses DOE conducted and technical 

documentation for each analysis. The NOPR TSD was accompanied by the LCC 

spreadsheet, the national impact analysis spreadsheet, and the manufacturer impact 

27 
analysis (MIA) spreadsheet—all of which are available on DOE’s website.12 The 

proposed standards were as shown in Table II.2.78 FR 51463 (August 20, 2013). 

12 All the spreadsheets models developed for this rulemaking proceeding are available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16. 

28 

 
Table II.2 Energy Conservation Standards Proposed in the NOPR

Designed to be 

Operated with 

Lamps of the 

Following Rated 

Lamp Wattage

Indoor/ 

Outdoor***†

Test Input 

Voltage†††

Minimum Standard Equation‡

% 

≥50 W and ≤100 

W Indoor 480 V 99.4/(1+2.5∗×P^(-0.55)) ‡

≥50 W and ≤100 

W Indoor All others 100/(1+2.5∗×P^(-0.55))

≥50 W and ≤100 

W Outdoor 480 V 99.4/(1+2.5∗×P^(-0.55))

≥50 W and ≤100 

W Outdoor All others 100/(1+2.5∗×P^(-0.55))

>100 W and <150 

W* Indoor 480 V 99.4/(1+0.36∗×P^(-0.30))

>100 W and <150 

W* Indoor All others 100/(1+0.36∗×P^(-0.30))

>100 W and <150 

W* Outdoor 480 V 99.4/(1+0.36∗×P^(-0.30))

>100 W and <150 

W* Outdoor All others 100/(1+0.36∗×P^(-0.30))

≥150 W** and 

≤250 W Indoor 480 V

For ≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

0.06 * ×P + 76.0

≥150 W** and 

≤250 W Indoor All others

For ≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

0.07 * ×P + 74.0

≥150 W** and 

≤250 W Outdoor 480 V

For ≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

0.06 * ×P + 76.0

≥150 W** and 

≤250 W Outdoor All others

For ≥150 W and ≤200 W: 88.0

For >200 W and ≤250 W:

0.07 * ×P + 74.0

>250 W and ≤500 

W Indoor 480 V 91.0

>250 W and ≤500 

W Indoor All others 91.5

>250 W and ≤500 

W Outdoor 480 V 91.0

>250 W and ≤500 

W Outdoor All others 91.5

>500 W and 

≤2000 W Indoor 480 V

For >500 W to <1000 W:

0.994 ∗ (×(0.0032 * ×P + 89.9)

For ≥1000 W to ≤2000 W: 92.5 and may 

not utilize a probe-start ballast

>500 W and 

≤2000 W Indoor All others

For >500 W to <1000 W:

0.0032 ∗ ×P + 89.9

For ≥1000 W to ≤2000 W: 93.1 and may 

not utilize a probe-start ballast

>500 W and Outdoor 480 V For >500 W to <1000 W:

Comment [AGA4]: Change requested by OIRA.

29 
Designed to be 

Operated with 

Lamps of the 

Following Rated 

Lamp Wattage

Indoor/ 

Outdoor***†

Test Input 

Voltage†††

Minimum Standard Equation‡

% 

≤2000 W 0.994 ∗ (×(0.0032 ∗ ×P + 89.9)

For ≥1000 W to ≤2000 W: 92.5 and may 

not utilize a probe-start ballast

>500 W and 

≤2000 W Outdoor All others

For >500 W to <1000 W:

0.0032 ∗ ×P + 89.9

For ≥1000 W to ≤2000 W: 93.1 and may 

not utilize a probe-start ballast

*Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

***†DOE’s proposed definitions for “indoor” and “outdoor” MHLFs are described in section V.A.2. 

†††Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less 

than 150 W would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. 

Ballasts not designed to operate at either of these voltages would be tested at the highest voltage for which 

the ballast is designed to operate.

‡P is defined as the rated wattage of the lamp that the MHLF is designed to operate.

In the NOPR DOE invited comment, particularly on the following issues: (1) the 

expanded scope of coverage, (2) the proposed amendments to the test procedure, (3) 

equipment class divisions, (4) the efficiency levels (ELs) analyzed, (5) the method of 

estimating magnetically ballasted system input power, (6) the determination to include a 

design standard that would prohibit the sale of probe-start ballasts in newly sold MHLFs 

for certain wattages, (7) the derived manufacturer selling prices (MSPs), (8) the 

equipment class scaling factor for tested input voltage, and (9) the proposed trial standard 

level (TSL 3). 78 FR 51463 (August 20, 2013). 

DOE held a NOPR public meeting on September 27, 2013, to hear oral comments 

on and solicit information relevant to the proposed rule (hereafter the NOPR public 

meeting). Interested parties in attendance discussed the following major issues: (1) the 

Comment [AGA4]: Change requested by OIRA.

30 
compliance date, (2) amendments to the test procedure, (3) scope of the rulemaking, (4) 

equipment class divisions, (5) impacts on the magnetic ballast footprint, (6) impacts on 

fixture design, (7) testing and manufacturing variation, and (8) impacts of solid-state 

lighting market penetration on MHLF shipments.

DOE considered the comments received in response to the NOPR after its 

publication and at the NOPR public meeting when developing this final rule, and 

responds to these comments in this notice.

3. Compliance Date

EPCA, as amended by EISA 2007, contains guidelines for the compliance date of 

the standards amended by this rulemaking. EPCA requires DOE to determine whether to 

amend the standards in effect for MHLFs and whether any amended standards should 

apply to additional MHLFs. The Secretary was directed to publish a final rule no later 

than January 1, 2012 to determine whether the energy conservation standards established 

by EISA 2007 for MHLFs should be amended, with any amendment applicable to 

equipment manufactured after January 1, 2015. (42 U.S.C. 6295(hh)(2)(B)) As discussed 

in section VI.C, DOE has determined it will maintain the three-year interval between the 

publication date of the final rule in the Federal Register and the compliance date. Comment [AGA5]: Change requested by OIRA.

31 
III. Issues Affecting the Scope of This Rulemaking

A. Additional MHLFs for Which DOE is Setting Standards

The existing energy conservation standards for MHLFs are established in EPCA 

through amendments made by EISA 2007. (42 U.S.C. 6295(hh)(1)(A)) The statute 

excludes from coverage MHLFs with regulated-lag ballasts; electronic ballasts that 

operate at 480 V; and ballasts that are rated only for (1) use with 150 W lamps, (2) use in 

wet locations, and (3) operation in ambient air temperatures higher than 50 °C..13 DOE 

considered expanding the coverage of its energy conservation standards to include these 

exempted MHLF types and additional rated lamp wattages. For each previously 

exempted MHLF type and for all expansions of the covered wattage range, DOE 

considered potential energy savings, technological feasibility, and economic justification 

when determining whether to include them in the scope of coverage.

Some stakeholders expressed confusion at the NOPR public meeting, stating that 

they interpreted this rulemaking as establishing efficiency standards for all metal halide 

ballasts rather than just ballasts in new metal halide lamp fixtures. The Edison Electric 

Institute (EEI) contended that the rule is misleading because the title indicates it is a rule 

for metal halide lamp fixtures when it actually establishes standards for all metal halide 

ballasts, including replacement ballasts. (EEI, Public Meeting Transcript, No. 48 at pp. 

14-15, 67-69)14 DOE clarifies that the scope of this rulemaking affects all new MHLFs. 

13 As a point of reference, 50 °C is equivalent to 122 °F. 14 A notation in the form ‘‘EEI, Public Meeting Transcript, No. 48 at pp. 14-15, 67-69’’ identifies a 

comment that DOE has received and included in the docket of this rulemaking. This particular notation 

refers to a comment: (1) submitted by EEI; (2) in the transcript of the MHLF NOPR public meeting, 

Comment [AGA6]: Change requested by OIRA.

32 

 
Ballasts sold with new fixtures after the compliance date must meet or exceed the 

standards promulgated by this rulemaking. Any ballasts sold on the replacement market 

do not need to comply with these standards. 

Regarding the additional fixtures that DOE proposed including in the scope of 

coverage, the California Energy Commission (CEC) generally supported the expanded 

scope for MHLFs DOE proposed in the NOPR. (CEC, No. 52 at p. 3) DOE received no 

other comment regarding the general approach to expand the scope of coverage and 

considers specific scope comments in the following sections.

1. EISA 2007 Exempted MHLFs

a. MHLFs with Regulated-Lag Ballasts

Regulated-lag ballasts are mainly used for specialty applications where line 

voltage variation is large. Regulated-lag ballasts are designed to withstand significant line 

voltage variation with minimum wattage variation to the lamp, which results in an 

efficiency penalty compared to ballasts whose output changes more significantly with 

line voltage variation. The power regulation provided by regulated-lag ballasts is higher 

than any other magnetic ballast. To be able to withstand large variations, regulated-lag 

ballasts are designed to be significantly larger than standard ballasts. Through 

manufacturer interviews and market research, DOE determined that the size and weight 

of regulated-lag ballasts limit their use as substitutes in traditional applications. 

document number 48 in the docket of this rulemaking; and (3) appearing on pages 14-15 and 67-69 of that 

transcript.

33 

 
Manufacturers and market research confirmed that their exemption did not lead to a 

significant market shift to regulated-lag ballasts. Furthermore, DOE’s market research 

found none of this equipment available in major manufacturers’ catalogs. The absence of 

regulated-lag ballasts from catalogs indicates a very small market share and therefore 

limited potential for significant energy savings. Thus, in the NOPR DOE proposed 

continuing to exempt MHLFs with regulated-lag ballasts from energy conservation 

standards.

Universal Lighting Technologies (ULT) and the National Electrical 

Manufacturers Association (NEMA) agreed with DOE’s proposal to continue exempting 

regulated-lag ballasts from the scope of this rulemaking. NEMA further added that this 

higher cost technology is used in limited and specific applications, such as heavy 

industrial, security, and street and tunnel lighting, in order to avoid lamp failures caused 

by severe voltage dips. (ULT, No. 50 at p. 2; NEMA, No. 56 at p. 5; NEMA, Public 

Meeting Transcript, No. 48 at p. 48) Agreeing with this description of a limited, niche 

market and receiving no comments to the contrary, in this final rule DOE exempts 

regulated-lag ballasts from energy conservation standards.

b. MHLFs with 480 V Electronic Ballasts

In the NOPR, DOE concluded that 480 V electronic ballasts have a very small 

market share as they are only manufactured by one company and have limited availability 

from distributors. As a result, DOE determined that there is limited potential for 

significant energy savings, and in the NOPR proposed continuing to exempt MHLFs with 

480 V electronic ballasts from energy conservation standards.

34 
Philips Lighting (Philips), ULT, and NEMA agreed with DOE’s decision to 

exclude 480 V electronic ballasts in the scope of this rulemaking. ULT noted that very 

few 480 V electronic ballasts are in the market, while Philips commented that 480 V 

electronic ballasts do not exist at any wattage. (Philips, Public Meeting Transcript, No. 48 

at p. 130; ULT, No. 50 at p. 2; NEMA, No. 56 at p. 5) Having received no comments in 

disagreement, DOE continues to exempt 480 V electronic ballasts from energy 

conservation standards in this final rule.

c. Exempted 150 W MHLFs

After receiving exemption from energy conservation standards in EISA 2007,

shipments of 150 W outdoor MHLFs rated for wet and high-temperature locations 

increased. Further, some indoor applications use the exempted outdoor MHLFs, negating 

possible energy savings for indoor 150 W MHLFs. Therefore, in the NOPR DOE 

concluded that including the currently exempt 150 W MHLFs in the scope of coverage 

has the potential for significant energy savings. Additionally, as a range of ballast 

efficiencies exists in commercially available ballasts, DOE found that improving the 

efficiencies of the ballasts included in these fixtures is technologically feasible and 

economically justified. Accordingly, in the NOPR DOE proposed including 150 W 

MHLFs in wet locations and ambient temperatures greater than 50 ̊C in the scope of this 

rulemaking.

NEMA, ULT, CEC, and the Southern Company disagreed with DOE’s decision to 

include all 150 W ballasts in the scope of this rulemaking. (NEMA, No. 56 at pp. 5, 12; 

35 
ULT, No. 50 at pp. 2-3; CEC, No. 52 at p. 3; Southern Company, No. 64 at p. 2; No. 64 

at p. 2) NEMA commented that while DOE does have the authority to include this 

equipment, it must be done in a technologically and economically feasible manner. 

NEMA stated that the efficiencies adopted in the final rule must be substantially lowered 

from those proposed in the NOPR to be technologically feasible. (NEMA, No. 56 at pp. 

5, 24) In support of this point, ULT and NEMA noted that the industry has not yet been 

able to create a 150 W MHLF with a magnetic ballast that achieves 88 percent efficiency, 

which is the minimum efficiency requirement proposed in the NOPR for previously 

exempt 150 W MHLFs. (ULT, Public Meeting Transcript, No. 48 at pp. 108-109; ULT, 

No. 50 at pp. 5-6, 23-24; NEMA, No. 56 at p. 13)

In contrast, in a joint comment the Pacific Gas and Electric Company, Southern 

California Gas Company, San Diego Gas and Electric, and Southern California Edison 

(hereafter referred to as the California investor-owned utilities or the “CA IOUs”) 

supported DOE’s proposal to include previously exempt 150 W MHLFs in the scope of 

coverage. CA IOUs were unaware of any specific attributes that limit 150 W ballasts 

from reaching greater efficiency, and believe the lower efficiencies of these ballasts are 

more likely due to their prior exemption from standards, as there is significant room for 

improvement. Therefore, CA IOUs supported the inclusion of these ballasts. (CA IOUs, 

No. 54 at pp. 1-2) Also, in a joint comment the Appliance Standards Awareness Project, 

American Council for an Energy-Efficient Economy, National Consumer Law Center, 

Natural Resources Defense Council, Northwest Energy Efficiency Alliance, and 

Northwest Power and Conservation Council (hereafter referred to as the “Joint 

36 
Comment”) supported including 150 W MHLFs previously exempted by EISA 2007 in 

the scope of this final rule. (Joint Comment, No. 62 at p. 9) 

DOE agrees that commercially available magnetic ballasts cannot meet the EISA 

2007 specified 88 percent efficiency. However, the 150 W fixtures exempted by EISA 

2007 have a range of magnetic ballast efficiencies available below 88 percent and 

therefore energy conservation standards are technologically feasible. These fixtures can 

be considered separately from those 150 W fixtures covered by EISA 2007 by separating 

them into different equipment classes and DOE therefore finds no reason the previously 

exempt 150 W fixtures should not be covered by this rulemaking. Therefore in this final 

rule, DOE has included 150 W fixtures rated for use in wet locations and ambient 

temperatures greater than 50 °C in the scope of coverage.

NEMA, ULT, and Southern Company commented that the inclusion of 150 W 

ballast efficiency requirements would practically prohibit usage of 150 W magnetic 

ballasts, thereby forcing the usage of electronic ballasts in new fixtures. (NEMA, No. 56 

at p. 6; ULT, No. 50 at pp. 2-3; Southern Company, No. 64 at p. 2) ULT and Southern 

Company expressed concerns that electronic ballasts for MH lamps are not proven in 

outdoor applications and are vulnerable to failures due to moisture, temperatures higher 

than 50 °C, and voltage variations and surges caused by lightning and other natural 

events. (ULT, No. 50 at pp. 2-3; Southern Company, No. 64 at p. 2) 

DOE considered both more efficient magnetic and more efficient electronic 

ballasts as replacements for ballasts in the previously exempt 150 W fixtures. DOE has 

37 
determined that, with the proper fixture adjustments, electronic ballasts can be used in the 

same applications as magnetic ballasts. For detailed discussion of this decision, see 

section V.A. DOE has concluded that the standard levels adopted in this final rule are 

economically justified.

General Electric (GE) commented that energy conservation standards for 

previously exempt 150 W MHLFs could actually increase rather than decrease national 

energy consumption. GE noted that the purpose of the 150 W exemption from EISA 2007 

was to shift the market from 175 W fixtures to 150 W fixtures, thereby saving energy. 

Thus, GE disagreed with the way DOE analyzed 150 W fixtures and noted that the 

previously exempt fixtures should not be subject to standards higher than max tech. (GE, 

Public Meeting Transcript, No. 48 at pp. 135-136) 

CA IOUs acknowledged that 150 W ballasts can be a low-wattage replacement 

for 175 W applications. Accordingly, CA IOUs encouraged increasing efficiency 

standards for both wattage levels equally, so as not to inadvertently push customers to the 

higher-wattage alternatives. (CA IOUs, No. 54 at pp. 1-2) CEC agreed, stating that by 

incentivizing 150 W fixtures through minimal efficiency standards, the market would be 

driven toward purchasing these lower-wattage fixtures instead of 175 W or 200 W 

fixtures. (CEC, No. 52 at p. 3) 

The Joint Comment noted that while customers may choose to shift between 

different wattage MHLFs, continuing to exempt 150 W MHLFs is not the best solution. 

For example, a continued exemption might create market distortions and hinder the 

38 
transitions to more efficient light-emitting diode (LED) lamps in this wattage category. 

(Joint Comment, No. 62 at p. 9) The Joint Comment also stated that even if the inclusion 

of 150 W fixtures leads to the use of more 175 W or 200 W fixtures, it might not result in 

more energy consumption as switching to higher-wattage fixtures could also reduce the 

number of fixtures installed. In situations where the number of fixtures installed is not 

reduced, additional energy use could be offset by increased ballast efficiency in this 

wattage bin. In addition, the increased price of the 175 W fixtures provides more 

disincentive to purchase them over 150 W fixtures. Finally, the Joint Comment argued 

that if the standards apply to all wattage ranges from 50 W to 500 W, switching from 150 

W to a higher-wattage fixture would not be a concern because all fixtures would be 

subject to the same standards. (Joint Comment, No. 62 at p. 9)

DOE notes that the exemption of certain 150 W fixtures from EISA 2007 resulted 

in a shift from 175 W to the exempted 150 W fixtures, which resulted in energy savings. 

In the shipments analysis, DOE considers how different standards for 150 W and 175 W 

MHLFs may impact customer choices. For example, when the initial first cost for 150 W 

fixtures exceeds that of 175 W fixtures, the shipments analysis models a shift to 175 W 

MHLFs. Even with some customers shifting to higher wattage MHLFs, energy 

conservation standards for 150 W fixtures still result in energy savings due to increased 

ballast efficiency. In this final rule, DOE has determined that standards for previously 

exempt 150 W MHLFs are technologically feasible, economically justified, and would 

result in significant energy savings (see section VII.C for details). Therefore, DOE has 

included previously exempt 150 W fixtures in the scope of coverage of this rulemaking.

39 
2. Additional Wattages

Based on equipment testing and market research, DOE found in the NOPR that 

energy conservation standards for MHLFs rated for wattages greater than 50 W and less 

than 150 W, and MHLFs rated for wattages greater than 500 W, are technologically

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

determined that MHLFs rated for wattages greater than 2000 W only served smallmarket-share applications like graphic arts, ultraviolet (UV) curing, and scanners. 

Therefore, in the NOPR DOE proposed to include in the scope of coverage 50 W – 150 

W MHLFs and 501 W – 2000 W MHLFs, in addition to the 150 W – 500 W MHLFs15

covered by EISA 2007. 

NEMA and ULT opposed the expansion of coverage of this rulemaking to include 

50 W – 150 W MHLFs. They further commented that coverage of 50 W – 100 W MHLFs 

would require redesign of all magnetic ballasts in that range, which would be nearly 

equivalent to banning magnetic ballasts. (NEMA, No. 56 at p. 6; ULT, No. 50 at pp. 2-3) 

DOE has found MHLFs with a variety of ballast efficiencies in the 50 W – 150 W 

range, including the 50 W – 100 W range specifically cited by NEMA and ULT. 

Therefore, DOE believes energy conservation standards for 50 W – 150 W MHLFs are 

technologically feasible. DOE considered both more efficient magnetic and more 

efficient electronic ballasts as replacements for ballasts in this rulemaking. DOE has 

15 DOE uses this shorthand to refer to MHLFs with ballasts designed to operate lamps rated greater than or 

equal to 50 W and less than 150 W, MHLFs with ballasts designed to operate lamps rated greater than 500 

W and less than or equal to 2000 W, and MHLFs with ballasts designed to operate lamps rated greater than 

or equal to 150 W and less than or equal to 500 W, respectively.

40 

 
determined that, with the proper fixture adjustments, electronic ballasts can be used in the 

same applications as magnetic ballasts. For detailed discussion of this decision, see 

section V.A. Economic impacts of standard levels on individual customers, 

manufacturers, and the nation are discussed in section VII.B. DOE has concluded that the 

standard levels adopted in this final rule for 50 W – 150 W MHLFs are economically 

justified and would result in significant energy savings. Therefore, DOE has included 50 

W – 150 W MHLFs in the scope of coverage for this final rule.

DOE received several comments regarding the inclusion of MHLFs greater than 

500 W in the scope of coverage. CA IOUs and Earthjustice supported the expansion of 

the scope of coverage to include 50 W – 2000 W fixtures. (CA IOUs, No. 54 at pp. 1-2; 

Earthjustice, Public Meeting Transcript, No. 48 at p. 171) CA IOUs commented that 

because 18 percent of MH ballasts are designed to operate lamps greater than 500 W, 

there exists an opportunity for significant energy savings. (CA IOUs, No. 54 at pp. 1-2) 

In contrast, NEMA and ULT disagreed with the inclusion of MHLFs greater than 

500 W, noting that coverage of the 501 W – 2000 W range would require redesign of the 

750 W fixture family and this would come with significant cost increase. (NEMA, No. 56 

at pp. 6-7; ULT, No. 50 at pp. 2-3) 

DOE believes that standards for 500 W – 1000 W MHLFs are technologically 

feasible because MHLFs in this wattage range contain ballasts that exhibit a range of 

efficiencies, indicating it is possible for a standard to improve the efficiency of ballasts 

already on the market. Specifically, DOE has found 750 W MHLFs with ballasts at 

41 
multiple efficiencies that span both EL1 and EL2. Furthermore, DOE has analyzed 

MHLFs in this wattage range and concluded that standards for these MHLFs are 

economically justified and result in significant energy savings (see section VII.B of this 

notice for more details). Therefore, DOE includes 500 W – 1000 W MHLFs in the scope 

of coverage for this rulemaking.

NEMA, GE, ULT, Musco Sports Lighting, LLC (Musco Lighting), Venture 

Lighting International, Inc. (Venture), and OSRAM SYLVANIA Inc. (OSI) all asserted 

that fixtures greater than 1000 W should not be covered by this rulemaking, as they are 

only operated in “specialty lighting” applications. They stated that the lamps’ limited 

applications and low hours of operation do not result in appreciable savings 

opportunities, provide little energy gains at a significant cost, and pose an unjustified 

burden on manufacturers. (NEMA, Public Meeting Transcript, No. 48 at p. 114; NEMA, 

No. 56 at pp. 6-7; GE, Public Meeting Transcript, No. 48 at pp. 115, 172; ULT, No. 50 at 

pp. 2-3; Musco Lighting, Public Meeting Transcript, No. 48 at pp. 118, 180; Musco 

Lighting, No. 55 at pp. 3-4; Venture, Public Meeting Transcript, No. 48 at p. 170; OSI, 

Public Meeting Transcript, No. 48 at p. 172) Further, NEMA cited the 2010 U.S. 

Lighting Market Characterization (2010 LMC),16 as evidence that stadium and sports 

lighting, the most common application for fixtures greater than 1000 W, is a niche 

market, unsuitable for energy savings exploration. Specifically, NEMA noted that in the 

2010 LMC, the 839,000 MH lamps in stadium applications represent 2.8 percent of 

16 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. 2010 U.S. Lighting 

Market Characterization. 2010. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

42 

 
outdoor MH lamps (0.4 percent of all outdoor lamps) and only 1.2 percent of all installed

MH lamps (see Table 4.1 in the 2010 LMC). For MH lamps in stadium applications, the 

average wattage is 1554 W (see Table 4.28 in the 2010 LMC) with an average usage of 

just 1 hour per day (see Table 4.29 in the 2010 LMC). NEMA agreed with the 2010 LMC 

that this is a reasonable average usage profile for MH lamps greater than 1000 W. In 

contrast, typical outdoor MH lamps average 12.1 hours per day ranging from 8.8 hours 

on building exteriors to 15 hours in parking areas. (NEMA, No. 56 at pp. 6-7) 

Musco Lighting pointed out that DOE’s decision to not directly analyze 480 V 

magnetic ballasts due to low shipment volume supported their assertion that 1500 W 

fixtures should be exempt from energy conservation standards. Musco Lighting specified 

that as more than 50 percent of their shipments of 1500 W MHLFs contained a 480 V 

ballast, both MHLF types should be exempt. (Musco Lighting, Public Meeting 

Transcript, No. 48 at p. 129)

DOE determined that sports lighting, which is the predominant application for 

lamps above 1000 W, fits the definition of general lighting and is therefore included in 

the scope of this rulemaking (see the following section III.A.3 for additional discussion). 

Although these higher wattage MHLFs do not comprise a large percentage of the market, 

their high wattage could potentially result in significant energy savings. DOE notes that 

MHLFs greater than 1000 W exist in a variety of efficiencies and therefore standards for 

these MHLFs are technologically feasible. DOE acknowledges, however, that MHLFs 

greater than 1000 W have a different cost-efficiency relationship than 501 W to 1000 W 

MHLFs. Therefore, in this final rule, DOE created a separate equipment class to analyze 

43 
these MHLFs. See section V.A.2 for additional detail. After considering the economic 

impacts of standards for MHLFs greater than 1000 W on individual customers, 

manufacturers, and the nation, DOE has concluded that standards for these MHLFs are 

not economically justified. Therefore, in this final rule, DOE has not included MHLFs 

greater than 1000 W in the scope of coverage and has not adopted energy conservation 

standards for these MHLFs. See section VII for a discussion of the economic impacts.

3. General Lighting

EISA 2007 defines the scope of this rulemaking as applying to MHLFs used in 

general lighting applications. (42 U.S.C. 6291(64)) In section 2 of 10 CFR Part 430, 

Subpart A, a general lighting application is defined as lighting that provides an interior or 

exterior area with overall illumination. In the NOPR, DOE proposed to add this definition 

to 10 CFR Part 431.2,17 the section of the CFR that relates to commercial and industrial 

equipment, such as MHLFs. DOE’s research indicated that there are a number of 

applications, such as outdoor sports lighting and airfield lighting, which commonly use 

MH ballasts of 1000 W to 2000 W and provide general illumination to an exterior area. 

In the NOPR, DOE proposed that such applications are general lighting applications and 

are covered by this rulemaking.

ULT, NEMA, GE, Musco Lighting stated that all MHLFs above 1000 W have 

limited operating hours and are for specialty applications, not general lighting. (ULT, No. 

17 The general lighting application definition prescribed by EISA 2007 was previously incorporated into the 

consumer products section (10 CFR Part 430), but has not yet been added to the commercial and industrial 

equipment section (10 CFR Part 431).

44 

 
50 at pp. 2-3; NEMA, No. 56 at pp. 6-7; GE, Public Meeting Transcript, No. 48 at p. 115; 

Musco Lighting, Public Meeting Transcript, No. 48 at p. 118) Earthjustice commented 

that the definition of “general lighting” refers to overall illumination of an interior or 

exterior area, not to the hours of use of an application. Therefore, Earthjustice stated that 

these higher-wattage lamps that serve applications such as sports lighting, parks, and 

airfields that provide overall illumination to exterior areas should not be considered niche 

equipment. (Earthjustice, Public Meeting Transcript, No. 48 at pp. 171, 174)

DOE agrees that the higher wattages fall under the CFR definition of general 

lighting. As mentioned previously, DOE also acknowledges that these lamps have limited 

operating hours and used these hours of use to calculate their energy savings potential. 

However, DOE does not believe that low operating hours impacts whether high wattage 

MHLFs are used in general lighting applications. DOE has determined that sports 

lighting is a general lighting application because it is “lighting that provides an interior or 

exterior area with overall illumination.” In this final rule, DOE adopts this definition for 

general lighting application in 10 CFR 431.2.

4. High-Frequency Electronic Ballasts

Electronic ballasts can be separated into two main types, low-frequency electronic 

(LFE) and high-frequency electronic (HFE). HFE ballasts are electronic ballasts with 

frequencies greater than or equal to 1000 hertz (Hz). DOE received comment that HFE 

ballasts should not be included in the scope of coverage based on compatibility issues and 

the lack of test procedure (DOE’s proposed test procedure is discussed in section IV.A).

45 
Venture and NEMA commented that there are no ANSI standards for the HFE 

ballasts that may be required to meet the analyzed standard levels, and therefore there 

will be limited MH lamps for use with these ballasts for a substantial period of time. 

(Venture, Public Meeting Transcript, No. 48 at p. 29; NEMA, No. 56 at p. 9) NEMA 

elaborated that many MH lamps are not compatible with existing HFE ballasts because of 

variation in arc tube size and shape. Due to this variation, HFE acoustic resonances can 

cause arc instability or even lamp failure. (NEMA, No. 44 at p. 6) NEMA specifically 

noted that high-frequency electronic ballasts are incompatible with the most efficacious 

lamps (ceramic metal halide). A standard that requires high frequency electronic ballasts 

could reduce overall energy savings because these ballasts are not compatible with the 

most efficacious MH lamps. (NEMA, No. 56 at p. 9) Furthermore, a standard that 

eliminates ballasts capable of operating ceramic metal halide lamps would be a violation 

of EPCA section 325(o)(4) which prohibits DOE from adopting a standard that interested 

parties have demonstrated results in the elimination of product features from the market. 

(NEMA, No. 44 at pp. 6-7) NEMA stated that industry standards for high frequency 

ballasts and lamps have only just begun to be developed and without these standards 

there will continue to be limited compatibility between high frequency ballasts and lamps 

(NEMA, No. 44 at p. 7). Even when acceptable frequency ranges are found, NEMA 

commented that HFE ballasts can also cause electrode back arcing, leading to shortened 

lamp life. (NEMA, No. 44 at p. 6)

As in the NOPR, DOE recognizes there are compatibility issues associated with 

HFE ballasts and some MH lamps, in particular ceramic metal halide (CMH) lamps. A 

standard that requires HFE ballasts could result in a full or partial elimination of CMH 

46 
lamps from the market due to these compatibility issues. The elimination of CMH lamps 

could increase energy usage, as CMH lamps are some of the most efficacious MH lamps 

on the market. In the NOPR, DOE indicated it would take compatibility issues with HFE 

ballasts into account when selecting the eventual adopted standard of today’s final rule. 

However, as detailed in section IV.A of this notice, DOE has not adopted a test procedure 

for HFE ballast, based on the lack of an industry consensus test method for this ballast 

type. DOE has found that in the absence of an applicable test method for these lamps, 

HFE ballasts cannot be subject to energy conservation standards. Therefore, DOE has not 

included HFE ballasts in the scope of coverage of this rulemaking.

5. Outdoor Fixtures

In the NOPR, DOE included both indoor and outdoor MHLFs in the scope of 

coverage because DOE determined that standards for both types of fixtures were 

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

savings. Because DOE concluded that indoor and outdoor fixtures had different costefficiency relationships, DOE analyzed them in separate equipment classes.

The American Public Power Association (APPA) noted that separating the 

outdoor and indoor lamps or exempting outdoor lamps is necessary because the usage 

patterns of outdoor lamps differ immensely from indoor. As the circumstances are 

different when considering both classes, APPA furthered, it is difficult to understand the 

effects of proposed efficiency standards on each group. APPA also noted that it may 

make sense to exempt outdoor fixtures from energy conservation standards because the 

47 
electronic ballasts will have difficulty in extreme weather conditions. APPA, No. 51 at p. 

4; APPA, Public Meeting Transcript, No. 48 at p. 103)

As mentioned previously, in the NOPR DOE determined that standards for both 

types of fixtures were technologically feasible, economically justified, and would result 

in significant energy savings. This conclusion is reaffirmed by the analysis in the final 

rule and DOE therefore includes both indoor and outdoor fixtures in the scope of 

coverage for this rulemaking. DOE agrees with analyzing outdoor and indoor fixtures 

separately by placing indoor and outdoor MHLFs into separate equipment classes. While 

the efficiencies achievable by indoor and outdoor fixtures are the same, the different costs 

affect the resultant cost-efficiency curves. See section V.A.2 of this notice for details on 

the equipment classes.

6. Hazardous Locations

Although DOE did not consider exempting fixtures designed for use in hazardous 

locations in the NOPR, NEMA commented that these fixtures need to be exempt from 

energy conservation standards. As these fixtures are used in potentially explosive 

atmospheres and listed to Underwriters Laboratories Inc. standard (UL) 844, any change 

in ballast size would require the fixture to be redesigned and re-tested, creating a 

tremendous burden on manufacturers. This is because the redesign, retesting, and 

relisting of these MHLFs would take significantly longer than three years, and leave this 

equipment type unavailable for an extended period of time. This would result in serious 

safety concerns until these fixture types were available again. NEMA also finds it would 

be very difficult for manufacturers to recoup the investment in standards-induced 

48 
efficiency improvement for these types of MHLFs due to their limited market. Therefore, 

NEMA suggested that hazardous location fixtures should be granted an exemption from 

the rulemaking. (NEMA, No. 56 at p. 14)

As discussed in section V.C.8, the standard levels analyzed in this rulemaking do 

not require an increase in ballast size. Therefore, DOE does not believe hazardous 

location fixtures would need to be modified due to a change in ballast size. DOE notes 

that the vast majority of hazardous location fixtures are specified for use with magnetic 

ballasts. Therefore, DOE investigated existing fixtures, and the requirements of UL 844, 

to determine whether higher standards for ballasts, specifically those that require 

electronic ballast technology, would cause existing hazardous location fixtures to be 

redesigned and/or retested. After reviewing the UL 844 requirements, DOE found no 

constraints that would specifically or effectively preclude the use of electronic ballasts. 

Instead, UL 844 contains explosion protection requirements for a luminaire, including 

requirements that no part of the fixture reach the thermal ignition temperature of a 

particulate or gas in the environment. DOE’s survey of existing hazardous location 

fixtures found that these fixtures are commonly rated for use with a type of MH ballast 

and specific wattage. For example, a hazardous location fixture may be rated for use with 

a magnetic MH ballast of a given wattage (e.g., a 750 W magnetic MH ballast). Most 

hazardous location fixtures that are currently available are certified for use with magnetic 

ballasts, with offerings at a variety of wattages.18 DOE only identified one hazardous 

18 While not comprehensive, DOE identified hazardous location fixtures certified for use with magnetic 

ballasts that operate lamps with rated wattages between 150 W and 750 W. 

49 

 
location fixture that was rated for use with electronic ballasts (in this case, a 150 W 

electronic ballast). DOE was unable to confirm that hazardous location fixtures 

compatible with electronic ballasts were available at the same wattages as hazardous 

location fixtures compatible with magnetic ballasts that are currently offered on the 

market. However, as discussed in section VII.C, DOE is not adopting standards that are 

expected to require the use of electronic ballast technology. Therefore, DOE does not 

believe the adopted standards in this rulemaking will require hazardous location fixtures 

to be redesigned and retested and does not exempt them from the standards adopted in 

this final rule. 

7. Summary of MHLFs for Which DOE is Setting Standards

EISA 2007 established energy conservation standards for MHLFs with ballasts 

designed to operate lamps with rated wattages between 150 W and 500 W. As previously 

discussed, EISA 2007 also exempted three types of fixtures within the covered wattage 

range from energy conservation standards. In this final rule, DOE extends coverage to 

MHLFs with ballasts designed to operate lamps rated 50 W – 150 W and 501 W – 1000 

W. DOE also includes one type of previously exempt fixture in the scope of coverage: 

150 W MHLFs rated for use in wet locations and containing a ballast that is rated to

operate at ambient air temperatures greater than 50 °C. DOE continues to exempt 

regulated-lag ballasts and 480 V electronic ballasts. For all ballasts included in the scope 

of coverage, DOE has determined that energy conservation standards are technologically 

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

DOE adopts standards for these MHLFs in this final rule.

Comment [AGA7]: Change requested by OIRA.

50 
B. Alternative Approaches to Energy Conservation Standards: System Approaches

As discussed in the NOPR, DOE considered several alternatives to establishing 

energy conservation standards for MHLFs by regulating the efficiency of the ballast 

contained within the fixture. Specifically, DOE considered a lamp-and-ballast system 

metric, fixture-level metrics, and the compliance paths specified in California’s Title 20 

regulations. (which are now preempted by federal energy conservation standards in 10 

CFR 431.326, 74 FR 12058; March 23, 2009). DOE concluded that, after considering all 

of these alternate approaches, maintaining the EISA 2007 approach of regulating MHLFs 

by specifying a minimum ballast efficiency was the most widely accepted, least 

burdensome approach that would ensure energy conservation standards resulted in energy 

savings. Therefore, in the NOPR DOE proposed standards for MHLFs by requiring that 

MHLFs contain ballasts that comply with minimum specified efficiencies. NEMA 

agreed, citing the increased testing burden associated with testing every combination of 

lamp and ballast sold in a fixture, and recognizing that the majority of MHLFs are not 

shipped with a lamp. (NEMA, No. 56 at p. 8) Receiving no comment to the contrary, 

DOE maintains this approach in this final rule.

C. Standby Mode and Off Mode Energy Consumption 

EPCA requires energy conservation standards adopted for covered equipment after 

July 1, 2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) 

The requirement to incorporate standby mode and off mode energy use into the energy 

conservation standards analysis is therefore applicable in this rulemaking.

Comment [AGA8]: Change requested by OIRA.

51 
DOE determined that it is not possible for MHLFs to meet off mode criteria 

because there is no condition in which the components of an MHLF are connected to the 

main power source and are not already in a mode accounted for in either active or 

standby mode. DOE recognizes that MHLFs could be designed with auxiliary control 

devices that could consume energy in standby mode. However, DOE has yet to encounter 

such a control device design, or other type of MHLF that uses energy in standby mode, 

on the market. Therefore, in the NOPR DOE concluded that it cannot establish a standard 

that incorporates standby mode or off mode energy consumption. Receiving no comment 

to the contrary, DOE maintains this conclusion in the final rule and does not include 

standby mode or off mode energy consumption in the standards adopted in this final rule.

IV. General Discussion

A. Test Procedures

1. Current Test Procedures

The current test procedures for MH ballasts and MHLFs are outlined in Subpart S 

of 10 CFR Part 431. The test conditions, setup, and methodology generally follow the 

guidance of ANSI C82.6-2005. Testing requires the use of a reference lamp, which is to 

be driven by the ballast under test conditions until the ballast reaches operational 

stability. Ballast efficiency for the fixture is then calculated as the measured ballast 

output power divided by the ballast input power. In the NOPR, DOE considered changes 

to the test procedure regarding input voltage, the testing of HFE ballasts, and rounding 

requirements.

52 
2. Test Input Voltage

MH ballasts can be operated at a variety of voltages. The most common voltages 

are 120 V, 208 V, 240 V, 277 V, and 480 V. Ballasts will also commonly be rated for 

more than one voltage, such as dual-input-voltage ballasts that can be operated at 120 V 

or 277 V, or quad-input-voltage ballasts that can be operated at 120 V, 208 V, 240 V, or 

277 V. Through manufacturer feedback and testing, DOE found that the specific design 

of a ballast and the voltage of the lamp operated by the ballast can affect the trend 

between input voltage and efficiency.

The existing test procedures do not specify the voltage at which a ballast is to be 

tested, and the majority of ballasts sold are capable of operating at multiple input 

voltages. Therefore, to ensure consistency among testing and reported efficiencies, DOE 

considered methods of standardizing this aspect of testing in the NOPR.

a. Average of Tested Efficiency at All Possible Voltages

One method analyzed in the NOPR was testing ballasts at each input voltage at 

which they are able to operate, and then having a standard for the average of these 

efficiencies. As averaging the efficiencies could misrepresent the performance of the 

ballast in its common uses and could increase the testing burden, in the NOPR, DOE did 

not propose this method. Having received no comments to the contrary, DOE continues 

to reject using the average of tested efficiency at all possible voltages in this final rule.

53 
b. Posting the Highest and Lowest Efficiencies

A second approach considered in the NOPR was requiring testing at each input 

voltage and listing the best and worst efficiencies on the MHLF label. DOE found that, 

similar to averaging efficiencies, this approach would increase the compliance testing 

burden for manufacturers compared to a requirement to test ballasts only at a single 

voltage. Therefore, DOE did not propose this method. Having received no comments to 

the contrary, DOE continues to reject the posting of the highest and lowest efficiencies on 

an MHLF label in this final rule.

c. Test at Single Manufacturer-Declared Voltage

A third approach considered in the NOPR was that the test procedures should 

allow testing at a single voltage determined by the manufacturer and declared in the test 

report. DOE concluded that this approach would not be favorable as the efficiency at the 

manufacturer-declared voltage and the efficiency at the more commonly used voltages 

may not be the same, and as such could potentially reduce the energy savings of this 

rulemaking. Thus, DOE did not propose to test ballast efficiency at a single 

manufacturer-declared voltage.

GE agreed that a multi-tap ballast should be tested at just one input voltage. 

Rather than testing at the designated highest voltage, GE stated that it should be up to the 

manufacturer to choose the voltage at which the ballast was optimally designed for 

purposes of reporting efficiencies. (GE, Public Meeting Transcript, No. 48 at p. 83)

54 
DOE agrees with testing multi-tap ballasts at a single voltage. DOE’s position 

against allowing manufacturers to declare their testing input voltage stems from concerns 

that manufacturers could optimize efficiency at a voltage that is most convenient or least 

expensive, rather than the voltage most commonly used by customers. If optimal 

efficiency is achieved at a less commonly used voltage, the reported ballast efficiency 

would not be representative of the ballast efficiency in the ballast’s more common 

applications. If the efficiency at the tested voltage and at the most commonly used 

voltage are not directly correlated, energy savings could potentially be reduced. For these 

reasons, DOE rejects the proposal to allow manufacturers to select the voltage at which 

ballasts are tested in this final rule.

d. Test at Highest Rated Voltage

Another input voltage specification that DOE considered was testing the ballast at 

the highest voltage possible. However, DOE concluded that a ballast’s highest rated 

voltage is not always its most common input voltage, and therefore testing and enforcing 

standards at the highest voltage could reduce the potential energy savings of this 

rulemaking. Accordingly, in the NOPR DOE did not propose to test ballast efficiency at 

the highest rated voltage. Having received no comments to the contrary, DOE continues 

to reject testing at the highest rated voltage in this final rule.

e. Test on Input Voltage Based on Wattage and Available Voltages

The final approach analyzed was testing the most common input voltages for each 

wattage range. This meant, when possible, ballasts less than 150 W are tested at 120 V, 

ballasts greater than or equal to 150 W are tested at 277 V, and if those specified voltages 

55 
are unavailable, the ballast is tested at the highest available voltage. DOE concluded that 

because this proposal only requires testing at one input voltage, it minimizes testing 

burden. In addition, because the input voltage specification matches the most commonly 

used voltage, the requirement encourages optimization of efficiency around an input 

voltage commonly used in practice.

NEMA and ULT agreed with DOE’s NOPR proposals regarding the input voltage 

for testing. (NEMA, No. 56 at p. 8; ULT, No. 50 at p. 4) Having received no comments 

to the contrary, in this final rule, DOE amends the test procedure to require that ballasts 

be tested at the following input voltages:

• For ballasts less than 150 W with an available voltage of 120 V, ballasts will be 

tested at 120 V.

• For ballasts less than 150 W that lack 120 V as an available voltage, ballasts will 

be tested at the highest available input voltage.

• For ballasts operated at 150 W – 2000 W that also have 277 V as an available 

input voltage, ballasts will be tested at 277 V.

• For ballasts operated at 150 W – 2000 W that lack 277 V as an available input 

voltage, ballasts will be tested at the highest available input voltage.

3. Testing High-frequency Electronic Ballasts

MHLF test procedures reference the 2005 version of ANSI C82.6 for testing both 

electronic and magnetic MH ballasts. However, ANSI C82.6-2005 does not provide a 

method for testing HFE ballasts. In the NOPR, DOE found that the instrumentation 

commonly used for HFE MH ballast testing is the same instrumentation used for 

56 
electronic fluorescent lamp ballast testing. Therefore, DOE proposed the same 

instrumentation used in electronic fluorescent lamp ballast testing be used for testing 

HFE MH ballasts. These proposed requirements specified that once the output frequency 

of a MH ballast is determined to be greater than or equal to 1000 Hz (the frequency at 

which DOE defines HFE ballasts) the test procedure instrumentation would be required 

to include a power analyzer that conforms to ANSI C82.6-2005 with a maximum of 100 

picofarads (pF) capacitance to ground and a frequency response between 40 Hz and 1 

MHz. The test procedures would also require a current probe compliant with ANSI 

C82.6-2005 that is galvanically isolated and has a frequency response between 40 Hz and

20 MHz, and lamp current measurement where the full transducer ratio is set in the power 

analyzer to match the current to the analyzer. The full transducer ratio would be required 

to satisfy the following equation:

Iin

Vout

 × 

Rin

Rin + Rs

Where:

 Iin is current through the current transducer;

 Vout is the voltage out of the transducer;

 Rin is the power analyzer impedance; and

 Rs is the current probe output impedance.

DOE received comment on the lack of compatibility standards between HFE 

ballasts and MH lamps. NEMA commented that no work has begun on the ANSI C82.6 

test procedure standard for HFE ballasts. (NEMA, No. 44 at p. 7) Philips noted that as 

HFE ballasts do not have testing standards, measurement errors and testing differences 

57 
could lead to false efficiency values. (Philips, Public Meeting Transcript, No. 48 at p. 70) 

Similarly, NEMA stated that lack of industry testing standard meant efficiencies are 

computed using internal test procedures. Therefore, using catalog data gathered from 

more than one manufacturer combines different test procedures. (NEMA, Public Meeting 

Transcript, No. 48 at p. 31; NEMA, No. 44 at p. 8) NEMA also noted that labs cannot be 

accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) to 

submit HFE ballast testing to DOE without a test procedure to accredit to. (NEMA, No. 

56 at p. 9) Further, NEMA noted that it is difficult to precisely measure the power of 

these HFE ballasts at frequencies over 100 kHz, which experience a 2-5 percent 

measurement uncertainty. With a tenth of a percentage precision on ballast efficiency, it 

will be very difficult to attain these levels of measurement. (NEMA, Public Meeting 

Transcript, No. 48 at p. 30; NEMA, No. 44 at p. 8)

DOE agrees that there are no industry test procedures for HFE ballasts. While the 

addition of instrumentation requirements addresses some concerns, specifications for 

lamps to be paired with the ballast during testing and a complete test method specific to 

HFE ballasts (an equivalent document to ANSI C82.6 – which covers magnetic ballasts 

and LFE ballasts, but not HFE ballasts) are not currently available. Therefore, in this final 

rule, DOE is not adopting any changes to the test procedure for HFE ballasts. As 

discussed in section III.A.4 of this notice, DOE is not considering standards for HFE 

ballasts because a test procedure for HFE ballasts does not exist.

58 
4. Rounding Requirements

Through testing, DOE found that testing multiple samples of the same ballast 

yielded a range of ballast efficiencies typically differing by less than one percent. 

Because this data introduces both test measurement and sample to sample variation, the 

test measurement itself should be at least this accurate. Therefore, DOE came to the 

conclusion that test procedures can resolve differences of less than one percent and 

rounding to the tenths of a percent would be reasonable. In the NOPR, DOE proposed 

amending the MH ballast test procedure for measuring and recording input wattage and 

output wattage to require rounding to the nearest tenth of a watt, and the resulting 

calculation of efficiency to the nearest tenth of a percent.

ULT, EEI, and NEMA commented that most test equipment for MHLFs is not 

calibrated to the proposed level of precision. ANSI standards require wattmeters to have 

0.5 percent accuracy. (ULT, Public Meeting Transcript, No. 48 at p. 82; EEI, Public 

Meeting Transcript, No. 48 at p. 85; NEMA, No. 44 at p. 13). Further, NEMA noted that 

white paper NEMA LSD-63-2012 on variability estimated the tolerance for a sample of 

four magnetic ballasts to be 4.7 percent when 99 percent confidence factor is required. 

(NEMA, No. 56 at p. 8) On the contrary, CA IOUs commented that efficiency 

measurement equipment accurate to plus or minus 0.5 percent is already capable of 

measuring efficiency to the nearest watt for lamps of 100 W and above, and the nearest 

tenth of a watt for lamps below 100 W. CA IOUs argued this supports tenths place 

rounding of an efficiency figure and setting of standards to the tenth of a percent. (CA 

IOUs, No. 54 at pp. 2-3). Finally, EEI commented that if the difference between EL1 and 

59 
EL2 is 0.6 percent, and there is a testing tolerance of plus or minus 1 percent, there could 

be a classing issue. (EEI, Public Meeting Transcript, No. 48 at p. 159). 

DOE reviewed ANSI C82.6-2005 and found that the instrumentation 

requirements stipulate that watts be measured with 3.5 digits of resolution, with basic

accuracy of 0.5 percent. For an efficiency calculation that involves output power divided 

by input power, 3.5 digits of resolution allows for rounding efficiency to three significant 

figures (e.g., 0.895 or 89.5 percent) using only three digits. DOE also notes that some 

manufacturers have submitted compliance data to DOE’s certification, compliance, and 

enforcement (CCE) database rounded to three significant figures and, in response to the 

NOPR, manufacturers had responded to certain issues using efficiency data rounded to 

three significant figures. Both of these suggest that manufacturers already have the 

capability to accomplish these measurements. DOE also considered LSD-63, as 

suggested by NEMA, but found that it details the population distribution from all sources 

of variation and did not find that it provides any information regarding the ability to 

measure the efficiency of an individual ballast to three significant figures. For these 

reasons, this final rule amends the test procedure to require measuring and calculating 

ballast efficiency to three significant figures. DOE also adopts energy conservation 

standards that are specified to three significant figures. 

B. Technological Feasibility

1. General

In each standards rulemaking, DOE conducts a screening analysis based on 

information gathered on all current technology options and prototype designs that could 

60 
improve the efficiency of the equipment that is the subject of the rulemaking. As the first 

step in such an analysis, DOE develops a list of technology options for consideration in 

consultation with manufacturers, design engineers, and other interested parties. DOE then 

determines which of those means for improving efficiency are technologically feasible. 

DOE considers technologies incorporated in commercially available equipment or in 

working prototypes to be technologically feasible. 10 CFR 430, subpart C, appendix A, 

section 4(a)(4)(i).

After DOE has determined that particular technology options are technologically 

feasible, it further evaluates each technology option in light of the following additional 

screening criteria: (1) practicability to manufacture, install, or service; (2) adverse 

impacts on equipment utility or availability; and (3) adverse impacts on health or safety. 

Section V.B of this notice discusses the results of the screening analysis for MHLFs, 

particularly the designs DOE considered, those it screened out, and those that are the 

basis for the TSLs in this rulemaking. For further details on the screening analysis for this 

rulemaking, see chapter 4 of the final rule TSD.

2. Maximum Technologically Feasible Levels

When DOE adopts a new or amended standard for a type or class of covered 

equipment, it must determine the maximum improvement in energy efficiency or 

maximum reduction in energy use that is technologically feasible for such equipment. (42 

U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the 

maximum technologically feasible (“max-tech”) improvements in energy efficiency for 

MHLFs, using the design parameters for the most efficient equipment available on the 

61 
market or in working prototypes. For MHLFs from 50 – 500 W, the max-tech fixtures use 

high-grade electronic ballasts. For MHLFs from 501 – 2000 W, the max-tech fixtures use 

magnetic ballasts that incorporate high-grade, grain-oriented steel (M619). (See chapter 5 

of the final rule TSD for additional detail.) The max-tech levels that DOE determined for 

this rulemaking are listed in Table IV.1. 

Table IV.1 Max-Tech Levels

Equipment Class 

Wattage Range Efficiency Level* Efficiency-Level Equation†

% 

≥50 and ≤100 EL4 1/(1+0.360∗×P^(-0.297))

>100 and <150* EL4 1/(1+0.360∗×P^(-0.297))

≥150** and ≤250 EL4 1/(1+0.360∗×P^(-0.297))

>250 and ≤500 EL4 1/(1+0.360∗×P^(-0.297))

>500 and ≤1000 EL2 For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 0.000104*×P+0.832

>1000 and ≤2000 EL2 0.936

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; 

rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

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

C. Energy Savings

1. Determination of Savings

For each TSL, DOE projected energy savings from the products that are the 

subject of this rulemaking purchased in the 30-year period that begins in the year of 

compliance with new and amended standards (2017–2046). The savings are measured 

19 The American Iron and Steel Institute type numbers and AK Steel designations for electrical steel grades 

consist of the letter M followed by a number. The M stands for magnetic material; the number is 

representative of the core loss of that grade.

Comment [AGA9]: Change requested by OIRA.

62 

 
over the entire lifetime of equipment purchased in the 30-year period.20 DOE quantified 

the energy savings attributable to each TSL as the difference in energy consumption 

between each standards case and the base case. The base case represents a projection of 

energy consumption in the absence of new or amended mandatory efficiency standards, 

and considers market forces and policies that affect demand for more efficient equipment. 

For example, in the base case, DOE models a migration from covered metal halide lamp 

fixtures to higher efficiency technologies such as high-intensity fluorescent (HIF), 

induction lights, and LEDs. DOE also models a move to other HID fixtures such as highpressure sodium, based on data given by manufacturers during the 2010 Framework 

public meeting. (Philips, Public Meeting Transcript, No.8 at p. 91)

DOE used its NIA spreadsheet model to estimate energy savings from new and 

amended standards for the metal halide lamp fixtures that are the subject of this 

rulemaking. The NIA spreadsheet model (described in section V.G of this notice) 

calculates energy savings in site energy, which is the energy directly consumed by 

products at the locations where they are used. For electricity, DOE reports national 

energy savings in terms of the savings in the energy that is used to generate and transmit 

the site electricity. To calculate this quantity, DOE derives annual conversion factors 

from the model used to prepare the Energy Information Administration’s (EIA) Annual 

Energy Outlook 2013 (AEO2013). 

20 In the past DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings 

measured over the entire lifetime of equipment purchased in the 30-year period. DOE has chosen to modify 

its presentation of national energy savings to be consistent with the approach used for its national economic 

analysis.

63 

 
DOE has begun to also estimate full-fuel-cycle energy savings. 76 FR 51282 

(August 18, 2011), as amended at 77 FR 49701 (August 17, 2012). The full-fuel-cycle 

(FFC) metric includes the energy consumed in extracting, processing, and transporting 

primary fuels, and thus presents a more complete picture of the impacts of energy 

efficiency standards. DOE’s evaluation of FFC savings is driven in part by the National 

Academy of Science’s (NAS) report on FFC measurement approaches for DOE’s 

Appliance Standards Program.21 The NAS report discusses that FFC was primarily 

intended for energy efficiency standards rulemakings where multiple fuels may be used 

by a particular product. In the case of this rulemaking pertaining to metal halide lamp 

fixtures, only a single fuel—electricity—is consumed by the equipment. DOE’s approach 

is based on the calculation of an FFC multiplier for each of the energy types used by 

covered equipment. Although the addition of FFC energy savings in the rulemakings is 

consistent with the recommendations, the methodology for estimating FFC does not 

project how fuel markets would respond to this particular standards rulemaking. The FFC 

methodology simply estimates how much additional energy, and in turn how many tons 

of emissions, may be displaced if the estimated fuel were not consumed by the equipment 

covered in this rulemaking. It is also important to note that inclusion of FFC savings does 

not affect DOE’s choice of adopted standards.

21 “Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building 

Appliance Energy- Efficiency Standards,’’ (Academy report) was completed in May 2009 and included 

five recommendations. A copy of the study can be downloaded at: 

www.nap.edu/catalog.php?record_id=12670.

64 

 
2. Significance of Savings

As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard 

for covered equipment unless such standard would result in “significant” energy savings. 

Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, in 

Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), 

indicated that Congress intended “significant” energy savings in this context to be 

savings that were not “genuinely trivial.” The energy savings for all of the TSLs 

considered in this rulemaking (presented in section VII.B.3.a) are nontrivial, and, 

therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.

D. Economic Justification

1. Specific Criteria

EPCA provides seven factors to be evaluated in determining whether a potential 

energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The 

following sections discuss how DOE has addressed each of those seven factors in this 

rulemaking.

a. Economic Impact on Manufacturers and Customers 

In determining the impacts of an amended standard on manufacturers, DOE first 

uses an annual cash-flow approach to determine the quantitative impacts. This step 

includes both a short-term assessment—based on the cost and capital requirements during 

the period between when a regulation is issued and when entities must comply with the 

65 
regulation—and a long-term assessment over a 30-year period.22 The industry-wide 

impacts analyzed include INPV, which values the industry on the basis of expected future 

cash flows; cash flows by year; changes in revenue and income; and other measures of 

impact, as appropriate. Second, DOE analyzes and reports the impacts on different types 

of manufacturers, including impacts on small manufacturers. Third, DOE considers the 

impact of standards on domestic manufacturer employment and manufacturing capacity, 

as well as the potential for standards to result in plant closures and loss of capital 

investment. Finally, DOE takes into account cumulative impacts of various DOE 

regulations and other regulatory requirements on manufacturers.

For individual customers, measures of economic impact include the changes in 

LCC and payback period (PBP) associated with new or amended standards. These 

measures are discussed further in the following section. For customers in the aggregate, 

DOE also calculates the national net present value of the economic impacts applicable to 

a particular rulemaking. DOE also evaluates the LCC impacts of potential standards on 

identifiable subgroups of customers that may be affected disproportionately by a national 

standard.

b. Savings in Operating Costs Compared to Increase in Price

EPCA requires DOE to consider the savings in operating costs throughout the 

estimated average life of the covered equipment compared to any increase in the price of 

22 DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.

66 

 
the covered equipment that are likely to result from the imposition of the standard (42 

U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis. 

The LCC is the sum of the purchase price of equipment (including its installation) 

and the operating expense (including energy, maintenance, and repair expenditures) 

discounted over the lifetime of the equipment. To account for uncertainty and variability 

in specific inputs, such as equipment lifetime and discount rate, DOE uses a distribution 

of values, with probabilities attached to each value. For its analysis, DOE assumes that 

consumers will purchase the covered products in the first year of compliance with 

amended standards. 

The LCC savings and the PBP for the considered ELs are calculated relative to a 

base case that reflects projected market trends in the absence of amended standards. DOE 

identifies the percentage of customers estimated to receive LCC savings or experience an 

LCC increase, in addition to the average LCC savings associated with a particular 

standard level. 

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement 

for imposing an energy conservation standard, EPCA requires DOE, in determining the 

economic justification of a standard, to consider the total projected energy savings that 

are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As 

discussed in section V.G, DOE uses the NIA spreadsheet to project national site energy 

savings.

67 
d. Lessening of Utility or Performance of Equipment

In establishing classes of equipment, and in evaluating design options and the 

impact of potential standard levels, DOE evaluates standards that would not lessen the 

utility or performance of the considered equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) The 

standards adopted in today’s final rule will not reduce the utility or performance of the 

equipment under consideration in this rulemaking. One piece of evidence for this claim 

includes that magnetic ballast ELs are allowed for every covered MHLF wattage and 

application, meaning that manufacturers are not required to change the electronic 

configuration of their current offerings. A second piece of evidence is that commercially 

available stack height and footprint is being maintained for all ballasts, resulting in no 

required change from current MHLF size. Another piece of evidence is that no standards 

were adopted for MHLFs greater than 1000 W, so that all commercially available 

MHLFs at such wattages are subjected to no mandatory adjustments. Overall, the adopted 

standards were selected to protect the interest of customers and do not lessen MHLF 

performance or utility.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as 

determined in writing by the Attorney General, that is likely to result from the imposition 

of a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to 

determine the impact, if any, of any lessening of competition likely to result from a 

standard and to transmit such determination to the Secretary within 60 days of the 

publication of a proposed rule, together with an analysis of the nature and extent of the 

68 
impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE transmitted a copy of its proposed rule to the 

Attorney General with a request that the Department of Justice (DOJ) provide its 

determination on this issue. DOE addresses the Attorney General’s determination in this 

final rule.

f. Need for National Energy Conservation

The energy savings from new and amended standards are likely to provide 

improvements to the security and reliability of the nation’s energy system. Reductions in 

the demand for electricity also may result in reduced costs for maintaining the reliability 

of the nation’s electricity system. DOE conducts a utility impact analysis to estimate how 

standards may affect the nation’s needed power generation capacity. 

The new and amended standards also are likely to result in environmental benefits 

in the form of reduced emissions of air pollutants and greenhouse gases associated with 

energy production. DOE reports the emissions impacts from today’s standards, and from 

each TSL it considered, in section VII.B.6 of this notice. DOE also reports estimates of 

the economic value of emissions reductions resulting from the considered TSLs.

g. Other Factors

EPCA allows the Secretary of Energy, in determining whether a standard is 

economically justified, to consider any other factors that the Secretary deems to be 

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

69 
2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable 

presumption that an energy conservation standard is economically justified if the 

additional cost to the customer of equipment that meets the standard is less than three 

times the value of the first year’s energy savings resulting from the standard, as 

calculated under the applicable DOE test procedure. DOE’s LCC and PBP analyses 

generate values used to calculate the effect potential amended energy conservation 

standards would have on the payback period for customers. These analyses include, but 

are not limited to, the 3-year payback period contemplated under the rebuttablepresumption test. In addition, DOE routinely conducts an economic analysis that 

considers the full range of impacts to customers, manufacturers, the nation, and the 

environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis 

serve as the basis for DOE’s evaluation of the economic justification for a potential 

standard level (thereby supporting or rebutting the results of any preliminary 

determination of economic justification). The rebuttable-presumption payback calculation 

is discussed in section VII.B.1 of this final rule.

V. Methodology and Discussion

DOE used two spreadsheets to estimate the impact of the adopted standards. The 

first spreadsheet calculates LCCs and PBPs of potential new energy conservation 

standards. The second provides shipments forecasts and then calculates national energy 

savings and NPV impacts of new energy conservation standards. The Department also 

70 
assessed manufacturer impacts, largely through use of the Government Regulatory 

Impact Model (GRIM).

Additionally, DOE uses a version of EIA’s National Energy Modeling System 

(NEMS) to estimate the impacts of energy efficiency standards on electric utilities and 

the environment. The NEMS model simulates the energy sector of the U.S. economy. 

The version of NEMS used for appliance standards analysis is called NEMS-BT (BT 

stands for DOE’s Building Technologies Program), and is based on the AEO2013 version 

of NEMS with minor modifications.23 The NEMS-BT accounts for the interactions 

between the various energy supply and demand sectors and the economy as a whole. For 

more information on NEMS, refer to The National Energy Modeling System: An 

Overview, DOE/EIA–0581 (98) (Feb.1998), available at: 

tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf. 

As a basis for this final rule, DOE has continued to use the approaches explained 

in the NOPR. DOE used the same general methodology as applied in the NOPR, but 

revised some of the assumptions and inputs for the final rule in response to public 

comments. The following sections discuss these revisions.

23 The EIA does not approve use of the name “NEMS” unless it describes an AEO version of the model 

without any modification to code or data. Because the present analysis entails some minor code 

modifications and runs the model under various policy scenarios that deviate from AEO assumptions, the 

name “NEMS-BT” refers to the model as used here.

71 

 
A. Market and Technology Assessment

1. General

When completing an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the equipment concerned, 

including the purpose of the equipment, the industry structure, and the market 

characteristics. This activity includes both quantitative and qualitative assessments based 

on publicly available information. The subjects addressed in the market and technology 

assessment for this rulemaking include: equipment classes and manufacturers; historical 

shipments; market trends; regulatory and non-regulatory programs; and technologies or 

design options that could improve the energy efficiency of the equipment under 

examination. See chapter 3 of the final rule TSD for further discussion of the market and 

technology assessment.

2. Equipment Classes

When evaluating and establishing energy conservation standards, DOE divides 

covered equipment into equipment classes by the type of energy used or by capacity or 

other performance-related features that justifies a different standard. In making a 

determination whether a performance-related feature justifies a different standard, DOE 

must consider such factors as the utility to the customer of the feature and other factors

DOE determines are appropriate. (42 U.S.C. 6295(q)) DOE then considers separate 

standard levels for each equipment class based on the criteria set forth in 42 U.S.C. 

6295(o). In the NOPR, DOE proposed to divide equipment classes by input voltage, rated 

lamp wattage, and designation for indoor versus outdoor applications.

72 
a. Input Voltage

MHLFs are available in a variety of input voltages (most commonly 120 V, 208 

V, 240 V, 277 V, and 480 V), and the majority of fixtures are equipped with ballasts that 

are capable of operating at multiple input voltages (for example, quad-input-voltage 

ballasts are able to operate at 120 V, 208 V, 240 V, and 277 V). DOE determined that 

input voltage represents a feature affecting consumer utility as certain applications 

demand specific input voltages. DOE’s ballast testing did not indicate a prevailing 

relationship (e.g., higher voltages are not always more efficient) between discrete input 

voltages and ballast efficiencies, with one exception. In the NOPR, DOE found that 

ballasts tested at 480 V were less efficient on average than ballasts tested at 120 V or 277 

V.

As discussed in section IV.A of this final rule, MH ballasts will be tested at a 

single input voltage based on the lamp wattage operated by the ballast. Ballasts that 

operate lamps less than 150 W shall be tested at 120 V, and all others shall be tested at 

277 V, unless the ballast is incapable of operating at the specified input voltage; in that 

case, the ballast shall be tested at the highest input voltage possible. Because dedicated 

480 V ballasts have a distinct utility in that certain applications require 480 V operation 

and a difference in efficiency relative to ballasts tested at 120 V and 277 V, in the NOPR 

DOE proposed separate equipment classes for ballasts tested at 480 V (in accordance 

with the test procedure).

Philips noted that when manufacturing multi-tap magnetic ballasts, each tap must 

be precisely placed. The voltage variation in each tap makes it more difficult for multi73 
tap ballasts to meet efficiency requirements than ballasts with dedicated voltage. (Philips, 

Public Meeting Transcript, No. 48 at p. 99) NEMA, ULT, and Southern Company 

supported a separate equipment class for dedicated 480 V ballasts. (NEMA, No. 56 at p. 

12; ULT, No. 50 at p. 5; Southern Company, No. 64 at p. 2) 

DOE acknowledges that the existence of multiple voltage taps could cause multitap ballasts to be less efficient than dedicated voltage ballasts. However, DOE’s testing of 

commercially available ballasts did not identify this trend. Rather, DOE’s test results 

indicated that the only obvious relationship between input voltage and ballast efficiency 

is that ballasts tested at 480 V were less efficient on average than ballasts tested at 120 V 

or 277 V. As stated above, DOE believes that input voltage offers unique utility because 

certain applications require specific input voltages. Therefore, in this final rule, DOE 

creates a separate equipment class for ballasts that are tested at 480 V. 

b. Lamp Wattage

As lamp wattage increases, lamp-and-ballast systems generally produce 

increasing amounts of light (lumens). Because certain applications require more light 

than others, wattage often varies by application. For example, low-wattage (less than 150 

W) lamps are typically used in commercial applications for general lighting. Mediumwattage (150 W – 500 W) lamps are commonly used in warehouse, street, and general 

commercial lighting. High-wattage (greater than 500 W) lamps are used in searchlights, 

stadiums, and other applications that require powerful white light. Because different 

applications require different amounts of light and the light output of lamp-and-ballast 

systems is typically reflected by the wattage, wattage affects consumer utility. 

74 
Additionally, the wattage of a lamp operated by a ballast is correlated with the ballast 

efficiency; ballast efficiency generally increases as lamp wattage increase. Because 

wattage affects consumer utility and has a strong correlation to efficiency, DOE 

determined in the NOPR that separate equipment classes based on wattage were 

warranted.

DOE found that even within a designated wattage range (such as 101 W – 150 

W), the potential efficiencies ballasts can achieve is not constant, but rather varies with 

wattage. Thus for certain wattage bins, instead of setting a constant efficiency standard, 

DOE used an equation-based energy conservation standard (see section V.C). DOE 

combined the wattage bins and equations rather than using a single equation spanning all 

covered wattages for two reasons. First, the range of ballast efficiencies considered can 

differ significantly by lamp wattage, making it difficult to construct a single continuous 

equation for ballast efficiency from 50 W to 2000 W. This efficiency difference can be 

attributed to the varying cost of increasing ballast efficiency for different wattages and 

the impact of legislated (EISA 2007) standards that affect only some wattage ranges. 

Second, different wattages often serve different applications and have unique costefficiency relationships. Analyzing certain wattage ranges as separate equipment classes 

allows DOE to establish the energy conservation standards that are cost-effective for 

every wattage.

75 
In the NOPR, DOE proposed to define MHLF equipment classes by the following 

rated lamp wattage ranges: 50 W – 100 W, 101 W – 150 W, 150 W – 250 W, 251 W – 

500 W, and 501 W – 2000 W.24 As discussed previously in section III.A.1, there is an 

existing EISA 2007 exemption for ballasts rated for only 150 W lamps, used in wet 

locations, and that operate in ambient air temperatures higher than 50 °C. This exemption 

has led to a difference in the commercially available efficiencies for ballasts that are 

contained within fixtures exempted versus not exempted from EISA 2007. The exempted 

fixtures have ballasts with a range of efficiencies similar to ballasts that operate lamps 

less than 150 W. Fixtures not exempted by EISA 2007 have ballasts that follow 

efficiency trends representative of ballasts greater than 150 W. As a result, DOE 

proposed that 150 W MHLFs previously exempted by EISA 2007 be included in the 101 

W – 150 W range, while 150 W MHLFs subject to EISA 2007 standards continue to be 

included in the 150 W – 250 W range.

ULT and NEMA stated that industry data shows ballast losses are significantly 

higher in 150 W ballasts relative to 175 W to 500 W ballasts due to the increased lamp 

current in 150 W MHLFs. (ULT, Public Meeting Transcript, No. 48 at p. 108; ULT, No. 

50 at pp. 5-6, 23; NEMA, No. 56 at p. 13) ULT explained that for 150 W – 175 W 

fixtures, the lower the wattage, the larger the ballast needed to maintain efficiency. ULT 

noted that this relationship is the net effect of three main factors: (1) higher lamp current, 

24 DOE uses this shorthand to refer to MHLFs designed to operate lamps rated at equal to or greater than 50 

W and equal to or less than 100 W, greater than 100 W and less than 150 W (however, including MHLFs 

designed to operate lamps rated at 150 W and exempted from EISA 2007), equal to or greater than 150 W 

and less than or equal to 250 W, greater than 250 W and less than or equal to 500 W, and greater than 500 

W and less than or equal to 2000 W, respectively.

76 

 
(2) increased impedance, and (3) decreased wire cross‐section. In conjunction, these 

factors make it impossible to have an 88 percent efficient 150 W ballast on a 3.25 inch by 

3.75 inch (commonly referred to as a “3x4”) frame. (ULT, No. 50 at pp. 23-24) ULT 

believed that 150 W fixtures could belong to the lower wattage bin; otherwise, the 

proposed standards would result in a ban of magnetic autotransformer 150 W ballasts. 

(ULT, No. 50 at p. 5)

DOE agrees with ULT and NEMA that 150 W ballasts have a lower maximum 

achievable efficiency relative to 175 W ballasts because of the resistive losses 

characteristic to ballasts at 150 W. Commercially, DOE also found that 150 W ballasts 

have a range of efficiencies similar to wattages below 150 W. Both of these trends 

support 150 W fixtures being categorized in separate equipment classes than 175 W 

fixtures. In this final rule, DOE is maintainingWhile DOE continues to group 150 W 

fixtures covered by EISA 2007 in the 150 W – 250 W equipment class, in this final rule 

DOE maintains the NOPR approach to group 150 W fixtures previously exempt by EISA 

2007 in the 101 W – 150 W equipment class and 150 W fixtures covered by EISA 2007 

in the 150 W – 250 W equipment class..

NEMA proposed that DOE establish a separate equipment class for 575 W 

ballasts but did not provide supporting detail for this proposal. (NEMA, No. 56 at p. 17) 

DOE examined the efficiency distribution of 575 W ballasts and found that efficiency 

varied in a manner similar to that of other ballasts within the 500 W to 1000 W wattage 

range. DOE is unaware of significant differences in the cost-efficiency relationship, 

consumer utility, or application of 575W fixtures relative to 1000 W fixtures, and 

Comment [AGA10]: Change requested by 

OIRA.

77 
therefore is not establishing a separate equipment class for these MHLFs. DOE continues 

to group all 501 W – 1000 W MHLFs in one wattage bin, using 1000 W fixtures as 

representative of the entire class.

Musco Lighting disagreed with the grouping of fixtures in the 501 W – 2000 W 

range. Musco Lighting stated that there are significant differences between the markets 

and applications of 1500 W and 1000 W MHLFs, and, accordingly, they should not be 

grouped together. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 107) Musco 

Lighting commented that 1500 W fixtures should not be in the same equipment class as 

1000 W fixtures. Musco Lighting commented that a majority of 1500 W fixtures operate 

at 480 V input, which distinguishes them from other equipment classes. (Musco Lighting, 

Public Meeting Transcript, No. 48 at p. 129) Musco Lighting further commented that 

annual operating hours should be taken into account so that MHLFs used in applications 

with very different operating hours would not be included in the same equipment class. 

Musco Lighting gave the example of sports lighting having much fewer operating hours 

than indoor warehouse lighting. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 

161) 

Upon further review, DOE agrees that there are differences between 1500 W and 

1000 W fixtures. DOE determined that the trend between increasing wattage and 

increasing efficiency found from 501 W – 1000 W did not continue above 1000 W. DOE 

found that above 1000 W, efficiency increased to a lesser extent with increased wattage. 

This is consistent with the NOPR analysis, in which different equations were used above 

and below 1000 W. DOE also found that lamp lifetime and annual operating hours are 

78 
much shorter for 1500 W fixtures relative to 1000 W fixtures because 1500 W fixtures 

are predominantly used in sports lighting. This causes 1500 W fixtures to have different 

cost-efficiency relationships relative to 1000 W fixtures. There is also a different costefficiency relationship based on the MSP of the fixtures themselves, representing a 

different portfolio of applications used from 501 – 1000 W and above 1000 W. 

Therefore, DOE determined that separate equipment classes should be established for 501 

W – 1000 W and 1001 W – 2000 W fixtures.25

In summary, DOE established MHLF equipment classes by the following rated 

lamp wattage bins: 50 W – 100 W, 101 W – 150 W, 150 W – 250 W, 251 W – 500 W, 

501 W – 1000 W, and 1001 W – 2000 W. DOE maintained that 150 W fixtures 

previously exempted by EISA 2007 are included in the 101 W – 150 W range, while 150 

W fixtures subject to EISA 2007 standards are included in the 150 W – 250 W range.

c. Fixture Application

MHLFs are used in a variety of applications such as parking lots, roadways, 

warehouses, big-box retail, and flood lighting. Although the fixture size, shape, and 

optics are often tailored to the application, generally the same type of ballast is utilized 

for most of the applications. DOE found in the NOPR, however, that indoor and outdoor 

MHLFs are subject to separate cost-efficiency relationships, specifically at the electronic 

ballast levels.

25 DOE uses this shorthand to refer to MHLFs designed to operate with lamps rated at greater than 500 W 

and less than or equal to 1000 W, and greater than 1000 W and less than or equal to 2000 W, respectively.

79 

 
As outdoor applications can be subject to large voltage transients, MHLFs in such 

applications require 10 kV voltage transient protection. Magnetic MH ballasts are 

typically resistant to voltage variations of this magnitude, while electronic MH ballasts 

are generally not as resilient. Therefore, in order to meet this requirement, electronic 

ballasts in outdoor MHLFs would need either (1) an external surge protection device or 

(2) internal transient protection of the ballast using metal-oxide varistors (MOVs) in 

conjunction with other inductors and capacitors.

DOE also noted that indoor fixtures can require the inclusion of a 120 V auxiliary 

tap. This output is used to operate an emergency incandescent lamp after a temporary loss 

of power while the MH lamp is still too hot to restart. These taps are generally required 

for only one out of every ten indoor lamp fixtures. A 120 V tap is easily incorporated into 

a magnetic ballast due to its traditional core and coil design, and incurs a negligible 

incremental cost. Electronic ballasts, though, require additional design to add this 120 V 

auxiliary power functionality.

These added features impose an incremental cost to the ballast or fixture (further 

discussed in section V.C.12 of this notice). As these incremental costs could affect the 

cost-effectiveness of fixtures for indoor versus outdoor applications, in the NOPR DOE 

proposed separate equipment classes for indoor and outdoor fixtures. 

DOE proposed that outdoor fixtures be defined as those that (1) are rated for use 

in wet locations and (2) have 10 kV of voltage transient protection. DOE proposed to 

define the wet location rating as specified by the National Fire Protection Association

80 
(NFPA) 70-2002,26 section 410.10(A) or UL 1598 Wet Location Listed.27 Providing two 

possible definitions will reduce the compliance burden as many manufacturers are 

already familiar with one or both of these ratings (the NFPA 70-2002 definition was 

included in EISA 2007 and both are used in California energy efficiency regulations). For 

10 kV voltage transient protection, DOE proposed to use the 10 kV voltage pulse 

withstand requirement from ANSI C136.2-2004. 

APPA agreed with separating equipment classes for indoor and outdoor fixtures, 

as they have separate uses that create differences in the frequency and length of use. 

APPA stated that because the circumstances are different when considering both classes, 

it is difficult to understand the effects of proposed efficiency standards on each group. 

(APPA, No. 51 at p. 4; APPA, Public Meeting Transcript, No. 48 at p. 103) Conversely, 

NEMA noted that separate equipment classes for indoor and outdoor fixtures could be 

problematic as, at the ballast level, there is no way of knowing whether equipment will be 

used indoors or outdoors. (NEMA, No. 56 at p. 14) Acuity Brands Lighting, Inc. (Acuity) 

commented that fixture application should also take into account the probability of 

transient voltages and extreme conditions, even in indoor applications. (Acuity, Public 

Meeting Transcript, No. 48 at p. 162) NEMA and ULT suggested combining indoor and 

outdoor equipment classes, except for electronic ballasts, as fewer classes will mean 

26 The NEC 2014NFPA 70-2002 states that fixtures installed in wet or damp locations shall be installed 

such that water cannot enter or accumulate in wiring components, lampholders, or other electrical parts. All 

fixtures installed in wet locations shall be marked, “Suitable for Wet Locations.” All fixtures installed in 

damp locations shall be marked “Suitable for Wet Locations” or “Suitable for Damp Locations.”

27 UL Standard Publication 1598 defines a wet location is one in which water or other liquid can drip, 

splash, or flow on or against electrical equipment. A wet location fixture shall be constructed to prevent the 

accumulation of water on live parts, electrical components, or conductors not identified for use in contact 

with water. A fixture that permits water to enter the fixture shall be provided with a drain hole.

81 

 
fewer reporting requirements. NEMA acknowledged that this will conflict with DOE’s 

desire to encourage electronic ballasts in outdoor applications. (NEMA, No. 56 at p. 9; 

ULT, No. 50 at p. 4)

DOE believes that indoor and outdoor MHLFs should be placed into separate 

equipment classes. While the efficiencies achievable indoors and outdoors are the same, 

the different costs between indoor and outdoor fixtures result in different cost-efficiency 

curves. When electronic ballasts are used in outdoor applications, they require additional 

transient protection because of the potential for voltage surges in outdoor locations. 

Indoor fixtures with electronic ballasts also have an added cost to provide 120 V auxiliary 

power functionality for use in the event of a power outage. Both of these cost adders are 

discussed in more detail in section V.C.12. As these costs adders differ based on a fixture 

being used indoors or outdoors, the cost-efficiency relationships differ based on indoor or 

outdoor application, and therefore separate equipment classes are warranted. Thus, in this 

final rule DOE establishes separate equipment classes for indoor and outdoor fixtures. 

DOE defines outdoor fixtures as those that (1) are rated for use in wet locations and (2) 

have 10 kV of voltage transient protection. Conversely, fixtures that do not meet these 

requirements will be defined as indoor fixtures. DOE continues to use the wet location 

rating definition from the National Fire Protection Association 70-2002, section 

410.10(A) or UL 1598 Wet Location listing. 

d. Electronic Configuration

Of the two MH ballast types (electronic and magnetic), magnetic ballasts are 

currently more common. , making up more than 90 percent of MH ballast shipments. Comment [AGA11]: Change requested by 

OIRA.

82 
Magnetic ballasts typically use transformer-like copper or aluminum windings on a steel 

or iron core. The newer electronic ballasts, which are more efficient but less common, 

rely on integrated circuits, switches, and capacitors or inductors to control current and 

voltage to the lamp. Both electronic and magnetic ballasts are capable of producing the 

same light output and, with certain modifications (e.g., thermal management, transient 

protection, 120 V auxiliary power functionality), can be used interchangeably in all 

applications. In the NOPR, DOE concluded that electronic configuration and circuit type 

do not affect consumer utility. With the necessary design alterations, electronic ballasts 

can provide the same utility as any magnetic ballast circuit type. Because electronic 

ballasts are typically more efficient than magnetic ballasts, utility is not lost with 

increasing efficiency. Therefore, DOE did not propose to define equipment classes based 

on electronic configuration.

ULT stated that electronic HID ballasts were originally intended for indoor, niche 

purposes. Therefore, automatically expecting that electronic MH ballasts would be able 

to perform in outdoor conditions, including applications subjected to wind, extreme 

temperature, and transient surges, is not reasonable. ULT noted that electronic ballasts’ 

vulnerability in outdoor applications is known throughout the industry. (ULT, Public 

Meeting Transcript, No. 48 at p. 52)

NEMA also disagreed with DOE not dividing equipment classes by electronic 

configuration. NEMA stated that performance requirements should be separated for 

electronic and magnetic ballasts to avoid an enormous burden on the industry. (NEMA, 

No. 56 at p. 12, 24) NEMA commented that they disagreed with DOE’s suggestion that 

83 
an electronic ballast is a design option for a magnetic ballast, as they are completely 

different technologies. (NEMA, No. 56 at p. 14). 

DOE has determined that these electronic ballasts, when fitted in an appropriate 

fixture, can be used in the same applications as magnetic ballasts. As mentioned in the 

previous section, various protections will be required for electronic ballasts in these 

applications. See section V.C.8.b for more detail about the feasibility of electronic 

ballasts as more efficient replacements for magnetic ballasts. After adjusting outdoor 

fixture prices to account for the modifications necessary to incorporate electronic ballasts, 

DOE has found that electronic ballasts can be reliably used in the same outdoor 

applications as magnetic ballasts. Therefore, DOE did not find that magnetic ballasts 

provided a unique utility over electronic ballasts. Thus, in this final rule, DOE included 

electronic and magnetic ballasts in the same equipment class.

e. Circuit Type

NEMA disagreed with DOE not dividing equipment classes by circuit type, citing 

the fluorescent lamp ballast rule as precedent. (NEMA, No. 56 at pp. 12, 24) ULT and 

NEMA proposed three different technology classes; magnetic series reactors, magnetic 

autotransformers, and electronic. (ULT, No. 50 at p. 5; NEMA, No. 44 at p. 17) NEMA 

explained the need for dividing equipment classes in this way by describing the 

technologies’ different utilities and relationships to efficiency. Specifically, NEMA stated 

that series reactors circuits are the most efficient, although they do not offer any power 

regulation. Power factor correction is weak with this ballast type, and high power factor 

increases total harmonic distortion. This circuit type only works for lamps that require an 

84 
open circuit voltage lower than the mains. It results in an increased inrush and current, 

and reduced maximum number of lamps per circuit. (NEMA, No. 44 at p. 18) 

Autotransformer ballasts may be used on various mains voltages, and the ballast open 

circuit voltage may be higher than the mains voltage. Constant-wattage autotransformer 

(CWA) designs include a secondary coil and operate with lower harmonic distortion. 

They offer better power regulation than series reactors and are highly reliable. (NEMA, 

No. 44 at p. 19) Electronic circuits are typically less reliable than autotransformer 

circuits, but operate with similar energy efficiency to series reactors. (NEMA, No. 44 at 

p. 20)

DOE agrees that within magnetic ballasts there are multiple circuit types, such as 

reactor and autotransformer. However, DOE has found that electronic ballasts can 

provide the same utility as any magnetic circuit type and can be substituted in all 

applications, while being generally more efficient than all magnetic ballasts. DOE also 

notes that all of the magnetic ELs in this final rule are determined by autotransformer 

magnetic ballasts, as autotransformer ballasts are the most common type on the market. 

Because reactor ballasts are typically more efficient than autotransformer ballasts, DOE 

found that setting a magnetic ballast EL based on autotransformer efficiency would not 

prohibit reactor ballasts. For these reasons, DOE did not find it necessary in this final rule 

to separate equipment classes by circuit type.

85 
f. Summary

DOE developed equipment classes in this final rule using three class-setting 

factors: input voltage, rated lamp wattage, and fixture application. DOE presents the 

resulting equipment classes in Table V.1

Table V.1 MHLF Equipment Classes Table

Designed to be Operated with 

Lamps of the Following Rated 

Lamp Wattage

Indoor/Outdoor† Input Voltage Type‡

≥50 W and ≤100 W Indoor Tested at 480 V

≥50 W and ≤100 W Indoor All others

≥50 W and ≤100 W Outdoor Tested at 480 V

≥50 W and ≤100 W Outdoor All others

>100 W and <150 W* Indoor Tested at 480 V

>100 W and <150 W* Indoor All others

>100 W and <150 W* Outdoor Tested at 480 V

>100 W and <150 W* Outdoor All others

≥150 W** and ≤250 W Indoor Tested at 480 V

≥150 W** and ≤250 W Indoor All others

≥150 W** and ≤250 W Outdoor Tested at 480 V

≥150 W** and ≤250 W Outdoor All others

>250 W and ≤500 W Indoor Tested at 480 V

>250 W and ≤500 W Indoor All others

>250 W and ≤500 W Outdoor Tested at 480 V

>250 W and ≤500 W Outdoor All others

>500 W and ≤1000 W Indoor Tested at 480 V

>500 W and ≤1000 W Indoor All others

>500 W and ≤1000 W Outdoor Tested at 480 V

>500 W and ≤1000 W Outdoor All others

>1000 W and ≤2000 W Indoor Tested at 480 V

>1000 W and ≤2000 W Indoor All others

>1000 W and ≤2000 W Outdoor Tested at 480 V

>1000 W and ≤2000 W Outdoor All others

*Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A);); and containing a ballast 

that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A);); and containing a ballast 

that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

†DOE’s proposed definitions for “indoor” and “outdoor” MHLFs are described in section V.A.2.c. 

‡Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less 

than 150 W would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. 

Ballasts not designed to operate at either of these voltages would be tested at the highest voltage the ballast 

86 
Designed to be Operated with 

Lamps of the Following Rated 

Lamp Wattage

Indoor/Outdoor† Input Voltage Type‡

is designed to operate. See section IV.A for further detail.

B. Screening Analysis

For the screening analysis, DOE consults with industry, technical experts, and 

other interested parties to determine which technology options to consider further and 

which to screen out. Appendix A to subpart C of 10 CFR Part 430, “Procedures, 

Interpretations, and Policies for Consideration of New or Revised Energy Conservation 

Standards for Consumer Products” (the Process Rule), sets forth procedures to guide 

DOE in its consideration and promulgation of new or revised energy conservation 

standards. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 

6295(o) and, in part, eliminate problematic technologies early in the process of 

prescribing or amending an energy conservation standard. In particular, sections 4(b)(4) 

and 5(b) of the Process Rule provide guidance to DOE for determining which design 

options are unsuitable for further consideration:

Technological feasibility. DOE will consider technologies incorporated in 

commercial products or in working prototypes to be technologically feasible.

Practicability to manufacture, install, and service. If mass production and 

reliable installation and servicing of a technology in commercial products could be 

achieved on the scale necessary to serve the relevant market at the time the standard 

comes into effect, then DOE will consider that technology practicable to manufacture, 

install, and service.

87 
Adverse impacts on product utility or product availability. If DOE determines 

a technology would have significant adverse impacts on the utility of the product to 

significant subgroups of consumers, or would result in the unavailability of any covered 

equipment type with performance characteristics (including reliability), features, sizes, 

capacities, and volumes that are substantially the same as equipment generally available 

in the United States at the time, it will not consider this technology further.

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

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

further.

In the NOPR, DOE screened out one technology option: laminated sheets of 

amorphous steel. For magnetic metal halide ballasts, DOE found one method of 

decreasing transformer losses is to create the core of the inductor from laminated sheets 

of amorphous steel, insulated from each other. DOE screened out amorphous steel 

technology because it failed to pass the “practicable to manufacture, install, and service” 

criterion, and using amorphous steel could have adverse impacts on consumer utility 

because increasing the size and weight of the ballast may limit the places a customer 

could use the ballast. DOE received no comments to the contrary, and thus continues to 

screen out amorphous steel in the final rule.

88 
DOE identified the design options listed in Table V.2 as technologies that could 

improve MHLF ballast efficiency and pass the screening criteria discussed above. For 

further details on these design options, see chapter 3 of the final rule TSD.

Table V.2 Metal Halide Lamp Fixture Design Options

Ballast Type Design Option Description

Magnetic

Improved Core Steel Use a higher grade of electrical steel, including grain

oriented silicon steel, to lower core losses.

Copper Wiring Use copper wiring in place of aluminum wiring to 

lower resistive losses.

Increased Stack Height Add steel laminations to lower core losses.

Increased Conductor Cross Section Increase conductor cross section to lower winding 

losses.

Electronic Ballast Replace magnetic ballasts with electronic ballasts. 

Electronic

Improved 

Components

Magnetics

Use grain-oriented or amorphous electrical steel to 

reduce core losses.

Use optimized-gauge copper or litz wire to reduce 

winding losses.

Add steel laminations to lower core losses.

Increase conductor cross section to lower winding 

losses.

Diodes Use diodes with lower losses.

Capacitors Use capacitors with a lower effective series resistanc 

and output capacitance.

Transistors Use transistors with lower drain-to-source resistance

Improved Circuit 

Design

Integrated 

Circuits

Substitute discrete components with an integrated 

circuit.

C. Engineering Analysis

1. Approach

The engineering analysis develops cost-efficiency relationships depicting the 

manufacturing costs of achieving increased ballast efficiency. DOE applies two 

methodologies to estimate manufacturing costs for the engineering analysis: (1) the 

design-option approach, which provides the incremental costs of adding the design 

89 
options discussed in section V.B of this notice to improve the efficiency of a baseline 

model; and (2) the efficiency-level approach, which estimates the costs of achieving 

increases in ELs through ballast efficiency testing, manufacturer catalogs, and teardowns. 

Details of the engineering analysis are in chapter 5 of the final rule TSD. The following 

discussion summarizes the general steps of the engineering analysis:

Determine Representative Equipment Classes. When multiple equipment classes 

exist, to streamline testing and analysis, DOE selects certain classes as “representative,” 

primarily because of their high market volumes. DOE then scales the ELs from 

representative equipment classes to those equipment classes it does not analyze directly.

Determine Representative Wattages. Within each representative equipment class, 

DOE also selects a particular wattage fixture as “representative” of the wattage range, 

primarily because of their high market volumes. In this final rule, DOE assigns only one 

representative wattage per representative equipment class.

Representative Fixture Types. To calculate the typical cost of a fixture at each 

representative wattage, DOE selects certain types of fixtures to analyze as representative.

Select Baseline Units. DOE establishes a baseline unit for each representative 

wattage. The baseline unit has attributes (circuit type, input voltage capability, electronic 

configuration) typical of ballasts used in fixtures of that wattage. The baseline unit also 

has the lowest (baseline) efficiency for each representative wattage. DOE measures 

changes resulting from potential amended energy conservation standards compared with 

90 
this baseline. For fixtures subject to existing federal energy conservation standards, a 

baseline unit is a MHLF with a commercially available ballast that just meets existing 

standards. If no standard exists for a fixture, the baseline unit is the MHLF at a 

representative wattage with a ballast with the lowest tested ballast efficiency that is sold. 

To determine energy savings and changes in price, DOE compares each higher EL with 

the baseline unit.

To determine the ballast efficiency, DOE tested a range of MH ballasts from 

multiple ballast manufacturers. In some cases, when test data was unavailable, DOE used 

efficiency values listed in manufacturer catalog data sheets. Appendix 5A of the final rule 

TSD presents the test results. When necessary, DOE selects more than one baseline for a 

representative wattage to ensure consideration of different fixture and ballast types and 

their associated customer economics.

Select More-Efficient Units. DOE selected both commercially available MHLFs 

and modeled MHLFs with higher-than-baseline-efficiency ballasts as replacements for 

each baseline model in each representative equipment class. In general, DOE can identify 

the design options associated with each more-efficient ballast model by considering the 

design options that meet the criteria of the screening analysis (chapter 4 of the final rule 

TSD). For electronic ballasts, where design options cannot be identified for that class by 

the product number or catalog description, DOE conducts testing to determine their 

efficiency. Appendix 5A of the final rule TSD presents these test results. These ballast 

efficiencies were calculated according to the MH ballast test procedures (10 CFR 

431.324), unless otherwise specified. DOE estimates the design options likely to be used 

91 
to achieve a higher efficiency based on information gathered during manufacturer 

interviews and information presented in ballast catalogs.

Determine Efficiency Levels. DOE develops ELs based on: (1) the design options 

associated with the equipment class studied and (2) the max-tech EL for that class. As 

previously noted and as discussed in section IV.B.2, DOE’s ELs are based on test data 

collected from commercially available equipment, catalog data, manufacturer input, and 

ballast modeling.

Conduct Price Analysis. DOE generated a bill of material (BOM) by 

disassembling multiple manufacturers’ ballasts from a range of ELs and fixtures that span 

a range of applications for each equipment class. The BOMs describe the equipment in 

detail, including all manufacturing steps required to make and assemble each part. DOE 

then developed a cost model to convert the BOMs for each representative unit into 

manufacturer production costs (MPCs). By applying derived manufacturer markups to 

the MPCs, DOE calculated the MSPs28 and constructed industry cost-efficiency curves. 

In cases where DOE was not able to generate a BOM for a given ballast, DOE estimated 

an MSP based on the relationship between teardown data and retail data. DOE also 

estimated ballast and fixture cost adders necessary to allow replacement of more-efficient 

substitutes for baseline models.

28 The MSP is the price at which the manufacturer can recover all production and non-production costs and 

earn a profit. Non-production costs include selling, general, and administration (SG&A) costs, the cost of 

R&D, and interest.

92 

 
2. Representative Equipment Classes

As described in the previous section, DOE selects certain equipment classes as 

“representative” to focus its analysis. The 24 equipment classes (based on rated lamp 

wattage, indoor or outdoor designation, and test voltage) and the criteria used for 

development are presented in section V.A.2. Due to their low shipment volume (as 

indicated through manufacturer interviews), DOE does not directly analyze the 

equipment classes containing only fixtures with ballasts tested at 480 V. DOE selected all 

other equipment classes as representative, resulting in a total of 12 representative classes 

that cover the full range of lamp wattages, as well as indoor and outdoor designations. 

DOE had only analyzed 10 representative equipment classes in the NOPR. This increase 

is a result of DOE’s decision to split the 501 W – 2000 W equipment classes into 501 W 

– 1000 W and 1001 W – 2000 W. This new equipment class structure is discussed in 

section V.A.2. 

3. Representative Wattages

In the NOPR, DOE selected five representative wattages of MHLFs (70 W, 150 

W, 250 W, 400 W, and 1000 W) to analyze in the engineering analysis. Each 

representative wattage was typically the most commonly sold wattage within each 

equipment class, based on analysis of fixture availability from catalogs and manufacturer 

input.

As discussed in section V.A.2, DOE has split the 501 W – 2000 W equipment 

classes from the NOPR into 501 W – 1000 W and 1001 W – 2000 W in the final rule. 

From 501 W – 1000 W, DOE still finds 1000 W to be an appropriate representative 

93 
wattage based on it being the most commonly sold. In the final rule, DOE is analyzing 

1500 W as the representative wattage for the 1001 W – 2000 W equipment classes based 

on this wattage being the most commonly shipped in the wattage range.

4. Representative Fixture Types

After selecting representative wattages for analysis, DOE identified the 

applications commonly served by each equipment class’s wattage range in order to select 

representative fixture types. DOE recognizes that technological changes in the ballast 

caused by standards considered in this rulemaking, especially moving from magnetic 

ballasts to electronic ballasts, could necessitate alterations to the fixture. These changes 

often incur additional costs depending on the fixture type that needs to be altered. In the 

engineering analysis, DOE estimates a baseline fixture cost, as well as incremental costs 

to the fixture based on the type of ballast used (e.g., electronic ballasts require specific 

fixture adaptations that magnetic ballasts do not). The cost adders to the fixtures are 

discussed in section V.C.12. 

In the NOPR, DOE selected one to three representative fixture types for each 

rated wattage range based on the most common application(s) within that range. For the 

50 W – 100 W range, DOE selected canopy fixtures as the representative fixture types. 

For the 101 W – 150 W and 150 W – 250 W range, DOE selected canopy, low bay, and 

94 
wallpack fixtures as representative fixture types. For wattages greater than 250 W, DOE 

chose canopy, flood, and high bay fixtures as representative fixture types.29

In this final rule, DOE has expanded its analysis of representative fixtures to 

account for separate uses in indoor and outdoor applications. This allows DOE to develop 

separate prices for indoor and outdoor fixtures, taking into account the weather protection 

built into outdoor fixtures. The new representative fixture types, which include from one 

to four applications for each equipment class, are shown in Table V.3. 

Table V.3 Representative Wattages and Fixtures

Designed to be Operated 

with Lamps of the Following 

Rated Lamp Wattage

Representative 

Wattage

Representative Fixture Types

Indoor Outdoor

≥50 W and ≤100 W 70 W Recessed Can Wallpack, Post Top, Flood

>100 W and <150 W* 150 W Low Bay Parking Lot, Area, Wallpack, 

Flood

≥150 W and ≤250 W** 250 W Low Bay Area, Flood, Wallpack

>250 W and ≤500 W 400 W Flood, High Bay Pole Top, Flood

>500 W and ≤1000 W 1000 W High Bay Flood, Sports

>1000 W and ≤2000 W 1500 W Sports Sports

* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

29 Descriptions of each of these fixtures types can be found in chapter 3 of the final rule TSD.

95 

 
5. Ballast Efficiency Testing

After selecting representative wattages and fixture types, DOE purchased and 

tested MH ballasts, ranging from low-efficiency magnetic to high-efficiency electronic, 

in order to evaluate the range of commercially available ballast efficiencies. In selecting 

units for testing and analysis, DOE focused its effort on representative wattage ballasts 

with operating characteristics similar to ballasts most prevalent in the market. For 

example, through interviews and an assessment of commercially available MH ballasts, 

DOE learned that the majority of MH ballasts sold are quad-input voltage ballasts. Thus, 

DOE primarily tested MH ballasts capable of quad-input operation. Similarly, DOE 

found that at low wattages (less than or equal to 150 W), high-reactance autotransformer 

(HX) ballasts and CWA ballasts are most prevalent. At higher wattages, CWA ballasts 

compose the vast majority of the market. In consideration of these findings, DOE focused 

its testing and analysis on HX and CWA ballasts for the 70 W to 150 W range and CWA 

ballasts for all other wattage units.

DOE calculated average ballast efficiencies, across four samples, in accordance 

with MH ballast test procedures (10 CFR 431.324) by dividing measured output power 

by measured input power. As discussed in sections V.C.7 and V.C.8 of this notice, DOE 

selects baseline and higher-efficiency representative units for analysis based on these 

average efficiencies. Also, as discussed in the following section, DOE determines 

representative ballast input power for each EL based on these tested ballast efficiencies. 

To determine the ELs under consideration, as discussed in section V.C.9 of this notice, 

DOE uses a reported efficiency value based on the four tested samples, pursuant to the 

MH ballast certification procedures in 10 CFR 429.54.

96 
6. Input Power Representations

As MH lamps age, they exhibit higher voltages, which can lead to higher system 

input power over the life of the lamp. Electronic ballasts have the capability to sense that 

the lamp voltage has increased and, in response, decrease their output current to maintain 

constant wattage throughout the life of the ballast. In the NOPR, DOE noted that 

magnetic ballasts do not have this capability and therefore the system wattage of 

magnetic MH ballasts would increase in response to an increase in lamp voltage over the 

lamp life. Therefore, DOE used a 5.5 percent increase in the NOPR when calculating the 

representative input power of magnetic ballasts.

Venture, NEMA, and ULT commented that while there is a voltage rise over the 

life of MH lamps, it can be extremely variable based on lamp design and manufacturing 

tolerances. Venture cautioned against applying a single factor to increase power across all 

ballasts. (Venture, Public Meeting Transcript, No. 48 at p. 178; NEMA, No. 56 at p. 15; 

ULT, No. 50 at pp. 8-9) ULT further asserted that DOE did not consider that ballast 

efficiency increases with a lamp’s voltage and age, and also that many lamps have 

voltage below the nominal level when new. (ULT, No. 50 at pp. 8-9) In contrast, CA 

IOUs agreed with DOE on the increase in system input power and voltage that occurs 

over a ballast’s life, but remarked that this increase may not be linear, and that the 

increase is smaller with electronic ballasts than with magnetic ballasts. They suggested 

that DOE continue to research this area, as the 5.5 percent figure determined could be an 

underestimation of the advantages of electronic ballasts. (CA IOUs, No. 54 at p. 7)

97 
In the NOPR, DOE’s inclusion of a 5.5 percent increase in input power for 

magnetic ballasts was based on feedback from manufacturers gathered during interviews. 

After reviewing the NOPR interview feedback in light of the new comments and 

conducting additional research on this topic, it was unclear whether the input power of 

magnetic ballasts actually increased over the ballasts’ lifetime and, if it did increase, what 

the magnitude of that increase would be. Therefore, in this final rule DOE has not applied 

a scaling factor to increase the input power of magnetic ballasts.

7. Baseline Ballast Models 

DOE selected baseline models as reference points for each representative 

equipment class, against which DOE measured changes in energy use and price resulting 

from potential amended energy conservation standards. For MHLFs and MH ballasts 

subject to existing federal energy conservation standards, a baseline model is a 

commercially available ballast that just meets existing standards and provides basic 

consumer utility. If no standard exists for a specific fixture type (e.g., less than 150 W or 

greater than 500 W fixtures), DOE chooses baselines that represent the least efficient

equipment (based on average tested ballast efficiencies) or highest-volume equipment 

within the representative parameters defined (e.g., representative wattage, magnetic 

circuit type, input voltage).

For the NOPR, DOE analyzed a CWA, quad-input voltage, pulse-start baseline 

ballast for the 70 W, 150 W, 250 W, and 400 W representative wattages. As electronic 

ballasts comprise a significant portion of the 50 W – 100 W ballasts shipped with indoor 

fixtures, for the 70 W representative wattage DOE analyzed a second baseline ballast 

98 
utilizing an LFE circuit and operating at quad-voltage. For the 1000 W representative 

wattage, DOE analyzed a CWA, quad-input voltage, probe-start baseline ballast.

a. 70 W Baseline Ballast

In the NOPR, DOE analyzed an electronic ballast as a second baseline ballast for 

the 70 W representative wattage. DOE included this second baseline because it had 

determined that electronic ballasts comprise a significant portion (estimated as more than 

25 percent) of the 50 W – 100 W ballasts shipped with indoor fixtures. NEMA agreed 

with the addition of the electronic 70 W baseline ballast. (NEMA, No. 56 at p. 15) 

Receiving no comments in opposition, DOE has continued analyzing both an electronic 

and magnetic baseline ballast at 70 W for this final rule.

b. 1000 W Baseline Ballast

In the NOPR, DOE identified a probe-start ballast as the 1000 W baseline unit. 

While DOE acknowledged that pulse-start ballasts are available at the 1000 W level, it 

noted that probe-start, CWA, quad-voltage units are predominant in the high-wattage 

category, and are therefore the most appropriate baselines.

Musco Lighting questioned why a probe-start ballast was used as the 1000 W 

baseline ballast if this standard is suggesting a shift towards pulse-start in all equipment 

classes. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 130) As discussed 

previously, a baseline ballast is the most common, least efficient ballast at the 

representative wattage, without the imposition of standards (i.e., the base case). The 

baseline unit is meant to measure changes resulting from potential amended energy 

99 
conservation standards compared with this baseline. DOE found that while pulse-start 

ballasts are available at the 1000 W level, probe-start ballasts currently dominate the 

market. As it is much more common for 1000 W ballasts to be probe-start, DOE 

continued to analyze a probe-start ballast as the 1000 W baseline unit in this final rule.

c. 1500 W Baseline Ballast

In the NOPR, a 1000 W baseline was analyzed in the 501 W to 2000 W 

equipment class. In this final rule, DOE divided this wattage range into a 501 W – 1000 

W equipment class and a 1001 W – 2000 W equipment class (see section V.A.2 of this 

notice). DOE continued to analyze a 1000 W baseline in the 501 W to 1000 W equipment 

class. In the 1001 W – 2000 W equipment class, DOE analyzed the 1500 W wattage as 

representative. Therefore, DOE added a baseline model at the new representative 

wattage, 1500 W, to represent the most common, least efficient ballast in the 1001 W – 

2000 W representative equipment class. The baseline unit for 1500 W is a magnetic 

CWA ballast and has a ballast efficiency of 92.9 percent.

d. Summary of Baseline Ballasts

In summary, after considering the comments received and changes to the 

equipment class structure, DOE has selected seven baseline units for analysis: 70 W 

magnetic, 70 W electronic, 150 W magnetic, 250 W magnetic, 400 W magnetic, 1000 W 

magnetic, and 1500 W magnetic.

100 
8. Selection of More-Efficient Units

After the selection of baseline models, DOE used a combination of two methods 

to determine more-efficient units for analysis within each representative equipment class. 

The first method was examining DOE’s own test data (discussed in section V.C.5 of this 

notice) to select commercially available ballasts to represent higher ELs. The second 

method involved filling in large gaps of efficiency present in the test data (often between 

commercially available magnetic and electronic ballasts) by modeling ballasts with 

improved efficiency due to the implementation of several of the design options described 

in section V.B of this notice. DOE derived those estimates based on manufacturer 

interviews and by validating or supplementing that feedback with independent modeling 

of potential reductions in ballast losses. Specifically, DOE used the watts loss per pound 

characteristics for various steel types to determine the levels of efficiency modeled 

ballasts could achieve.

DOE developed a max-tech magnetic ballast based on either commercially 

available equipment or a modeled ballast that utilized the highest grade steel practicable 

for manufacturing MH ballasts. For further details on the higher-efficiency units analyzed 

in this final rule, see chapter 5 of the final rule TSD.

a. Higher-Efficiency Magnetic Ballasts

DOE recognizes that several commercially available magnetic ballasts may 

already utilize the most efficient design options and have reached their efficiency limit. 

However, based on feedback from manufacturer interviews, DOE has learned that for 

each of the representative wattages analyzed, there exist design options to improve 

101 
efficiency of magnetic ballasts. Therefore, DOE utilizes these design options to estimate 

the max-tech efficiency for magnetic ballasts for each representative wattage. DOE 

received a number of comments in response to the NOPR regarding the modeled higherefficiency magnetic ballasts, specifically regarding the modeling method, performance 

characteristics of the modeled more-efficient units, and the impacts on fixture and ballast 

redesign.

Modeling Method

In modeling more-efficient magnetic ballasts for the NOPR, DOE maintained the 

physical size of the higher-efficiency models relative to commercially available magnetic 

ballasts within the representative wattages (i.e., the modeled ballasts did not increase in 

size compared to what’s currently available on the market). By using design information 

provided by manufacturers, DOE assumed improvements to the core steel and conductor 

of the commercially available magnetic ballasts to determine the higher-efficiency 

magnetic ballast efficiency and prices.

NEMA explained that core losses are determined by the type of material being 

used, the most efficient being M6 steel. Wire loss is generated from electrical resistance, 

and the most efficient wire material used is copper. (NEMA, No. 56 at p. 3) NEMA cited 

that for EL1 and EL2, the model assumes a higher quality steel will be used than is 

provided in the baseline unit. (NEMA, No. 56 at p. 10) NEMA and ULT noted that the 

EL2 calculation appears speculative, and that to move from EL1 to EL2 would require a 

17 percent reduction (in the case of 70 W ballasts) in ballast losses, which is unfeasible. 

(NEMA, No. 56 at p. 10; ULT, No. 50 at pp. 6-7) NEMA commented that DOE 

102 
underestimated both core steel losses and winding losses, which led to overestimates of 

feasible efficiencies. (NEMA, No. 56 at p. 11)

Regarding core losses, NEMA and ULT noted that the watts loss per pound of 

core steel constants DOE provided in the NOPR TSD are correct numbers obtained by an 

Epstein test30 per the ASTM A-343 standard. However, NEMA and ULT stated that 

those numbers would be more appropriate to use for power transformers than for ballasts, 

and that the values are deceiving when applied directly to ballast core loss calculations. 

NEMA and ULT gave the example that M6 steel is shown to have 0.66 W/lb losses at 1.5 

Tesla 60 Hz sine flux along the grain, when losses across the grain for M6 steel in an MH 

ballast are approximately 1.2 W/lb. Furthermore, NEMA and ULT explained that when 

ballast laminations are welded during manufacturing, grain-oriented material degrades 

substantially, and the losses increase. (NEMA, No. 56 at p. 11; ULT, No. 50 at p. 7) 

Philips agreed, commenting that the watts per pound loss for M6 steel would more than 

double during the manufacturing process, limiting the benefit of using this steel. (Philips, 

Public Meeting Transcript, No. 48 at p. 120) Philips also explained that the increase in 

M6 core losses is because welding disrupts the magnetic properties of the material. 

(Philips, Public Meeting Transcript, No. 48 at p. 121) Additionally, NEMA and ULT 

commented that magnetic flux in MH ballasts is not purely sinusoidal, rather it also 

includes harmonic frequencies that increase losses. They commented that even relative 

ratios of the losses provided in the NOPR TSD would not work, because data for grain30 An Epstein test is a method for evaluating a steel’s magnetic properties by testing its performance with a 

standardized Epstein frame. During the measurement the Epstein frame, comprising a primary and a 

secondary winding, behaves as an unloaded transformer and the power losses are then measured with a 

wattmeter.

103 

 
oriented steels are found using the 100 percent along the grain Epstein test, while data for 

cold-rolled steels, such as M19, use the 50 percent Epstein test. This 50/50 Epstein test 

takes into account and averages losses along the grain and across the grain. Therefore, 

DOE is not comparing equivalent measurements when simply using the already 

calculated core loss values presented in the NOPR. (NEMA, No. 56 at p. 11; ULT, No. 

50 at p. 7)

In this final rule, DOE has revised its approach to modeling the efficiency of 

magnetic ballasts. The efficiency of commercially available ballasts is established by 

independent test data conducted in accordance with the DOE test procedure, or taken 

directly from a manufacturer’s ballast data sheet when test data was unavailable. Based 

on feedback obtained during individual manufacturer interviews, DOE assigned design 

characteristics to these commercially available ballasts. Design characteristics included 

core steel type, core mass, wire material, and wire mass. To analyze more-efficient 

ballast designs than those currently on the market, DOE calculated the change in 

efficiency (i.e., change in ballast losses) resulting from a substitution of steel type.

Regarding the core loss calculations, DOE revised its loss values for M6 steel in 

response to the comments received. In the NOPR, the losses per pound values for M6 

steel were based on alignment of the magnetic field longitudinally (in the same direction 

as the grain orientation) to the core steel. However, portions of the magnetic field are 

aligned transverse (perpendicular to the grain orientation) to the core steel. The core 

losses in the transverse orientation are much higher. For this final rule, DOE calculated a 

weighted average of longitudinal and transverse losses as the core loss factor for M6 steel

104 
and found that about one third of losses are in the transverse direction. Using this 

information, DOE calculated the average core losses, in W/lb, for M6 steel. See chapter 5 

of the final rule TSD for additional detail. With this revision, the M6 loss value is 

comparable with the conventional cold-rolled steel (such as M19) 50/50 Epstein-testbased loss per pound values.

To calculate the losses associated with an EL2 ballast that uses M6 steel, DOE 

first calculated the losses of the EL1 ballast of the same wattage, by dividing lamp 

wattage by ballast efficiency, and then subtracting the lamp wattage. Next, DOE 

calculated the core losses of the EL1 ballast based on the mass of the EL1 core and the 

watts per pound loss value associated with the type of steel used in the EL1 ballast. Then, 

assuming the footprint and stack height cannot change, DOE assumed the EL2 M6 core 

would have the same mass. DOE therefore multiplied the M6 loss per pound value by the 

mass of the EL1 core to calculate the losses assuming an M6 steel substitution. DOE 

assumed all other losses remained constant, and therefore reduced the total EL1 ballast

losses by the incremental decrease in core losses associated with the M6 steel. Regarding 

the 70 W ballasts, this final rule now models an increase in ballast efficiency from 76.6 

percent to 78.4 percent, based on the decrease in core losses (and therefore increase in 

ballast efficiency) from M19 to M6 steel. This is a reduction in losses of 9.1 percent 

relative to EL1.

Regarding the resistive losses in the windings, NEMA and ULT stated that DOE’s 

assumption that the current in the primary side of the transformer was approximately 

equal to the input current to the ballast is incorrect. This incorrect assumption would lead 

105 
to calculated losses substantially lower than actual losses. (NEMA, No. 56 at p. 11; ULT, 

No. 50 at pp. 7-8) NEMA and ULT pointed out that the current in the secondary coil of 

the transformer does not need to be estimated, as it is equal to lamp current. (NEMA, No. 

56 at p. 11; ULT, No. 50 at p. 8) NEMA and ULT suggested that as lamp current is 

responsible for winding losses, it should be used as a technical parameter when screening 

ballast design options. (NEMA, No. 56 at p. 10; ULT, No. 50 at p. 6) 

DOE agrees with NEMA and ULT’s description of current in various stages of 

the magnetic ballast. In an HX ballast, the presence of a capacitor in parallel with the 

primary transformer winding increases the current in the primary winding relative to the 

input current from the power source. With the secondary winding, the current is equal to 

the lamp current, which is given in ANSI C78.43-2010. However, for the final rule, 

modeled ELs are only based on substitution of electrical steel, assuming all else remains 

equal. Therefore, the comments relating to resistive losses based on current are not 

applicable to DOE’s final rule calculations.

Modeled More-Efficient Units

In the NOPR, DOE used the modeling ballast methodology to calculate the 

efficiency of ballasts more efficient than those currently available for sale. NEMA, 

Philips, and ULT stated that 150 W fixtures could not meet the proposed efficiency 

requirement. (NEMA, Public Meeting Transcript, No. 48 at p. 33; Philips, Public Meeting 

Transcript, No. 48 at p. 48; ULT, No. 50 at pp. 23-24) ULT commented that an efficiency 

requirement for 150 W magnetic ballasts higher than currently commercially available 

equipment would practically ban 150 W magnetic autotransformer ballasts. (ULT, No. 50 

106 
at pp. 23-24) NEMA and ULT suggested that DOE made a mistake in considering how 

magnetic ballast efficiency behaves as a result of design considerations. As ballast 

wattage decreases, efficiency loss factors are compounded and the ballast size necessary 

to achieve potential efficiency gains increases, making it difficult to further raise the 

efficiency of ballasts 150 W and below. (NEMA, No. 56 at p. 3; ULT, No. 50 at pp. 19-

24) ULT noted that typically, as lamp wattage decreases, so does lamp current. As 150 W 

lamps have higher lamp current than 175 W ballasts, it is more difficult for the 150 W 

ballasts to achieve high efficiencies. ULT noted that this relationship is the net effect of 

three main factors: (1) higher current, (2) increased inductance, and (3) wire cross‐

section. In conjunction, these factors make it impossible to have an 88 percent efficient 

150 W magnetic ballast on a 3x4 frame. Hence, the industry has not developed a 150 W 

MHLF with an 88 percent efficient magnetic autotransformer ballast in response to EISA 

2007. (ULT, No. 50 at pp. 23-24) Furthermore, ULT stated that as ballasts ranging from 

50 W to 150 W would need to increase in size in order to meet the EL proposed in the 

NOPR, these ballasts would not fit in the fixtures for which they were previously 

suitable. (ULT, No. 50 at p. 6) Philips clarified that the increase in size comes from the 

magnetic ballast stack height. Philips noted there are options for electronic ballasts, but 

they are not necessarily interchangeable and might be too big for existing fixtures. 

(Philips, Public Meeting Transcript, No. 48 at p. 50)

DOE notes that the level proposed at 150 W in the NOPR was intended to only be 

met by electronic ballasts, as are all EL3 and EL4 levels in both the NOPR and this final 

rule. DOE agrees with ULT that 150 W autotransformer ballasts cannot reach 88 percent 

efficiency with today’s technology. In the NOPR, the magnetic ELs were set at 84.0 

107 
percent for EL1 and 86.5 percent for EL2. DOE disagrees that an EL above commercially 

available equipment would ban 150 W magnetic ballasts, as improving the core steel to 

M6, even while maintaining the same core footprint and weight, would improve the 

magnetic ballast efficiency beyond commercially available levels. DOE agrees that 150 

W ballasts have a lower maximum achievable efficiency relative to 175 W ballasts, and 

has analyzed the 150 W fixture exempted by EISA 2007 accordingly. For this final rule, 

DOE revised the magnetic ballasts analyzed as more efficient replacements for the 150 W 

representative wattage. DOE selected a more common replacement ballast for EL1. At 

EL2, revisions in the magnetic ballast modeling resulted in changes to the performance 

characteristics. In the final rule, as in the NOPR, the ballast efficiencies analyzed at both 

EL1 and EL2 are less than 88 percent.

APPA and NEMA commented that the modeled magnetic ELs are not 

technologically feasible, as modeling and calculations are not proof of concept and do not 

account for variability in manufacturing. (APPA, No. 51 at pp. 7-8; NEMA, No. 56 at pp. 

2, 24) NEMA and ULT also commented that the proposed characteristics of the modeled 

magnetic ballasts are based on theories, but have not been proven in manufacturing or 

physical testing and are therefore infeasible and cannot be tested for form, fit, or 

functions compatibility. ULT further asserted that the max-tech magnetic levels would 

require higher grade steel and wire, and would therefore increase ballast size. (NEMA, 

No. 56 at p. 11; ULT, No. 50 at pp. 4, 8, 30) In addressing the technological feasibility of 

the max-tech levels, NEMA stated that most max-tech levels selected for magnetic 

ballasts are possible only in laboratory conditions, and even then only with electronic 

ballasts. In cases where magnetic ballasts could reach the EL, they would need to be 

108 
enlarged, and might not fit in existing fixtures. (NEMA, No. 56 at p. 10) Philips 

questioned whether a modeled product proves technological feasibility. (Philips, Public 

Meeting Transcript, No. 48 at p. 214) Philips also questioned whether interviews with 

manufacturers were enough to constitute an assessment of technological feasibility 

without actual proof. (Philips, Public Meeting Transcript, No. 48 at p. 215) NEMA stated 

that many other rulemakings select products of the highest efficiency that are already 

commercially available, as opposed to modeling something that has not been produced 

yet. Philips stated that it is unreasonable to think that there would not be other changes 

required in order to implement the modeled product. (Philips, Public Meeting Transcript, 

No. 48 at p. 221)

DOE conducted interviews with individual manufacturers for the NOPR analysis 

and received information through that process describing the design characteristics of 

ballasts more efficient than those currently in production. DOE then validated that 

information by calculating the incremental change in losses associated with substituting 

the electrical steel of a commercially available ballast for a higher grade of steel. While it 

is true that the ballasts directly analyzed at EL2 are not currently commercially available, 

the design option (M6 steel) used to create these ballasts is commercially available. M6 

steel designs are used for 175 W ballasts with a 3x4 footprint, as evidenced by public 

comment during the preliminary analysis and NOPR phases of this rulemaking. In 

addition, DOE purchased and inspected a 175 W 3x4 magnetic ballast, and found the 

lamination thickness (0.14 inches) was indicative of M6 steel. DOE has modified its 

calculations of the benefits of M6 steel based on comment received from industry, but 

continues to analyze modeled ballasts for some ELs.

109 
APPA and NEMA commented that meeting EL2, which DOE based on modeled 

magnetic ballasts, will actually require electronic ballasts. APPA and NEMA especially 

noted that the 91.5 percent efficiency requirement for 250 W ballasts is only achievable 

with electronic ballasts. (APPA, No. 51 at pp. 7-8; NEMA, No. 56 at pp. 2, 24) Overall, 

ULT stated that EL2 is too high for magnetic ballasts. (ULT, Public Meeting Transcript, 

No. 48 at p. 137) NEMA and ULT commented that the proposed efficiency standards 

would only be achievable by magnetic ballasts in some lab conditions, and would 

therefore require everything less than or equal to 750 W to be redesigned. (NEMA, 

Public Meeting Transcript, No. 48 at pp. 32, 37; NEMA, No. 56 at pp. 2, 10; NEMA, No. 

44 at p. 9; ULT, No. 50 at pp. 2, 4, 10) Therefore, NEMA suggested that the max-tech 

magnetic levels (EL2) of this rule be lower than proposed. (NEMA, No. 56 at p. 12) 

However, the Joint Comment provided a listing of various magnetic ballasts capable of 

meeting the max tech magnetic levels (EL2), 13 of which exceeded both EL2 and EL3, 

and two exceeded EL4. (Joint Comment, No. 62 at p. 6) The Joint Comment noted that 

reactor ballasts represent a high-efficiency magnetic alternative to electronic ballasts for 

many applications and urged DOE to model these ballasts as the equipment chosen by 

customers in many cases when the standard is set at EL3 or EL4. (Joint Comment, No. 62 

at p. 7)

DOE found that after revising its assumptions for M6 core losses, EL2 at 250 W 

(and other wattages) decreased relative to the NOPR. The 250 W EL2 is now set at 91.0 

percent based on an M6 ballast design. DOE’s analysis indicates both magnetic ballasts 

(using M6 steel) and electronic ballasts would be compliant with EL2 at 250 W. In 

110 
response to the model list given by the Joint Comment, the commercially available 

magnetic ballasts that were noted as capable of meeting EL2 were single-voltage reactor 

ballasts. DOE agrees that there are commercially available reactor ballasts that have 

increased efficiency compared to more common magnetic ballast circuit types, but has 

chosen not to model them for EL3 and EL4. Reactor ballasts have limited utility due to 

their single input voltage and reduced ability to mitigate input voltage variation relative 

to HX or CWA ballasts, though these limited features do lead to increased efficiency. As 

discussed in section V.C.7 of this notice, DOE bases its analysis on CWA and HX 

magnetic ballasts. DOE has accounted for the thermal and voltage transient concerns with 

electronic ballasts with the design changes discussed in section V.C.8 of this notice.

Fixture and Ballast Redesign

DOE noted in the NOPR that its modeling method would not require changes in 

ballast or fixture size relative to those currently commercially available. NEMA, ULT, 

and GE commented that DOE’s assumption that proposed ELs will not require changes to 

the size of the ballast is incorrect, especially for ballasts in the 50 W – 150 W range, 

noting that the fixtures would need to be replaced to reach those levels. (NEMA, No. 56 

at p. 14; ULT, No. 50 at p. 6; GE, Public Meeting Transcript, No. 48 at p. 190) ULT 

stated that as the ballast size would increase, the proposed financial analysis, and market 

and manufacturer impact, might be incorrect. (ULT, Public Meeting Transcript, No. 48 at 

p. 66) ULT asked how DOE could be sure that ballast size would not increase if in some 

cases ballasts meeting the max tech magnetic ELs were not yet commercially available. 

(ULT, Public Meeting Transcript, No. 48 at p. 140) Similarly, NEMA requested that 

DOE explain its assumption that there will be no size increase. (NEMA, No. 56 at p. 14) 

111 
However, CA IOUs and the Joint Comment supported DOE’s modeled teardown 

approach as an indicator of potential higher-efficiency equipment that could be 

manufactured in the future, and an indicator that the max tech magnetic standard levels 

would not necessarily increase ballast size. (CA IOUs, No. 54 at p. 2; Joint Comment, 

No. 62 at p. 6)

As discussed previously, DOE’s modeling approach for magnetic ballasts does 

not change the ballast footprint or stack height relative to a commercially available 

ballast. For example, when modeling an EL2 magnetic ballast, all parameters remain 

constant except for a substitution of the electrical steel. The cost and efficiency associated 

with the DOE’s magnetic ballast analysis is based on the constraint that ballast size 

(footprint and stack height) is not allowed to change. As discussed in section V.I of this 

notice, DOE notes that any modifications to fixtures necessary so that the fixture can be 

used in conjunction with electronic ballasts can be completed during the manufacturing 

process, and the costs associated with these new processes are accounted for in the MIA. 

This regulation does not require retrofitting of MHLFs already installed in the field.

CA IOUs also illustrated the existence of high efficiency magnetic ballasts 

throughout the wattage ranges, which conflicts with manufacturer claims that ELs beyond 

EL1 could not be achieved by magnetic ballasts. (CA IOUs, No. 54 at pp. 3-7) DOE 

notes that the ballasts found with higher than EL1 efficiencies in the CEC database were 

either reactor ballasts or ballasts capable of only one input voltage. As discussed in 

section V.C.7, DOE only identified ballasts that were quad-voltage and either CWA or 

HX as representative. While there are more efficient ballasts, if DOE were to set an EL 

112 
that only permitted single input voltage or reactor ballasts then there would be significant 

utility lost. 

NEMA and ASAP cautioned that any standard requiring a larger ballast for one 

wattage will likely require a larger ballast to be designed for all wattages within the 

associated range. This will increase the ballast size, weight, and the cost of materials 

(steel and aluminum) for a broad range of equipment – not just the wattage directly 

analyzed. (NEMA, No. 56 at p. 14; ASAP, Public Meeting Transcript, No. 48 at p. 63) 

For example, ULT commented that coverage of the 50 W – 100 W range would require 

redesign of all magnetic ballasts of that range. EEI and Acuity commented that increasing 

the size of a ballast would require increasing the size of the accompanying fixture, which 

would use more natural resources and would impact wind-loading requirements. (EEI, 

Public Meeting Transcript, No. 48 at p. 59; Acuity, Public Meeting Transcript, No. 48 at 

p. 59) ULT further affirmed that bigger ballasts would lead to alterations of fixture 

housing, and thus to a complicated replacement process affecting the entire installed base. 

Replacing all the MHLFs currently installed, especially in applications, such as light 

poles, where more than the fixture would have to change to accommodate the mounting 

of a larger ballast, would have a negative impact on the whole market. (ULT, Public 

Meeting Transcript, No. 48 at p. 61) APPA noted that altered design specifications and 

wind-loading requirements are significant cost adders. (APPA, Public Meeting 

Transcript, No. 48 at p. 62) 

As stated previously, DOE does not analyze a level that would require an increase 

in ballast size relative to commercially available ballasts. All magnetic ballasts are either 

113 
commercially available, or modeled using the size constraints of a commercially 

available ballast. All electronic ballasts analyzed are commercially available. Thus, DOE 

does not find that the ballast efficiencies analyzed in this final rule would necessitate an 

increase in ballast size. Regarding ballast weight, electronic ballasts tend to be lighter 

than magnetic ballasts. For fixtures, DOE analyzed the size of fixtures on pole tops 

(parking/area fixtures and acorn-style post tops) to determine if any ELs would increase 

the surface area of fixtures to the point of causing concerns with wind loading. DOE 

found no evidence that fixtures listed for only magnetic ballasts, versus those listed for 

both electronic and magnetic or only electronic had a systematically different wind 

resistance (effective projected area – surface area of the largest side) or overall weight. 

Thus, DOE does not find that the ballast efficiencies analyzed in this final rule would 

necessitate an increase in fixture size.

GE commented that manufacturers could choose to rate ballasts conservatively 

(i.e., overdesign the ballast) compared to standards, thus providing a cushion between the 

regulation and the ballasts’ tested efficiency. This approach would translate into 

increased size and material costs. (GE, Public Meeting Transcript, No. 48 at p. 89) 

DOE acknowledges that manufacturers have flexibility in choosing how to design 

and rate their products. However, DOE does not require manufacturers to rate a product 

at a certain increment above the adopted standard level. Therefore, DOE has not 

accounted for any increase in ballast size or material cost that may result from such a 

decision.

114 
b. Electronic Ballasts

In the NOPR, DOE analyzed electronic ballasts as higher-efficiency replacements 

for magnetic ballasts and based max-tech efficiencies for 50 W to 500 W MHLFs on 

commercially available electronic ballasts independently tested by DOE. In response to 

that approach, DOE received several comments, discussed below, regarding outdoor 

transient protection, thermal protection, fixture and ballast redesign, electronic ballast 

applications, HFE ballasts, lumen maintenance, and other issues.

Transient Protection

In the NOPR, DOE recognized the necessity for outdoor fixtures to be able to 

withstand large voltage transients, primarily due to lightning strikes. While MHLFs with 

magnetic ballasts are robust and do not require any additional devices or enhancements to 

withstand these transients, based on its evaluation of commercially available MHLFs, 

DOE found that fixtures with electronic ballasts usually require additional design features 

in order to have adequate protection. Some manufacturers indicated that a portion of their 

electronic ballasts already have 10 kV surge protection built in, but most electronic 

ballasts are only rated for 2.5 kV-6 kV voltage spikes. Though magnetic ballasts are 

known to provide protection in excess of the 10 kV specified by the ANSI C62.41.1-2002 

Class C rating, for the NOPR DOE only considered the cost of meeting the 10 kV 

requirement.

NEMA asserted the proposed efficiency standards would lead to a shift from 

magnetic to electronically ballasted fixtures that are more susceptible to transient surges. 

(NEMA, No. 56 at pp. 5-6; NEMA, No. 44 at p. 9; NEMA, Public Meeting Transcript, 

115 
No. 48 at pp. 32-33) The South Carolina Electric and Gas Company (SCE&G), APPA, 

NEMA, and ULT noted that the need for additional surge protection in outdoor 

applications using electronic ballasts is real, as they will not handle transient surges as 

well as magnetic ballasts. (SCE&G, No. 49 at p. 1; APPA, No. 51 at p. 5; NEMA, No. 56 

at p. 16; ULT, No. 50 at pp. 9-10) Acuity expressed concern that the efficiency standards 

could preclude necessary fixtures used in environments with transient voltage. (Acuity, 

Public Meeting Transcript, No. 48 at p. 162) SCE&G explained that magnetic ballasts 

contain larger coils and steel cores that better absorb energy. SCE&G added that the more 

robust protection required for electronic ballasts would add cost and complexity. 

(SCE&G, No. 49 at p. 1) Specifically, APPA and NEMA stated that transient surge 

protection would require a much larger front end or an external sacrificial device, 

resulting in additional reengineering cost. (APPA, No. 51 at p. 6; NEMA, No. 56 at p. 2) 

DOE agrees that electronic ballasts need additional surge protection in outdoor 

applications. In this final rule, DOE continues to find that by providing external surge 

protection up to the 10 kV requirement of ANSI C62.41.1-200, electronic ballasts can be 

used in the same outdoor locations as magnetic ballasts. The cost of the additional 

equipment in outdoor applications is added to the total fixture MSP (see section 

V.C.12.c). Using electronic ballasts outdoors may also result in increased maintenance or 

replacement costs for the voltage surge protection devices. These costs are accounted for 

in the LCC analysis (section V.F of this notice).

APPA, NEMA, and ULT noted that while it is not difficult to add extra surge 

protection, it is impossible to predict when the protection device will need to be replaced 

116 
and how many strikes any given surge protector can handle over its lifetime before the 

ballast and lamp are affected. APPA, NEMA, and ULT added that voltage transients can 

be variable in severity and timeframe. The current requirements for surge protection only 

cover 10 kV, even though surges of 20 kV are common. ULT stated that even with 

transient protection, electronic ballasts would likely not withstand voltage transients as 

well as magnetic ballasts do. When the surge protector has reached the end of its life, the 

next surge will cause the ballast to fail. (APPA, No. 51 at pp. 5, 6; NEMA, No. 56 at pp. 

2, 16; ULT, No. 50 at pp. 12-13. 16). SCE&G further commented that resources will be 

consumed while installing and repairing fixtures with electronic ballasts damaged by 

lightning. (SCE&G, No. 49 at p. 1) The Joint Comment agreed that the surge protection 

device might need to be replaced during a fixture’s lifetime for some fixtures and this 

additional maintenance and repair cost should be analyzed by DOE. (Joint Comment, No. 

62 at p. 5) 

DOE has included the cost of transient protection capable of surge protection up 

to 10 kV in its estimates of the initial cost of outdoor MHLFs with electronic ballasts, as 

that is the level specified in ANSI C136.2-2004. DOE agrees that one difficulty arising 

from the addition of transient protection to electronic ballasts in voltage transient affected 

areas is the uncertainty in how many strikes the protection will be able to absorb and 

when the protective device will be sacrificed and the ballast made vulnerable. This 

vulnerability will affect the maintenance costs and average lifetime of outdoor electronic 

ballasts. See section V.F of this notice for discussion of these costs.

117 
APPA suggested that DOE take into account data regarding the frequency and 

severity of lightning strikes in the United States and revise the forecasts for maintenance 

costs given the frequency and effect of strikes. A lightning strike can affect fixtures 

within a square kilometer, and according to National Lightning Safety Institute data, 

which would affect hundreds of ballasts each year. (APPA, No. 51 at p. 6) APPA and 

NEMA noted that besides lightning, there could be many other causes of transient surges, 

such as wind, transmission line movement, wind generator surges, equipment or load 

switching, and collapse of sections of a distribution network. (APPA, No. 51 at p. 6; 

NEMA, No. 56 at p. 17) APPA and NEMA urged DOE not to eliminate the desirable 

performance characteristics of magnetic ballasts from the market. APPA and NEMA 

predicted that replacement rates for outdoor fixtures would increase significantly for 

utilities and could cause safety and security concerns. (APPA, No. 51 at p. 6; NEMA, No. 

56 at p. 16) Therefore, APPA and NEMA stated that the many causes of transient surges 

make magnetic ballasts necessary in outdoor applications. (APPA, No. 51 at p. 6; NEMA, 

No. 56 at p. 17)

As discussed previously, DOE has determined that electronic ballasts can be used 

as substitutes for magnetic ballasts when the necessary design changes are included. DOE 

agrees that transient protection is a critical consideration, which is why DOE is modeling 

electronically ballasted fixtures sold with transient protection devices, and also including 

transient protection device and ballast replacement costs. See section V.F of this notice 

for details on how DOE models the frequency with which outdoor ballasts encounter 

surges, and how those translate directly to increased maintenance and replacement costs, 

and the cost-effectiveness of these measures.

118 
NEMA and ULT noted that indoor applications also expose ballasts to high 

voltage transients. While transient protection is needed to protect against lighting strikes 

in any outdoor application, it is also needed in heavy industrial indoor applications where 

large machinery can send massive transients across the power lines when they are turned 

on. (NEMA, No. 56 at p. 16; ULT, No. 50 at pp. 9-10) 

In researching transient protection for the final rule, DOE found that indoor 

industrial fixtures are also subject to voltage surges. DOE has thus included voltage 

transient protection in its price analysis for indoor electronic ballasts experiencing 

transient surges in these industrial applications. Specifically, DOE analyzes the indoor 

industrial applications that require additional surge protection as an LCC subgroup. DOE 

found that indoor industrial MHLFs could experience voltage surges up to 6 kV. The 

voltage transient protection device used in DOE’s analysis can withstand 120 surges of 3 

kV, 18 surges of 6 kV, or 5 surges of 10 kV before failure. LCC subgroups are discussed 

in section V.H and the results of the subgroup analysis are presented in section VII.B.1.b. 

Thermal Protection

In the NOPR, DOE found that fixtures with electronic ballasts had to be designed 

to tolerate electronic ballasts’ higher sensitivity to temperatures. Manufacturers must 

design new and often larger brackets, and apply additional potting material, for example, 

to create an adequate thermal contact between the ballast and fixture housing. Based on 

manufacturer feedback and fixture teardown costs, DOE found that there was an 

119 
approximately 20 percent increase in fixture MPCs to include thermal management for 

electronic ballasts.

Several stakeholders commented on the heat sensitivity of electronic ballasts. 

SCE&G stated that the most serious flaw of the electronic MH ballast concept is heat 

dissipation. The heat sensitivity of electronic ballasts would lead to a larger fixture, so 

that the fixture could achieve proper thermal management, adding cost and using more 

resources. (SCE&G, No. 49 at p. 1) One issue identified by stakeholders regarding the 

thermal management of electronic ballasts is that electronic ballasts cannot operate in the 

same temperature environments as magnetic ballasts. SCE&G, APPA, and NEMA stated 

that most electronic ballasts have an 80 °C internal operating temperature (or case 

temperature) limit, while their magnetic counterparts are in the greater than 180 °C range. 

(SCE&G, No. 49 at p. 1; APPA, No. 51 at p. 5; NEMA, No. 56 at pp. 5-6; NEMA, No. 

44 at p. 9; NEMA, Public Meeting Transcript, No. 48 at pp. 32-33) ULT commented that 

this case temperature limitation results in the unavailability of electronic ballasts rated for 

operation in ambient air with a temperature higher than 50 °C. (ULT, No. 50 at pp. 2, 8-

10) APPA and NEMA stated that this poses significant maintenance and operations 

issues for existing fixtures. In some cases, protecting against temperature sensitivity 

would require a utility to move from ballast replacement to entire fixture replacement. 

(APPA, No. 51 at pp. 5, 8; NEMA, No. 56 at pp. 2, 16, 24) Acuity expressed concern for 

high wattage fixtures used in extreme applications, stating that the efficiency standards 

could preclude necessary fixtures from being available for use in environments with high 

temperatures. (Acuity, Public Meeting Transcript, No. 48 at p. 162)

120 
In addition, several stakeholders noted that the design of existing fixtures may 

create high temperature environments within the fixture itself, which would be unsuitable 

for electronic ballasts. Philips commented that many MHLFs are designed with the core 

and coil of the ballast directly above the lamp, which creates a high temperature 

environment in which electronic ballasts cannot survive. (Philips, Public Meeting 

Transcript, No. 48 at p. 188) In addition, Philips stated that with higher system input 

power, there are often higher temperature environments, and it is difficult to find 

components, especially capacitors, rated at those high temperatures. (Philips, Public 

Meeting Transcript, No. 48 at pp. 194-195) GE questioned whether the EL models took 

into account thermal conditions and luminaire design, or if it just assumed the boundary 

conditions would match the ballast. GE ultimately agreed that DOE’s model does not 

include the thermal characteristics of the fixture or the boundary conditions. (GE, Public 

Meeting Transcript, No. 48 at pp. 147, 217)

DOE agrees that thermal protection is required to render electronic ballasts 

suitable substitutes for magnetic ballasts in all applications. DOE accounts for this cost in 

section V.C.12 of this final rule. DOE also analyzed the commercially available fixtures 

that are advertised for use with electronic ballasts in outdoor locations. In extreme heat 

conditions, DOE has determined that electronic ballasts typically operate up to case 

temperatures of 80-90 °C. While magnetic ballasts themselves are able to handle 

temperatures as extreme as 180 °C, a magnetic ballast must be paired with a capacitor 

and DOE has determined that the capacitor typically only carries a temperature rating of 

about 100 °C. Furthermore, pulse start magnetic ballasts must be paired with an igniter in 

addition to a capacitor and DOE has determined that the igniter also typically carries a 

121 
temperature rating of about 100 °C. Based on manufacturer interviews and assessment of 

commercially available fixtures, DOE believes that thermal design changes, such as new 

brackets or additional potting material to create an adequate thermal contact between the 

ballast and fixture housing, can address this 10-20 °C difference in temperature rating 

between electronic and magnetic ballasts. Therefore in this final rule, as in the NOPR, 

DOE has included a 20 percent increase in fixture MPCs to account for increased thermal 

management for electronic ballasts.

DOE acknowledges that existing fixtures designed for magnetic ballasts may not 

be suitable for electronic ballasts due to the need for increased thermal management. This 

rulemaking does not require retrofits of fixtures currently installed in the field. Any

modifications to fixture design would be completed by the fixture manufacturer and 

incorporated in any new fixture sales. Fixture manufacturers already sell fixtures rated for 

use with electronic ballasts.

Fixture and Ballast Redesign

When analyzing electronic ballast levels (EL3 and EL4) in the NOPR, DOE 

assumed that the main design changes required to allow electronic ballasts were to 

increase thermal management, add voltage transient suppression, and add 120 V auxiliary 

power functionality. The costs of these design changes are discussed in section V.C.12 of 

this notice. In addition to the increased costs associated with these design changes, DOE 

also accounted for manufacturer conversion costs in the MIA.

122 
ASAP agreed with DOE’s methodology in analyzing the challenges and costs 

associated with using electronic ballasts in outdoor applications. (ASAP, Public Meeting 

Transcript, No. 48 at pp. 57, 62) CA IOUs and the Joint Comment stated that major 

manufacturers already offer electronic ballasts designed to be used outdoors. Further, 

electronic ballasts generate less internal heat and already make up approximately 25 

percent of sales for some wattage bins. In addition, using the CEC compliance database, 

CA IOUs illustrated the high efficiency and availability of electronic ballasts for indoor 

and outdoor applications. (CA IOUs, No. 54 at pp. 3-7; CA IOUs, Public Meeting 

Transcript, No. 48 at p. 202; Joint Comment, No. 62 at pp. 4-5) 

DOE also received several comments that questioned the feasibility of using 

electronic ballasts in all applications, in particular how requiring electronic ballasts could 

impact the need for ballast and fixture redesign. ULT stated that there is a difference 

between commercially available LFE ballasts and commercially available MHLFs 

effectively incorporating such ballasts. (ULT, Public Meeting Transcript, No. 48 at p. 

204) APPA, the National Rural Electric Cooperative Association (NRECA), ULT, and 

EEI stated that magnetic ballasts are better suited to withstand temperature and transient 

extremes, wet locations, heat from the lamp, and would require larger fixtures. Therefore, 

the switch to electronic ballasts would require new designs, retooling, and cause a lack of 

replacements for existing fixtures. (APPA, No. 51 at p. 4; NRECA, No. 61 at p. 2; ULT, 

No. 50 at p. 2; EEI, No. 53 at p. 3) NEMA commented further that electronic ballasts for 

outdoor applications would need to be redesigned, and hardened and sealed, and thus 

made larger. (NEMA, No. 56 at p. 6) While California has regulations that require 

electronic ballasts in certain situations, NEMA pointed out that efficiency standards in 

123 
California are low enough that the amount of redesign was not as challenging as it would 

be for some of the levels presented in the NOPR. (NEMA, Public Meeting Transcript, 

No. 48 at p. 199)

Stakeholders further stated that, because of the increased size of electronic 

ballasts and fixtures, there would be significant impacts on existing fixtures. APPA, 

NRECA, ULT, and EEI commented that the switch to electronic ballasts would require 

new designs, retooling, and cause a lack of replacements for existing fixtures. (APPA, 

No. 51 at p. 4; NRECA, No. 61 at p. 2; ULT, No. 50 at p. 2; EEI, No. 53 at p. 3) EEI 

elaborated, stating that electronic ballasts used for outdoor fixtures are larger and heavier 

than magnetic ballasts, which would make it harder to replace ballasts in existing 

fixtures. (EEI, No. 53 at p. 3) GE asserted that switching to electronic ballasts, especially 

outdoors, would take a great deal of care, attention, design, and development because it is 

not possible to put an electronic ballast into an existing magnetic fixture. (GE, Public 

Meeting Transcript, No. 48 at p. 198) APPA expressed concern regarding the ability to 

maintain existing infrastructure and Cooper Lighting (Cooper) cautioned against 

replacement fixtures not matching installations. (APPA, Public Meeting Transcript, No. 

48 at p. 196; Cooper, Public Meeting Transcript, No. 48 at p. 71) In addition, Cooper 

commented that lighting fixtures are usually UL listed with a certain type of ballast and 

have fit and thermal issues among different suppliers. (Cooper, Public Meeting 

Transcript, No. 48 at p. 74) NEMA asserted the proposed efficiency standards would 

force a shift from magnetic to larger electronic ballasts that would not be interchangeable 

in fixtures. (NEMA, No. 56 at pp. 5-6; NEMA, No. 44 at p. 9; NEMA, Public Meeting 

Transcript, No. 48 at pp. 32-33) 

124 
DOE agrees that there would need to be adjustments made to the MHLF system to 

allow electronic ballasts to be used outdoors. DOE determined that electronic ballasts are 

capable of use outdoors by adding transient protection, thermal protection, and using 

fixtures specifically designed to be used outdoors. Outdoor fixtures that use electronic 

ballasts already exist in the marketplace and DOE research did not indicate any trend of 

these fixtures being larger than comparable magnetic fixtures for the same wattage 

products. Furthermore, as discussed in section V.C.12, DOE revised its methodology for 

determining fixture pricing to ensure that the costs for outdoor fixtures housing electronic 

ballasts also incorporate the necessary weatherization.

DOE contends that the levels analyzed in this rulemaking will not require 

increases in ballast size. All magnetic ballast levels are designed to be achievable with 

magnetic ballasts commercially available or using magnetic ballasts that are the same size 

as commercially available ballasts. When switching to electronic ballasts, DOE notes that 

the sizes and shapes of electronic ballasts are typically different from magnetic ballasts 

(longer length but narrower width), but do not increase to a size that would cause concern 

about their use in any applications where magnetic ballasts are used. Any fixture redesign 

that is required to ensure fixtures comply with adopted standards was taken into account 

in the economic analyses of the final rule. As discussed above, DOE acknowledges that 

the surge protection device might need to be replaced during the fixture’s lifetime and 

this maintenance cost, as well as potential early replacement costs from the surge 

protection being sacrificed and the next strike compromising the electronic ballast, are 

taken into account in the LCC analysis (section V.F of this final rule).

125 
DOE has determined that replacement fixtures should have no issues with the 

adopted standard, as the size and weight of fixtures do not need to increase for any of the 

levels. While certain fixtures may require redesign for new ballast types, such as 

electronic, the overall size and weight of fixtures does not increase. DOE agrees that 

certain fixtures are UL listed and have compatibility assured with specific types of 

ballasts—but the ballasts affected by this rulemaking are those being placed in new 

fixtures and not those being used as replacements in existing fixtures. Any new fixture 

sold will be able to be cleared for UL listing and compatibility with the ballast included 

in the final assembly.

Regarding the most efficient levels analyzed, which require electronic ballasts, 

Philips stated that LFE MH ballasts cannot be made more efficient than the equipment 

already available. (Philips, Public Meeting Transcript, No. 48 at p. 70) DOE agrees that 

the efficiency of low frequency ballasts cannot be improved beyond that of currently 

commercially available ballasts. DOE’s max tech electronic level (EL4) is based on 

commercially available low frequency ballasts.

In summary, in this final rule, DOE continues to model the cost of switching from 

magnetic ballasts to electronic ballasts, accounting for thermal management, transient 

protection, and general weatherization of the fixture in applications in which it is 

required.

Applications 

126 
Because DOE concluded that electronic ballasts and magnetic ballasts could 

provide the same utility in the wattages that electronic ballasts are offered (50 W to 500 

W), DOE concluded in the NOPR that there was no application unique to magnetic or 

electronic ballasts. With the proper adjustments to the fixture, electronic ballasts could be 

used anywhere magnetic ballasts are used.

Several manufacturers commented on the prevalence of commercially available 

MHLFs listed for use with electronic ballasts. Cooper commented that they only use 

electronic ballasts in select MHLFs, including a very limited number of low-wattage 

fixtures in some garage applications. (Cooper, Public Meeting Transcript, No. 48 at p. 

191) GE stated that they carry a 400 W electronic ballast, but it is used in retail 

applications with ideal operating conditions. (GE, Public Meeting Transcript, No. 48 at p. 

191) Philips, on the other hand, commented that they make a lot of electronic MH 

ballasts, anywhere from 25 W to 400 W, mostly used in retail applications. However, 

these ballasts are primarily for use with CMH lamps and would not be suitable in existing 

fixtures, regardless of lamp type, without significant redesign. Philips added that there are 

no components available for applications greater than 400 W and the costs are 

approximately three times higher than magnetic ballasts (Philips, Public Meeting 

Transcript, No. 48 at pp. 192-193, 195) Acuity commented that the only applications with 

which they use electronic ballasts and low-wattage fixtures are downlights, cylindrical 

architectural lighting, and spaces meant for low-wattage fixtures where there is good 

power quality and no extreme temperatures. (Acuity, Public Meeting Transcript, No. 48 

at p. 192) CA IOUs clarified that as this ruling applies to new fixtures only, they do not 

127 
see a problem with electronic ballasts being used outdoors. (CA IOUs, Public Meeting 

Transcript, No. 48 at p. 196)

DOE identified fixtures for sale with electronic ballasts that were advertised for 

and intended for use in outdoor applications, such as exterior post top, outdoor area, 

bollard, canopy, security, and wall pack lighting. Manufacturers selling these fixtures did 

not provide any indication that they were to be used in a more limited set of applications 

relative to magnetic ballasts and did not contain warnings with regard to particular 

conditions that should be avoided when using those fixtures. For the previously described 

reasons, DOE has found that electronic ballasts can be used in outdoor applications 

assuming the proper adjustments have been made to the fixtures. Any overall fixture 

redesign or conversion costs incurred by the manufacturer to switch production to 

fixtures meeting these levels are accounted for in the MIA (see section V.I.4). DOE 

emphasizes that this rulemaking only applies to new fixtures.

High-Frequency Electronic Ballasts

In the NOPR, DOE analyzed HFE ballasts and determined that they were a valid 

design option to improve ballast efficiency. DOE acknowledged the lack of compatibility 

with CMH lamps, but proposed to take those impacts into account when adopting any 

amended standards.

NEMA commented that in the 320 W – 400 W range, when developing electronic 

ballasts the industry is split between low-frequency square wave and high-frequency. 

(NEMA, Public Meeting Transcript, No. 48 at p. 28) However, NEMA warned that HFE 

128 
ballasts are not compatible with all MH lamps; the size of the arc tube could lead to 

acoustic resonance problems, which cause arc instability and possible rupture of the arc 

tube. This would lead to compatibility problems where a ballast or lamp could not be 

readily replaced. (NEMA, Public Meeting Transcript, No. 48 at p. 28) NEMA expressed 

concern that there would likely be very limited lamp models that could be used with these 

high-efficiency, high-frequency ballasts. (NEMA, Public Meeting Transcript, No. 48 at p. 

29; NEMA, No. 56 at p. 15) ULT agreed, commenting that there are applications where 

an electronic ballast will not work and an HFE-only standard would therefore be a 

mistake. (ULT, No. 50 at p. 8)

DOE agrees that there are compatibility issues with HFE ballasts and CMH lamps 

and that there are no industry standards in place for HFE ballasts. As discussed in section 

III.A.4, DOE has decided to not consider standards for HFE ballasts in this rulemaking. 

Given that HFE ballasts are no longer in the scope of the final rule, DOE revised the 400 

W EL4 representative unit to be an LFE ballast. The final rule only analyzes LFE ballasts 

as representative units.

Lumen Maintenance

When analyzing the potential energy savings of electronic ballasts in the NOPR, 

DOE only considered the savings that would come from increased ballast efficiency. It 

was assumed that increased ballast efficiency when using the same wattage electronic 

MH system would still provide an equivalent light output.

129 
The Joint Comment expressed its belief that DOE has significantly 

underestimated the energy and economic savings from electronic ballasts because lamps 

driven by electronic ballasts experience better lumen maintenance, which allows for 

fewer fixtures or lower-wattage lamps and less frequent re-lamping. (Joint Comment, No. 

62 at pp. 1-2) The Joint Comment cited the following sources in support of the positive 

impact electronic ballasts have on lumen maintenance: (1) Natural Resources Canada 

stated an electronic ballast produced 15 percent more light output after 8000 hours; (2) 

GE claimed their UltraMaxTM electronic ballast produced 13 percent higher mean 

lumens at 40 percent of rated life than an MH system using a pulse-start magnetic ballast; 

(3) Advance claimed that their DynaVision® electronic ballast delivered a 20 percent 

improvement in lumen maintenance at 40 percent of rated life over a pulse-start MH 

system; and (4) Holophane claimed that electronic ballast technology increased mean 

lumen output by 13 percent on pulse-start lamps and stated that improved lumen 

maintenance is the most fundamental benefit of electronic HID ballasts. (Joint Comment, 

No. 62 at p. 2)

DOE researched the potential increase in lumen maintenance when switching 

from magnetic to electronic ballasts. While the comments cited several different 

examples of systems whose lumen maintenance was increased with electronic ballasts, 

DOE did not find universal agreement across the industry regarding the impact of 

electronic ballasts on lumen maintenance. While there seemed to be general agreement 

that electronic ballasts may have increased lumen maintenance, the literature indicated 

that specific claims may be unique to certain combinations of lamps and ballasts. There is 

no assurance that customers would choose an electronic ballast or lamp that would 

130 
increase lumen maintenance if DOE adopted an electronic ballast standard level. As such, 

DOE maintains the approach from the NOPR to only consider the energy savings from 

increased ballast efficiency.

Additional Considerations

NEMA stated that mandating ELs that preclude any technology but pulse-start 

electronically ballasted MHLFs would cause increased maintenance and material costs 

due to surge and lightning resistance, increased fixture size and price, added weather 

resistance, remote igniter installation, and the higher maintenance cost and considerations 

of high-mast lighting fixtures. (NEMA, No. 56 at p. 8) APPA and Florida Power and 

Light were skeptical about electronic ballasts being able to withstand all types of outdoor 

threats, such as extreme cold, extreme heat, humidity, salt water, salt air, surge, sag, and 

swell. (APPA, Public Meeting Transcript, No. 48 at p. 196; Florida Power and Light, 

Public Meeting Transcript, No. 48 at p. 204) NEMA stated that electronic ballasts would 

require added capabilities of weather resistance, surge resistance, and thermal resilience. 

(NEMA, Public Meeting Transcript, No. 48 at p. 70) 

DOE has accounted for the additional costs at any level requiring the use of 

electronic ballasts. DOE also agrees that electronic ballasts used outdoors require general 

weatherization. To account for this, DOE conducted additional fixture teardowns for this 

final rule to come up with a fixture price at each representative wattage that was unique 

for indoor versus outdoor applications. This way the outdoor fixtures incorporating 

electronic ballasts will account for the necessary weatherization. Weather resistance, 

voltage transient protection, and thermal protection are incorporated into the full fixture 

131 
MSPs (see section V.C.12). Any potential redesign required of manufacturers is 

considered in the MIA (see section V.I.4). Maintenance is considered in the LCC analysis 

(see section V.F). DOE investigated whether a standard that requires an electronic ballast 

would negatively impact high-mast lighting applications using remote ballast placement. 

Some electronic ballasts are capable of starting lamps up to 33 feet, but magnetic ballasts

can perform remote starting and lamp operation from longer distances. Unlike magnetic 

pulse-start ballasts, the ballast to lamp distance cannot be increased with a remote igniter, 

because this remote igniter device is not available for use with electronic ballasts. DOE 

investigated high-mast applications and determined some roadway applications with 30 

to 40 foot poles could be utilizing the remote starting feature. It is unclear what 

percentage, if any, of the 30 to 40 foot poles use remote ballast placement, such that the 

remote starting ability of electronic ballasts would be an issue. Further, DOE notes that 

electronic ballasts are capable of starting lamps at distances exceeding 30 feet. The other 

main category of high-mast applications includes those at extreme heights, at least 100 

feet, typical of sports stadium or airfield lighting. These applications require fixtures of 

1000 W or higher. Because DOE is not analyzing efficiency levels that would require 

electronic ballasts at these high wattages, these high-mast, high-wattage MHLFs do not 

pose a concern. In summary, DOE concluded the need for remote starting does not 

necessitate the usage of magnetic ballasts. 

Florida Power and Light commented that electronic ballasts are designed to work 

on a National Electrical Safety Code (NESC) three-wire system. However, Florida Power 

and Light runs a NESC two-wire system and is having difficulties with electronic drivers. 

Florida Power and Light stated that they have heard of similar issues from other utilities, 

132 
such as Duke Energy and National Grid, and are very concerned about being forced into 

using electronic ballasts. (Florida Power and Light, Public Meeting Transcript, No. 48 at 

p. 204) DOE reviewed manufacturer literature for a variety of electronic ballasts and 

found no requirements that they be used in conjunction with a specific wiring scheme. 

The literature does stipulate that the electronic ballast should be grounded to earth, but 

does not speak to preferred or required wiring systems. DOE continued to analyze 

electronic ballasts in outdoor locations for this final rule.

9. Efficiency Levels

Based on the higher-efficiency ballasts selected for analysis, discussed in section 

V.C.8, DOE developed ELs for the representative equipment classes. EL1 represented a 

moderately higher-efficiency magnetic ballast, and EL2 represented the max-tech 

magnetic ballast. EL1 and EL2 were characterized by a combination of commercially 

available and modeled magnetic ballasts. EL3 represented the least efficient 

commercially available electronic ballast, and EL4 represented the max-tech level for all 

ballasts incorporated into MHLFs. In the NOPR, DOE created four ELs for the 

equipment classes with the 70 W, 150 W, 250 W, and 400 W representative wattages. 

Due to the fact that DOE did not analyze electronic ballasts for the 1000 W representative 

wattage, DOE analyzed only two ELs in the equipment class above 500 W.

NEMA and ULT offered revised efficiency equations, suggesting efficiencies 

lower than the NOPR proposed levels. The levels are set with linear equations from 50 to 

150 W and 500 to 1000 W, with a flat efficiency of 88 percent from 150 to 500 W. 

(NEMA, No. 56 at pp. 17-19; ULT, No. 50 at pp. 10-11) Philips commented that 

133 
opportunities to further increase efficiency in this market have been explored and all 

economically feasible efficiency gains have already been achieved. (Philips, Public 

Meeting Transcript, No. 48 at p. 55) NEMA added to this point, stating that commercial 

markets, such as sports lighting, are already aggressively managing their costs and trying 

to get the most efficient equipment. (NEMA, Public Meeting Transcript, No. 48 at p. 56)

In this final rule, all of the max-tech levels are commercially available. All lower 

ELs analyzed are either commercially available or technologically feasible based on 

DOE’s revised ballast modeling. To develop efficiency-level equations in this final rule, 

DOE utilized its own efficiency test data as well as catalog efficiency data and modeling 

to develop the equation forms and efficiency trends for each wattage range. The 

efficiency-level equations are generally designed to closely match the efficiency of the 

more-efficient representative units identified for each equipment class. The discussion 

below describes the equations used in each wattage bin. For further details, see chapter 5 

of the final rule TSD.

For the lowest two wattage bins, which consist of 50 W – 150 W ballasts, DOE 

used its own test data, as well as efficiency trends according to catalog data and modeled 

more-efficient units, to generate separate power-law equations for magnetic (EL1 and 

EL2) and electronic (EL3 and EL4) ballasts.

The next wattage bin consists of 150 W ballasts, excluding those in the currently 

exempt 150 W fixtures, through and including 250 W ballasts. Because EISA 2007 

covered equipment in this wattage bin, DOE can only evaluate efficiencies equal to or 

134 
above the existing standards to avoid backsliding. 150 W magnetic ballasts cannot be 

designed to meet the EISA 2007 standard of 88 percent efficiency and 175 W ballasts 

only reach 88 percent by using M6 steel. DOE’s test data also indicated that there are no 

150 W or 175 W magnetic ballasts available that exceed 88 percent efficiency. Though 

DOE did not test any 200 W ballasts, a review of the CCE database indicates that 200 W 

ballasts are typically only available at about 88 percent efficiency. Because DOE has no 

specific information indicating that these ballasts can be designed to be more efficient, 

DOE assumed that 88 percent is also the max-tech magnetic ballast efficiency for 

wattages up through 200 W. Thus, DOE maintained the EISA 2007 efficiency 

requirement of 88 percent for ELs designed to represent levels met by magnetic ballasts. 

DOE did not have any information available about the achievable efficiencies for 201 W 

– 250 W ballasts, as ballasts in this range are not commercially available. Therefore, 

DOE gradually increased the magnetic ELs (EL1 and EL2) between 200 W and 250 W 

ballasts using a linear trend from 88 percent to the efficiency of the EL1 and EL2 250 W 

representative units. For the electronic ballast levels (EL3 and EL4), DOE continued the 

power-law function fit from the 50 W – 150 W range to 250 W. 

The next wattage bin consists of 251 W – 500 W ballasts. Because the 250 W and 

400 W magnetic representative units at EL1 and EL2 have the same efficiency and utilize 

similar design options, DOE created a flat efficiency requirement for magnetic ballasts in 

this wattage bin. For the electronic ballast levels (EL3 and EL4), DOE continued the 

power-law function fit from the 50 W – 250 W range to 500 W. 

135 
The next wattage bin consists of 501 W – 1000 W ballasts. DOE examined 

catalog data for market availability and found no electronic ballasts for general lighting 

applications commercially available above 500 W. Thus, there are only two ELs at this 

wattage range rather than four. NEMA submitted written comments indicating that 

different groups of ballasts have different relationships between lamp current squared and 

lamp wattage. (NEMA, No. 56 at p. 13) Through review of ANSI C78.81-2010 and lamp 

datasheets, DOE found lamps with rated wattages between 501 W and 750 W generally 

had different lamp voltages than lamps with rated wattages between 751 W and 1000 W, 

suggesting a difference in ballast efficiency trends across the 750 W threshold. Therefore, 

DOE used linear equations from 501 W – 750 W that (1) connect to the EL1 and EL2 

equations from the 251 W – 500 W equipment class, and (2) connect to the least efficient 

750 W ballasts on the market at 91 percent. Then from 751 W – 1000 W DOE used linear 

equations that (1) connect to 91 percent at the low wattage end, and (2) connect to the 

EL1 and EL2 representative unit efficiencies at 1000 W. This approach to the 501 W – 

1000 W equipment class also has the advantage of encouraging purchase of lower 

wattage ballasts, by ensuring that commercially available options remain on the market at 

EL1 and EL2.

The highest wattage bin consists of 1001 W – 2000 W ballasts. DOE again found 

no electronic ballasts in this wattage range, so there are only two levels of efficiency at 

the highest wattage range rather than four. After examining the efficiency trends among 

commercially available ballasts in this wattage bin, DOE used a flat linear equation above 

1000 W due to the limited data available regarding an efficiency trend for these wattages. 

DOE anchored the line from the previous wattage bin’s 1000 W efficiencies at EL1 and 

136 
EL2 and confirmed the equation allows the representative units at 1500 W to just meet 

their respective ELs.

Table V.4 summarizes all of the functions and efficiencies describing each 

equipment class.

137 
Table V.4 Efficiency Level Descriptions for the Representative Equipment Classes

Representative Equipment 

Class

Rep. 

Wattage EL Minimum Efficiency Equation†

% 

≥50 W and ≤100 W 70 W

EL1 1/(1+1.33∗×P^(-0.346)) †

EL2 1/(1+1.24∗×P^(-0.351))

EL3 1/(1+0.600∗×P^(-0.340))

EL4 1/(1+0.360∗×P^(-0.297))

>100 W and <150 W* 150 W

EL1 1/(1+1.33∗×P^(-0.346))

EL2 1/(1+1.24∗×P^(-0.351))

EL3 1/(1+0.600∗×P^(-0.340))

EL4 1/(1+0.360∗×P^(-0.297))

≥150 W** and ≤250 W 250 W

EL1 ≥150 W and ≤200 W:

0.880 

>200 W and ≤250 W:

0.000400*×P + 0.800

EL2 ≥150 W and ≤200 W:

0.880 

>200 W and ≤250 W:

0.000600*×P + 0.760

EL3 1/(1+0.600∗×P^(-0.340))

EL4 1/(1+0.360∗×P^(-0.297))

>250 W and ≤500 W 400 W

EL1 0.900 

EL2 0.910 

EL3 1/(1+0.600∗×P^(-0.340))

EL4 1/(1+0.360∗×P^(-0.297))

>500 W and ≤1000 W 1000 W

EL1 >500 W and ≤750 W:

0.0000400*×P+0.880

>750 W and ≤1000 W: 

0.0000840*×P + 0.847

EL2 >500 W and ≤750 W:

0.910

>750 W and ≤1000 W: 

0.000104*×P + 0.832

>1000 W and ≤2000 W 1500 W

EL1 0.931

EL2 0.936

*Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use 

in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for 

use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated 

to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.

†P is defined as the rated wattage of the lamp the MHLF is designed to operate.

10. Design Standard

Under 42 U.S.C. 6295(hh)(4), DOE is permitted to set an energy efficiency 

standard based on both design and performance requirements. EISA 2007 required probestart ballasts to be 94 percent efficient, effectively banning probe-start ballasts between 

Comment [AGA12]: Change requested by 

OIRA.

138 
150 W and 500 W (except those 150 W ballasts exempted by EISA 2007) based on their 

inability to meet this performance requirement. (42 U.S.C. 6295(hh)(1)(A)(ii)) 

Manufacturers responded to the EISA 2007 standards by shifting their inventory to pulsestart ballasts, which are subject to less stringent standards. In the NOPR, DOE proposed a 

design standard that would prohibit the sale of probe-start ballasts in newly sold fixtures 

from 501 W – 2000 W.

The Joint Comment supported standards for high-wattage fixtures and agreed that 

a design standard prohibiting probe-start ballasts could yield additional energy savings by 

allowing a customer to install fewer or lower-wattage pulse-start fixtures. If DOE found 

that a design standard for the highest wattage products was not feasible or cost effective, 

the Joint Comment urged DOE to split the highest-wattage equipment class into two 

classes—one for 501 W – 1000 W fixtures and one for 1001 W – 2000 W fixtures—such 

that the design standard could be applied to only 501 W – 1000 W fixtures. (Joint 

Comment, No. 62 at p. 8)

DOE agrees that the design standard could result in energy savings through 

various potential energy saving pathways. As discussed in section V.A.2, in the final rule 

DOE has established separate equipment classes for 501 W – 1000 W MHLFs and 1001 

W – 2000 W MHLFs. As a result, DOE analyzed the feasibility of the design standard 

separately for these two wattage ranges.

In the NOPR, DOE based its analysis of the design standard on the 1000 W 

MHLFs. For the final rule DOE continues to analyze the 1000 W MHLFs, but only as 

139 
representative of the 501 W – 1000 W equipment class. The Joint Comment disagreed 

with DOE’s figure proposed in the NOPR of a 5.6 increase in lumen maintenance 

corresponding to a 5.6 percent reduction in normalized input system power and instead 

predicted higher energy savings of 12.5 percent. (Joint Comment, No. 62 at p. 8) Musco 

Lighting also did not agree with the 5.6 percent energy savings assumed in the NOPR, 

but predicted it would be a smaller percentage. Musco Lighting stated that in sports 

lighting applications, which are common at the higher wattage range, the lamp arc tube is 

horizontal or in a tilted position, yielding less projected energy savings than calculated 

with a vertical base up position. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 

180) Musco Lighting provided further data demonstrating that 1500 W probe-start start 

applications have greater efficiency than 1000 W or 2000 W pulse-start when operated in 

a horizontal position. Furthermore, Musco Lighting commented that while the probe in 

probe-start lamps contributes to the blackening of the arc tube in lower-wattage lamps, as 

the size of the arc tube increases in higher-wattage lamps, the probe does not increase in 

size and thus has less of an impact. In larger arc tubes, the blackening is driven 

principally by the primary electrodes, which are present in pulse-start lamps as well. 

(Musco Lighting, No. 55 at p. 2) Philips commented that there are no efficiency 

differences between probe-start and pulse-start at or above 1000 W. (Philips, Public 

Meeting Transcript, No. 48 at p. 130) Acuity noted that the majority of the energy 

savings at 1000 W would come from the lamp rather than the ballast. Acuity questioned 

whether or not the statutory authority allows energy savings to be calculated using gains 

in lamp performance, as this MHLF rulemaking is based on ballast efficiency. (Acuity, 

Public Meeting Transcript, No. 48 at p. 173)

140 
DOE notes that the intent of the design standard is to encourage customers to 

switch to reduced-wattage pulse-start from full-wattage probe-start systems due to the 

observation that pulse-start lamps have better lumen maintenance. For the 501 W – 1000 

W equipment classes, DOE has adjusted the assumption that pulse-start systems have 5.6 

percent higher mean lumens which would result in 5.6 percent energy savings. DOE

presents two commercially available pathways that an existing 1000 W probe-start 

customer could take in response to the design standard: shifting to an 875 W pulse-start 

system, or staying at 1000 W and shifting to a pulse-start system. The shift to pulse-start 

at 1000 W would result in additional light output and no energy savings relative to a 

probe-start MHLF. The shift to 875 W would maintain equal lumen output and result in 

about 12.5 percent energy savings relative to 1000 W probe-start MHLFs.31 This 

rulemaking regulates the efficiency of ballasts used in new MHLFs. Due to the increased 

mean lumens available in pulse-start lamps, the pulse-start lamp-and-ballast system can 

save energy relative to probe-start lamp-and-ballast systems. The design standard 

component of this final rule only regulates the ballast component of the lamp-and-ballast 

system.

NEMA, Venture, Musco Lighting, and ULT disagreed with DOE’s proposed 

design standard regarding greater than or equal to 1000 W applications. (NEMA, Public 

Meeting Transcript, No. 48 at p. 168; Venture, Public Meeting Transcript, No. 48 at p. 

170; Musco Lighting, Public Meeting Transcript, No. 48 at p. 180; Musco Lighting, No. 

31 The estimate of 12.5 percent energy savings comes from reducing a 1000 W system by 12.5 percent to 

get to 875 W. However, since 875 W ballasts are characteristically less efficient than 1000 W ballasts, the 

total energy savings will in reality be slightly less than 12.5 percent. 

141 

 
55 at pp. 1-3; ULT, No. 50 at p. 120) Musco Lighting pointed out that pulse-start has 

limited applicability above 1000 W and should not be considered at these higher 

wattages. (Musco Lighting, No. 55 at p. 3) ULT commented that MHLFs above 1000 W 

are typically probe-start and the proposed ruling would eliminate this class. ULT also 

added that there are no 1250 W or 1650 W pulse-start lamps. (ULT, No. 50 at p. 3) 

NEMA also stated that there would be a conspicuous cost increase for most other higherwattage ballasts, including the change from probe- to pulse-start for 1001 W – 2000 W. 

(NEMA, No. 56 at pp. 6-7) Musco Lighting additionally expressed concerns about 

involving 1500 W fixtures in the rulemaking because their principal use is sports lighting. 

Not only does sports lighting have very specific application standards requiring 

particularly uniform light levels and glare control that dictate specific pole locations, but 

also the transition from probe-start to pulse-start would require development of a 944 W 

system that does not currently exist. Due to this lack of existing commercially available 

technology, Musco Lighting stated that the proposed rule would go against 42 U.S.C. 

6295(o)(4). (Musco Lighting, No. 55 at pp. 1-3) NEMA further explained that stadium 

fixtures for double-ended, pulse-start 1500 W and 2000 W MH lamps meet industry 

standards for containment in the event of lamp rupture, and provide a UV attenuation 

barrier and lens interlock, while meeting league and television network requirements for 

on-field illumination and uniformity. Therefore, NEMA contended that there are no 

direct replacements for this equipment. Elimination of the lamp type used in such fixtures 

would result in significant retrofitting or replacement with lamps less suitable for the 

application, costs that NEMA stated must also be added to feasibility estimates. (NEMA, 

No. 56 at p. 7)

142 
After establishing a new equipment class for 1001 W to 2000 W fixtures, DOE 

reanalyzed the merits of the design standard for the 1500 W representative wattage. DOE 

agrees that the design standard banning probe-start lamps should not be analyzed for 

fixtures above 1000 W because pulse-start systems in this wattage range do not have 

increased lumen maintenance relative to probe-start systems. Therefore, there are no 

commercially available pulse start options that would offer the same light output with 

reduced energy consumption (industry considers changes in light output of greater than 

10 percent to be perceptible by the average customer). Thus, in this final rule, DOE did 

not analyze a design standard in the 1001 W – 2000 W equipment classes.

NEMA expanded upon its view that DOE’s proposed efficiency requirements 

would eliminate probe-start ballasts and lamps. NEMA argued that the facility of starting 

probe-start lamps in the greater than 1000 W category is a highly desirable performance 

characteristic. NEMA described that sports lighting owners and operators prefer the 

ballast and other serviceable components to be located in the base of the fixture mast, for 

ease of maintenance and safety. With probe-start technology, the 400 V starting signal is 

able to travel up the mast and reliably ignite the lamp. The 3000 V – 4000 V microsecond 

pulses from pulse-start ballasts are attenuated by long wires over the 30 ft. – 40 ft. height 

of the masts so that the high pressure starting gas in pulse-start lamps may not ignite. 

NEMA noted that moisture could also cause attenuation with pulse-start ballasts, while 

probe-start ballasts are less susceptible to the effects of weather. NEMA acknowledged 

that pulse-start remote electronic igniters are available at a considerable cost premium. 

However, as the fixture housing is not designed for them, there are thermal concerns and 

the igniters themselves are difficult to access for maintenance. (NEMA, No. 56 at p. 7) 

143 
Philips, NEMA, Musco Lighting, and ULT further commented that a ruling that 

discontinued probe-start ballasts and lamps would create problems. There are currently 

no pulse-start options for MHLFs installed in high-mast locations; to make the 

technology work would require the addition of an igniter at the top of the pole, which 

would add costs and complexity. (Philips, Public Meeting Transcript, No. 48 at pp. 166, 

169; NEMA, Public Meeting Transcript, No. 48 at p. 166; NEMA, No. 56 at p. 19; 

Musco Lighting, No. 48, Public Meeting Transcript, at p. 167; ULT, No. 50 at p. 3) ULT 

explained that applications at 1000 W or higher generally have a ballast-to-lamp distance 

that is too long for standard pulse-start ballasts and would require the addition of a 

special igniter and a cost adder of $10-$15 per ballast. (ULT, No. 50 at p. 12) Musco 

Lighting stated that the additional costs required to change from a probe-start to pulsestart system are much higher than DOE estimated. (Musco Lighting, No. 55 at p. 3) 

NEMA asserted that mandating ELs that preclude any technology but pulse-start 

electronically ballasted equipment would create increased maintenance and material costs 

due to surge and lightning resistance, increased fixture size and price, added weather 

resistance, remote igniter installation, and the higher maintenance cost and considerations 

of high-mast lighting fixtures. NEMA suggested excluding such equipment from energy 

conservation standards in order to avoid these issues. (NEMA, Public Meeting Transcript, 

No. 48 at p. 168; NEMA, No. 56 at p. 8) NEMA also noted that given the previous 

considerations, including greater than or equal to 1000 W fixtures in the rulemaking, 

would go against 42 USC § 62955(o)(4), as the adoption of these standards would be 

“likely to result in the unavailability in the United States in any covered product type (or 

class) of performance characteristics (including reliability), features, sizes, capacities, and 

144 
volumes that are substantially the same as those generally available in the United States 

at the time of the Secretary's finding.” (NEMA, No. 56 at pp. 6-7) 

For 1000 W high-mast applications, DOE found that remote starting is an option 

that is commercially available using pulse-start technology. As mentioned in comments, 

this would require the addition of a remote igniter at the top of the pole. DOE has 

accounted for the added equipment costs that would be associated with using pulse-start 

technology in 1000 W applications requiring high-mast fixtures. DOE notes that the 

design standard would not result in a push towards electronic levels, as the design 

standard is only considered for fixtures between 501 W and 1000 W, where electronic 

ballasts are not commercially available, and thus not analyzed.

NEMA commented that DOE appears to be applying incandescent technology to 

ballast efficiency and lamp efficacy. NEMA and ULT asserted that a ballast will have 

difficulties operating at wattages other than its rating and that such operation is a 

violation of its intended use and should not be considered. (NEMA, No. 56 at p. 15; ULT, 

No. 50 at p. 8). DOE agrees that ballasts would have difficulty operating at wattages 

other than those listed by the manufacturer. As mentioned previously, in this final rule 

DOE analyzed the design standard so that 1000 W probe-start systems would be replaced 

with either 875 W or 1000 W pulse-start systems. The use of 875 W ballasts would be 

with 875 W lamps, as DOE is not modeling the design standard to use a reduced-wattage 

lamp on a full-wattage ballast in this MHLF rulemaking. DOE continues to agree that 

ballasts will have difficulties operating lamps at wattages other than their rating, and does 

not analyze any such scenarios in this final rule.

145 
EEI expressed concerns that an outright ban on probe-start ballasts may hinder 

technological developments and higher-efficiency possibilities for the technology. (EEI, 

Public Meeting Transcript, No. 48 at p. 183) Further, NEMA and ULT opposed the ban, 

as 175 W to 400 W probe-start ballasts are already practically prohibited by existing 

regulation. NEMA and ULT stated that any limited remaining market should be 

maintained for desirable performance characteristics where it is deemed necessary. 

(NEMA, No. 56 at p. 19; ULT, No. 50 at p. 12)

DOE recognizes that probe-start MH ballasts have the remote-starting feature that 

is not provided with standard pulse-start MH ballasts. However, as discussed previously, 

DOE has found that pulse-start 1000 W systems can provide the remote-starting feature 

with the addition of a remote igniter. DOE accounts for the increased cost of the remotestart pulse-start system in section V.C.12 of this notice. 

In summary, this final rule analyzes a design standard from 501 W – 1000 W, but 

not from 1001 W – 2000 W. In the 1001 – 2000 W equipment class pulse start systems 

do not have better lumen maintenance compared to probe start systems. At 501 W – 1000 

W, however, DOE is still analyzing a design standard banning probe-start ballasts. 

Customers previously purchasing 1000 W probe-start fixtures would have the option of 

purchasing an 875 W pulse-start system with 12.5 percent energy savings while 

maintaining light output, or adopting a compliant 1000 W pulse-start system.

146 
11. Scaling to Equipment Classes Not Analyzed

DOE did not directly analyze ballasts tested at an input voltage of 480 V. Thus, it 

was necessary to develop a scaling relationship to establish ELs for these equipment 

classes. To do so in the NOPR, DOE compared quad-voltage ballasts from the 

representative equipment classes to their 480 V ballast counterparts using catalog data 

over all representative wattages at various efficiencies. In the NOPR, DOE found the 

average reduction to ballast efficiency to be 0.6 percent. Therefore, DOE proposed 

applying this reduction (in the form of a multiplier of 0.994) to develop ELs for the 480 

V ballasts. For the 150 W – 250 W equipment classes, DOE made adjustments to 

resulting scaled equations to ensure all ELs were equal to or more stringent than the 

existing standards (see chapter 5 of the final rule TSD for additional detail).

ULT and NEMA commented that a flat 0.6 percent efficiency gap between quadvoltage and dedicated 480 V fixtures cannot be used across all wattages. In lower 

wattages, this difference can be much higher, greater than 2 percent. (ULT, Public 

Meeting Transcript, No. 48 at p. 209; NEMA, No. 56 at p. 19) ULT and NEMA proposed 

a scaling factor of 2 percent for wattages less than or equal to 150 W, and 1 percent for 

wattages greater than 150 W (in the form of a subtraction of 2 percentage points and 1 

percentage point from the representative equipment class ELs, respectively). (ULT, No. 

50 at pp. 11-12; NEMA, No. 56 at p. 19) Musco Lighting noted that the 480 V scaling 

factor should be a 1 percent reduction instead of 0.6 percent to account for the inability to 

measure ballast efficiency with more precision than a whole percentage point. (Musco 

Lighting, No. 55 at p. 4)

147 
In the final rule, DOE analyzed the test data and agreed that the difference in 

efficiency between ballasts tested at 480 V and ballasts tested at other input voltages 

changes based on wattage. At lower wattages, ballasts are more compact and less 

efficient, and the difference in efficiency between the voltages is greater. Because of this 

correlation, DOE has adjusted the scaling factor used to scale efficiency levels from 

representative equipment classes to the 480 V equipment classes from the 0.6 percent 

reduction in the NOPR to the values shown in Table V.5. As in the NOPR, DOE again 

compared quad-voltage ballasts to their 480 V ballast counterparts using catalog data 

over all representative wattages. DOE found the average reduction to ballast efficiency 

changed based on two wattage ranges: 50 W – 150 W and 151 W – 1000 W. For 50 W – 

150 W, DOE found the average reduction in ballast efficiency to be less than the 2.0 

percent proposed by NEMA. However, DOE did find some instances in which the 

difference in efficacy was as high or higher than that noted by NEMA. Therefore, DOE 

determined a scaling factor of 2.0 percent (in the form of a subtraction of 2 percent from 

the representative equipment class ELs) to be appropriate from 50 W – 150 W. 

Subtracting 2.0 percent across all wattages from 50 W – 150 W, instead of applying a 

scaling multiplier to the EL equations, also aligns with DOE’s observation that the 

difference in efficiency between 480 V ballasts and quad-voltage ballasts is greater at 

lower wattages. For 150 W – 1000 W, DOE also found the average reduction to ballast 

efficiency to be less than the 1.0 percent proposed by NEMA. However DOE did find 

some instances in which the difference in efficacy was as high or higher than that noted 

by NEMA. Therefore, DOE determined a scaling factor of 1.0 percent (in the form of a 

subtraction of 1 percent from the representative equipment class ELs) to be appropriate 

from 151 W – 1000 W. As with the 50 W – 150 W range, DOE applied this scaling factor 

148 
as a subtraction from the representative equipment class ELs instead of as a multiplier. 

Even though the 1001 W – 2000 W equipment class no longer shows a difference in 

efficiency between 480 V and non-480 V classes, DOE continues to consider the 480 V 

and non-480 V equipment classes separately for the purposes of this rulemaking. This 

separation allows DOE to continue comparing consistent representative classes, of 

ballasts not tested at 480 V, for each wattage bin. Additionally, for the 150 W – 250 W 

equipment classes, DOE made adjustments to the resulting scaled equations to ensure all 

ELs were equal to or more stringent than the existing standards (see chapter 5 of the final 

rule TSD for additional detail).

Table V.5 Final Rule Scaling Factors

Wattage Range Scaling Factor

50 W – 150 W 2.0%

151 W – 1000 W 1.0% 

1001 W – 2000 W 0.0%

12. Manufacturer Selling Prices 

a. Manufacturer Production Costs

DOE developed the MSPs for MHLFs and MH ballasts by determining an MPC, 

either through a teardown or retail pricing analysis, and then applying a manufacturer 

markup to arrive at the MSP. For the NOPR, DOE conducted teardown analyses on a 

total of 32 commercially available MH ballasts and eight MHLFs. Using the information 

from these teardowns, DOE summed the direct material, labor, and overhead costs used 

149 
to manufacture a MHLF or MH ballast, to calculate the MPC.32 For further details on this 

analysis, see chapter 5 of the final rule TSD.

APPA noted that if this rulemaking requires larger and heavier ballasts, the 

replacement costs would increase substantially and have a large effect on the LCC and 

PBP analyses since the fixture may need to be replaced. (APPA, No. 51 at p. 7) As 

described in section III.A, this rulemaking only covers ballasts in new fixtures. A 

replacement ballast for an existing fixture would not need to comply with DOE standards. 

As described in section V.C.8, DOE also notes that the ballasts needed to meet the 

standards adopted by this final rule are not notably larger than the baseline ballasts. 

Efficiency levels based on magnetic ballasts are either based on commercially available 

ballasts, or modeled using the constraint that ballast size cannot increase relative to less 

efficient commercially available designs. As such, DOE concluded fixtures would not 

need to be redesigned to account for an increase in ballast size. See section V.F of this 

notice for details about the costs that are accounted for in the LCC and PBP analyses.

ULT commented that the fixture price assumptions are too low, as a majority of 

the fixtures would have to be redesigned, requiring engineering time, new tools, and 

testing time. (ULT, No. 50 at p. 15) DOE’s final fixture prices account for the MPC of 

the fixture, as detailed in chapter 5 of the final rule TSD. DOE also determined that for 

the levels analyzed in this rulemaking, fixtures would not be required to be substantially 

32 When viewed from the company-wide perspective, the sum of all material, labor, and overhead costs 

equals the company’s sales cost, also referred to as the cost of goods sold.

150 

 
redesigned. Further, any costs associated with redesign, tooling, testing and the general 

manufacturing process are accounted for in the MIA as detailed in section V.I of this 

notice.

b. Empty Fixture Costs

DOE conducted fixture teardowns for the NOPR to determine appropriate empty 

fixture prices. When referring to the “empty fixture” component of a MHLF, DOE means 

the lamp enclosure and optics. The empty fixture does not include the ballast or lamp. 

DOE added the other components required by the system (including ballasts and any cost 

adders associated with electronically ballasted systems) and applied appropriate markups 

to get the final full fixture MSP. In the NOPR, a representative fixture price was 

developed for each wattage (using the same MSP for indoor and outdoor fixtures), 

resulting in five unique fixture prices to account for the five representative wattages.

As detailed in section V.C.4 of this notice, DOE has expanded its analysis of 

representative fixtures in the final rule to account for the varying fixture types used in 

indoor and outdoor applications. This new division allows DOE to develop separate 

empty fixture prices for indoor and outdoor fixtures, and thus take the weather protection 

built into outdoor fixtures into account. These new empty fixture MPCs can be found in 

chapter 5 of the final rule TSD. The updated pricing results in 12 unique empty fixture

prices, namely an indoor and an outdoor price for each of the six representative wattages.

151 
c. Incremental Costs for Electronically Ballasted MHLFs

After determining baseline MH ballast and fixture MPCs, DOE considered 

whether transitioning from magnetic to electronic ballast technology would require any 

further ballast or fixture design changes to accommodate the electronic ballast or 

maintain similar utility to the baseline magnetic ballast. In the NOPR, DOE proposed 

three sources of incremental costs: (1) outdoor transient protection, (2) thermal 

management, and (3) 120 V auxiliary power functionality.

Transient Protection

DOE recognizes the necessity for outdoor fixtures to be able to withstand at least 

10 kV voltage transients. While MHLFs with magnetic ballasts are robust and do not 

require any additional devices or enhancements to withstand these transients, based on its

evaluation of commercially available MHLFs, DOE finds that fixtures with electronic 

ballasts usually require additional design features in order to have adequate protection. 

Some manufacturers indicated that a portion of their electronic ballasts already have 

surge protection built in, but most electronic ballasts are only rated for 2.5 kV – 6 kV 

voltage spikes. In the NOPR, DOE proposed an incremental fixture cost of $19 for 10 kV 

inline (external to the ballast) surge protection for electronically ballasted outdoor 

fixtures. CA IOUs and the Joint Comment supported DOE’s approach to modeling the 

incremental cost for electronic ballasts over magnetic ballasts to account for 10 kV surge 

protection. (CA IOUs, No. 54 at pp. 3-7; CA IOUs, Public Meeting Transcript, No. 48 at 

p. 202; Joint Comment, No. 62 at pp. 4-5) 

152 
In the final rule, DOE updated the price of 10 kV voltage transient protection 

devices. Based on a review of selling prices from transient manufacturers, DOE assigned 

a cost adder to manufacturers of $10.31 for 10 kV inline surge protection for electronic 

ballasts, as most electronic ballasts do not have this feature built in. The $10.31 cost 

adder reflects a high volume purchase, which would be representative of a fixture 

manufacturer. As such, DOE applies this adder to the fixture MPC for fixtures that 

require voltage surge protection. DOE also assigned a cost to end-users of $21.45 to 

purchase a replacement voltage transient protection device at a single unit quantity.

In response to public comment, DOE researched indoor industrial fixtures and 

found these fixtures can also be subject to voltage surges. DOE has thus accounted for the 

issue of indoor electronic ballasts experiencing voltage surges in these industrial 

applications. Specifically, DOE analyzes the indoor industrial applications that require 

additional surge protection as an LCC subgroup. In order for electronic ballasts to be 

used in these applications, the voltage transient device costs were added to total fixture 

MSPs in the subgroup. The costs for the transient protection devices for electronic 

ballasts assigned to the manufacturer and the end user are the same for indoor industrial 

applications as for outdoor applications. Additionally, when these surge protection 

devices are compromised from repeated transient events, the additional maintenance and 

replacement are incorporated in the LCC analysis and NIA.

Thermal Management

Electronic ballasts are more vulnerable than magnetic ballasts to high ambient 

temperatures which, if not managed well, can cause premature ballast failure. In order to 

153 
correct for this difference, fixtures housing electronic ballasts would need to be 

redesigned to account for thermal management in both indoor and outdoor applications. 

Manufacturers must design new and often larger brackets, and apply additional potting 

material to create an adequate thermal contact between the ballast and fixture. During 

interviews, manufacturers gave DOE information about the cost to add thermal 

management to fixtures with electronic ballasts. In aggregate, manufacturers indicated a 

20 percent increase in fixture MPCs associated with thermal management. Additionally, 

DOE conducted teardown analyses of empty MHLFs. Through analysis of pairs of 

fixtures designed for electronic ballasts and fixtures designed for comparable magnetic 

ballasts, DOE also found an approximately 20 percent increase in fixture MPCs to 

include thermal management for electronic ballasts. Accordingly, in the NOPR cost 

analysis, all electronically ballasted MHLFs incur a 20 percent incremental cost to the 

empty fixture MPCs.

Philips and Georgia Power both expressed concerns that the MSP will increase 

more substantially than DOE projected. (Philips, Public Meeting Transcript, No. 48 at p. 

207; Georgia Power, Public Meeting Transcript, No. 48 at p. 207) Philips emphasized 

that DOE’s 20 percent figure for electronic ballasts in outdoor fixtures is understated and 

would become much higher with pole, fixture, and ballast redesign. However, CA IOUs 

and the Joint Comment supported DOE’s approach to modeling the incremental cost for 

electronic ballasts over magnetic ballasts to account for thermal management and the 

potential need for fixture redesign. (CA IOUs, No. 54 at pp. 3-4; CA IOUs, Public 

Meeting Transcript, No. 48 at p. 202; Joint Comment, No. 62 at pp. 4-5) 

154 
As previously mentioned, any price increases required for MHLFs are accounted 

for in this MSP analysis, while any capital conversion and redesign costs are addressed in 

the MIA (see section V.I of this notice). DOE has determined that ballast size and weight 

are not required to change in response to the ELs analyzed, so DOE did not analyze a 

change in pole size or cost. DOE believes that a cost adder for thermal management is 

necessary, and given that the costs cited by manufacturers are either not required or are 

accounted for in another part of the analysis, DOE continues to apply a 20 percent 

increase in fixture MPCs to reflect thermal management for electronic ballasts

120 V Auxiliary Tap 

For indoor applications, a number of magnetic ballasts include a 120 V auxiliary 

tap. This output is used to operate an emergency incandescent lamp after a temporary loss 

of power and while the MH lamp is still too hot to restart. These taps are generally 

required for only one out of every ten indoor lamp fixtures. A 120 V tap is easily 

incorporated into a magnetic ballast due to its traditional core and coil design, and incurs 

a negligible incremental cost. Electronic ballasts, though, require additional design to add 

this 120 V auxiliary power functionality. Using a combination of manufacturer 

information and market research, DOE proposed in the NOPR that a representative value 

for electronic ballasts to incorporate this auxiliary tap is $7.50. Because this functionality 

is only needed for 10 percent of ballasts in indoor fixtures, that number was multiplied by 

0.10 to get an incremental ballast cost of $0.75 per indoor ballast.

ULT questioned why DOE scaled down the price of an auxiliary power 120 V tap 

using a 1:10 ratio just because 10 percent of indoor fixtures require the auxiliary power 

155 
functionality. (ULT, No. 50 at p. 14) Philips commented that auxiliary power is not 

always available for electronic ballasts and would require an additional transformer, 

increasing costs. (Philips, Public Meeting Transcript, No. 48 at p. 189)

DOE scaled down the price of an auxiliary power 120 V tap using a 1:10 ratio 

because that was the simplest way to characterize the cost that the average fixture will 

incur when adding this functionality. Based on manufacturer feedback, DOE determined 

that 10 percent of indoor fixtures require auxiliary 120 V power functionality. Therefore, 

this method continued to be used to account for these costs in this final rule. DOE agrees 

that the auxiliary power is not always available with electronic ballasts, and therefore 

included this incremental ballast cost to account for integrating the additional tap. DOE 

maintains that the representative value for electronic ballasts to incorporate the auxiliary 

tap is $7.50. As mentioned previously, as this functionality is only needed for 10 percent 

of ballasts in indoor fixtures, the resulting incremental ballast cost is $0.75 per indoor 

ballast.

d. Costs Associated with the Design Standard

In the NOPR, DOE analyzed a design standard banning probe-start ballasts for 

fixtures greater than 500 W. Pulse-start MH systems require an igniter to start the lamp, 

while probe-start MH systems do not. In DOE’s NOPR cost model, the additional cost of 

this igniter in pulse-start systems was the only source of cost difference between probeand pulse-start systems.

156 
Musco Lighting commented that at 1500 W, the cost to shift from a probe-start to 

a pulse-start system would be much higher than DOE estimated. Musco estimated a more 

representative value would be four times the incremental cost currently utilized and noted 

that the igniter could lead to increased maintenance costs. (Musco Lighting, No. 55 at p. 

3) 

As noted in section V.C.10 of this notice, DOE has chosen to not analyze a design 

standard for lamps above 1000 W. Therefore, the costs of a transition to pulse-start 

technology at 1500 W are no longer needed for the final rule analysis.

However, DOE did find that at 1000 W, the design standard could create 

challenges with certain customers switching to pulse-start technology. Customers who 

use high-mast applications often see probe-start systems as preferable because they can 

be easily mounted remotely. This means that the ballast can be at the bottom of the pole 

for easy maintenance, while the lamp is operated at the top of the pole. In order for a 

pulse-start system to allow for this remote mounting, DOE found that there are 

commercially available remote-start igniters that allow pulse-start ballasts to also be 

remotely mounted. This comes at increased cost due to the addition of this more complex 

igniter at the top of the pole, and the added costs for the installation and maintenance..

When comparing commercially available standard and remote-start igniters, DOE found 

that remote-start igniter costs were about two times greater. As such, when modeling 

customers who require remote starting in design standard scenarios, DOE applied a 

multiplier of 2.07 to the igniter costs. The additional costs for installation and 

maintenance are accounted for the LCC analysis in section . 

157 
e. Manufacturer Markups

The last step in determining MSPs is development and application of 

manufacturer markups to scale the MPCs to MSPs. DOE developed initial manufacturer 

markup estimates by examining the annual SEC 10-K reports filed by publicly traded 

manufacturers of MH ballasts and MHLFs, among other products. Based on feedback 

from manufacturers, in the NOPR DOE proposed separate markups for ballast 

manufacturers (1.47) and fixture manufacturers (1.58). DOE also assumed that fixture 

manufacturers apply the 1.58 markup to the ballasts used in their fixtures rather than to 

only the empty fixtures. In aggregate, the markup also accounted for the different markets 

served by fixture manufacturers. The 1.47 markup for ballast manufacturers applied only 

to ballasts sold to fixture original equipment manufacturers (OEMs) directly impacted by 

this rulemaking. For the purpose of the LCC and NIA analysis, DOE assumed a higher 

markup of 1.60 for ballasts that are sold to distributors for the replacement market. 

Receiving no comments to the contrary, DOE continued using these manufacturer 

markups in the final rule.

D. Markups to Determine Equipment Price

By applying markups to the MSPs estimated in the engineering analysis, DOE 

estimated the amounts customers would pay for baseline and more-efficient equipment. 

At each step in the distribution channel, companies mark up the price of the equipment to 

cover business costs and profit margin. Identification of the appropriate markups and the 

determination of customer equipment price depend on the type of distribution channels 

through which the equipment moves from manufacturer to customer.

158 
1. Distribution Channels

Before it could develop markups, DOE needed to identify distribution channels 

(i.e., how the equipment is distributed from the manufacturer to the end user) for the 

MHLF designs addressed in this rulemaking. In an electrical wholesaler distribution 

channel, DOE assumed the fixture manufacturer sells the fixture to an electrical 

wholesaler (i.e., distributor), who in turn sells it to a contractor, who sells it to the end

user. In a contractor distribution channel, DOE assumed the fixture manufacturer sells the 

fixture directly to a contractor, who sells it to the end user. In a utility distribution 

channel, DOE assumed the fixture manufacturer sells the fixture directly to the end user 

(i.e., electrical utility).

2. Estimation of Markups

To estimate wholesaler and utility markups, DOE used financial data from 10-K 

reports from publicly owned electrical wholesalers and utilities. DOE’s markup analysis 

developed both baseline and incremental markups to transform the fixture MSP into an 

end-user equipment price. DOE used the baseline markups to determine the price of 

baseline designs. Incremental markups are coefficients that relate the change in the MSP 

of higher-efficiency designs to the change in the wholesaler and utility sales prices, 

excluding sales tax. These markups refer to higher-efficiency designs sold under market 

conditions with new and amended energy conservation standards.

In the NOPR, DOE assumed a wholesaler baseline markup of 1.23 and a 

contractor baseline markup of 1.13, for a total wholesaler distribution channel baseline 

159 
markup of 1.39. DOE also assumed utility baseline markups of 1.00 and 1.13 for the 

utility distribution channel in which the manufacturer sells a fixture directly to the end

user, and the channel in which a manufacturer sells a fixture to a contractor who in turn 

sells it to the end user, respectively.

The sales tax represents state and local sales taxes applied to the end-user 

equipment price. DOE obtained state and local tax data from the Sales Tax 

Clearinghouse.33 These data represent weighted averages that include state, county, and 

city rates. DOE then calculated population-weighted average tax values for each census 

division and large state, and then derived U.S. average tax values using a populationweighted average of the census division and large state values. For the NOPR, this 

approach provided a national average tax rate of 7.13 percent.

3. Summary of Markups

Table V.6 summarizes the markups at each stage in the distribution channels and 

the overall baseline and incremental markups, and sales taxes, for each of the three 

identified channels.

Table V.6 Summary of Fixture Distribution Channel Markups

Wholesaler Distribution

Utility Distribution

Via Wholesaler & 

Contractor Direct to End User

Baseline Incremental Baseline Incremental Baseline Incremental

33 The Sales Tax Clearinghouse. Available at https://thestc.com/STRates.stm. (Last accessed June 24, 

2013.)

160 

 
Electrical 

Wholesaler 

(Distributor)

1.23 1.05 N/A N/A N/A N/A

Utility N/A N/A 1.00 1.00 1.00 1.00

Contractor 

or Installer 1.13 1.13 1.13 1.13 N/A N/A

Sales Tax 1.07 1.07 1.07

Overall 1.49 1.27 1.21 1.21 1.07 1.07

Using these markups, DOE generated fixture end-user prices for each EL it 

considered, assuming that each level represents a new minimum efficiency standard. 

Chapter 6 of the final rule TSD provides additional detail on the markups analysis.

E. Energy Use Analysis

For the energy use analysis, DOE estimated the energy use of metal halide lamp 

fixtures in actual field conditions. The energy use analysis provided the basis for other 

DOE analyses, particularly assessments of the energy savings and the savings in 

operating costs that could result from DOE’s adoption of new and amended standard 

levels.

To develop annual energy use estimates for the August 2013 NOPR, DOE 

multiplied annual usage (in hours per year) by the lamp-and-ballast system input power 

(in watts). DOE characterized representative lamp-and-ballast systems in the engineering 

analysis, which provided measured input power ratings. To characterize the country’s 

average use of fixtures for a typical year, DOE developed annual operating hour 

distributions by sector, using data published in the 2010 LMC, the Commercial Building 

161 
Energy Consumption Survey (CBECS),34 and the Manufacturer Energy Consumption 

Survey (MECS).35 78 FR 51464, 51501 (Aug. 20, 2013).

Musco Lighting and NEMA commented that metal halide lamp fixtures over 1000 

W—particularly 1500 W fixtures—are principally confined to sports lighting 

applications, and Musco Lighting noted that their monitoring data indicates average 

usage of 250 hours per year for these fixture types. (Musco Lighting, No. 55 at pp. 1, 4; 

NEMA, No. 56 at pp. 6–7) The CA IOUs stated that high-wattage MH fixtures are also 

commonly used in high mast applications, with operating hours similar to other outdoor 

lighting applications. (CA IOUs, No. 54 at p. 2) DOE acknowledges that high-wattage 

MH fixtures may be used in high mast applications but notes that the 2010 LMC 

indicates an average MH lamp wattage of less than 250 W for roadway and parking 

applications, suggesting a negligible contribution by high mast lighting. As discussed in 

section V.A.2, DOE created a separate 1500 W equipment class for this final rule to 

address the unique design features and application of these fixture types. Musco did not 

provide detailed operating hours data with their written comments; however, NEMA 

cited the 2010 LMC estimate of 1 hour per day for stadium lighting as reasonable for 

MHLF applications greater than 1000 W. DOE agrees with NEMA that this 2010 LMC 

estimate is reasonable for sports lighting applications, and DOE assumed annual 

34 U.S. Department of Energy, Energy Information Agency. Commercial Building Energy Consumption 

Survey: Micro-Level Data, File 2 Building Activities, Special Measures of Size, and Multi-building 

Facilities. 2003. Available at www.eia.doe.gov/emeu/cbecs/public_use.html. 35 U.S. Department of Energy, Energy Information Agency. Manufacturing Energy Consumption Survey, 

Table 1.4: Number of Establishments Using Energy Consumed for All Purposes. 2006. Available at 

www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html. 

162 

 
operation of 350 hours per year (based on the actual LMC value of 0.958 hours per day) 

for the 1500 W equipment class in its final rule energy use analysis.

The August 2013 NOPR analysis assumed full operating power and no dimmed 

operation to estimate MHLF energy use. 78 FR 51464, 51502 (Aug. 20, 2013). DOE 

received no comments regarding its operating power assumption, and retained its 

approach for the energy use analysis in today’s final rule. Chapter 7 of the final rule TSD 

provides a more detailed description of DOE’s energy use analysis.

F. Life-Cycle Cost and Payback Period Analyses 

DOE conducted the LCC and PBP analysis to evaluate the economic effects of 

potential energy conservation standards for metal halide lamp fixtures on individual 

customers. For any given efficiency level, DOE measured the PBP and the change in 

LCC relative to an estimated baseline equipment efficiency level. The LCC is the total 

customer expense over the life of the equipment, consisting of purchase, installation, and 

operating costs (expenses for energy use, maintenance, and repair). To compute the 

operating costs, DOE discounted future operating costs to the time of purchase and 

summed them over the lifetime of the equipment. The PBP is the estimated amount of 

time (in years) it takes customers to recover the increased purchase cost (including 

installation) of more efficient equipment through lower operating costs. DOE calculates 

the PBP by dividing the change in purchase cost (normally higher) by the change in 

average annual operating cost (normally lower) that results from the more efficient 

standard.

163 
Inputs to the calculation of total installed cost include the cost of the equipment—

which includes MSPs, distribution channel markups, and sales taxes—and installation 

costs. Inputs to the calculation of operating expenses include annual energy consumption, 

energy prices and price projections, repair and maintenance costs, equipment lifetimes, 

discount rates, and the year that compliance with new and amended standards is required. 

To account for uncertainty and variability, DOE created distributions for selected inputs, 

including operating hours, equipment lifetimes, electricity prices, discount rates, and 

sales tax rates. For example, DOE created a probability distribution of annual energy 

consumption in its energy use analysis, based in part on a range of annual operating 

hours. The operating hour distributions capture variations across building types, lighting 

applications, and metal halide systems for three sectors (commercial, industrial, and 

outdoor stationary). In contrast, fixture MSPs were specific to the representative designs 

evaluated in DOE’s engineering analysis, and price markups were based on limited 

publicly available financial data. Consequently, DOE used discrete values instead of 

distributions for these inputs.

The computer model DOE uses to calculate the LCC and PBP, which incorporates 

Crystal Ball (a commercially available software program), relies on a Monte Carlo 

simulation to incorporate uncertainty and variability into the analysis. The Monte Carlo 

simulations randomly sample input values from the probability distributions and fixture 

user samples. The final rule TSD chapter 8 and its appendices provide details on the 

spreadsheet model and all the inputs to the LCC and PBP analysis.

164 
Table V.7 summarizes the approach and data DOE used to develop inputs to the 

LCC and PBP calculations for the August 2013 NOPR as well as the changes made for 

today’s final rule. The subsections that follow discuss the calculation inputs and DOE’s 

changes to them.

Table V.7 Summary of Inputs and Key Assumptions in the LCC and PBP Analysis*

Inputs NOPR Changes for the Final Rule

Equipment Cost Derived by multiplying MHLF MSPs 

by distribution channel markups and 

sales tax

No change

Installation Cost Calculated costs using estimated labor 

times and applicable labor rates from 

“RS Means Electrical Cost Data” 

(2009) and U.S. Bureau of Labor 

Statistics

Calculated costs using estimated labor 

times and applicable labor rates from 

“RS Means Electrical Cost Data” 

(2013); Sweets Electrical Cost Guide 

2013; and U.S. Bureau of Labor 

Statistics

Annual Energy Use Determined operating hours separately 

for indoor and outdoor fixtures. Used 

lighting market data: 2010 LMC 

(2012)

No change

Energy Prices Electricity: Based on EIA’s Form 826 

data for 2012

Variability: Energy prices determined 

at state level; incorporated off-peak 

electricity prices in the Monte Carlo 

analysis

No change

Energy Price 

Projections

Projected using AEO2013 No change

Replacement Costs Included labor and material costs for 

lamp and ballast replacement through 

the end of their lifetimes

No change

Equipment Lifetime Ballasts: Assumed 50,000 hours for 

magnetic ballasts and 40,000 hours for 

electronic ballasts

Fixtures: Assumed 20 years for indoor 

fixtures and 25 years for outdoor 

fixtures 

Variability: incorporated lamp and 

ballast lifetimes in the Monte Carlo 

analysis

Ballasts: No change

Fixtures: No change

Variability: incorporated lamp, ballast 

and fixture lifetimes in the Monte Carlo 

analysis

Discount Rates Commercial/Industrial: Developed a 

distribution of discount rates for each 

end-use sector

Outdoor Stationary: Developed a 

distribution of discount rates for each 

Commercial/Industrial: No change

Outdoor Stationary: No change

165 
end-use sector

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 

of the final rule TSD.

1. Equipment Cost

To calculate customer equipment costs, DOE multiplied the MSPs developed in 

the engineering analysis by the distribution channel markups described in section V.D.1

(along with sales taxes). DOE used different markups for baseline equipment and higher 

efficiency equipment because the markups estimated for incremental costs differ from 

those estimated for baseline models. For the August 2013 NOPR, DOE also examined 

historical price data for various appliances and equipment that—along with economic 

literature—suggest that the real costs of these products may in fact trend downward over 

time, partially because of “learning” or “experience.”36 78 FR 51464, 51503 (Aug. 20, 

2013). 

On February 22, 2011, DOE published a notice of data availability (February 

2011 NODA; 76 FR 9696) stating that DOE may consider improving regulatory analysis 

by addressing equipment price trends. DOE notes that learning-curve analysis 

characterizes the reduction in production cost mainly associated with labor-based 

performance improvement and higher investment in new capital equipment at the 

microeconomic level. Experience-curve analysis tends to focus more on entire industries 

and aggregates over various causal factors at the macroeconomic level: “Experience 

36 A draft paper, Using the Experience Curve Approach for Appliance Price Forecasting, posted on the 

DOE web site at www.eere.energy.gov/buildings/appliance_standards, provides a summary of the data and 

literature currently available to DOE that is relevant to price forecasts for selected appliances and 

equipment.

166 

 
curve” and “progress function” typically represent generalizations of the learning concept 

to encompass behavior of all inputs to production and cost (i.e., labor, capital, and 

materials). The economic literature often uses these two terms interchangeably. The term 

“learning” is used here to broadly cover these general macroeconomic concepts.

For the August 2013 NOPR and consistent with the February 2011 NODA, DOE 

examined two methods for estimating price trends for metal halide lamp fixtures: using 

historical producer price indices (PPIs), and using projected price indices (called 

deflators). With PPI data, DOE found both positive and negative real price trends, 

depending on the specific time period examined, and did not use this method to adjust 

fixture prices. DOE instead adjusted fixture prices using deflators used by EIA to develop 

the AEO2011. When adjusted for inflation, the deflator-based price indices decline from 

100 in 2010 to approximately 75 in 2046. 78 FR 51464, 51503 (Aug. 20, 2013).

DOE received no comments related to equipment price trends, and retained its 

deflator-based approach to adjust fixture prices for this final rule. Using updated 

(AEO2013) deflators, DOE estimated that the price indices decline from 100 in 2010 to 

approximately 90 in 2046. A more detailed discussion of price trend modeling and 

calculations is provided in appendix 8B of the final rule TSD.

167 
2. Installation Cost

Installation costs for metal halide lamp fixtures include the costs to install the 

fixture, maintain the ballast, and replace the lamp. For the August 2013 NOPR, DOE 

used data collected for its July 2010 HID lamps determination,37 labor rates for 

electricians from RS Means,

38 and other research to estimate the installation costs. DOE 

assumed that installation costs varied between equipment classes as a function of fixture 

size and mounting locations but were the same between efficiency levels within a given 

equipment class. For maintenance costs, DOE employed a methodology that allows the 

use of annualized maintenance costs while maintaining the integrity of the NPV 

calculations in the NIA. 78 FR 51464, 51503 (Aug. 20, 2013). 

DOE received comments that larger ballasts and housings—and larger poles 

required for outdoor fixtures—would increase costs and payback periods for higherefficiency designs. (Acuity Brands, Public Meeting Transcript, No. 48 at p. 60; GE, 

Public Meeting Transcript, No. 48 at pp. 231–232; NEMA, No. 56 at p. 2) As discussed 

previously in section V.C of this final rule, DOE’s engineering analysis indicated that 

higher-efficiency fixture designs would not incur significant increases in housing size, 

effective projected area, or required pole size. DOE, therefore, did not include the added 

cost of larger poles in the installation costs for higher efficiency fixture designs. For this 

37 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy Conservation 

Program for Consumer Equipment: Preliminary Technical Support Document: High-Intensity Discharge 

Lamps. 2010. Washington, D.C. Available at 

<www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/60> 38 R.S. Means Company, Inc. 2010 RS Means Electrical Cost Data. 2010. Kingston, MA.

168 

 
final rule, DOE also referenced Sweets Electrical Cost Guide39 in developing installation 

cost estimates for the LCC and PBP analysis. For further detail, see chapter 8 of the final 

rule TSD.

3. Annual Energy Use

As discussed in section V.E, DOE estimated the annual energy use of 

representative metal halide systems using system input power ratings and sector 

operating hours. For the August 2013 NOPR, DOE based the annual energy use inputs to 

the LCC and PBP analysis on weighted average annual operating hours. 78 FR 51464, 

51503 (Aug. 20, 2013). For this final rule, DOE based the annual energy use inputs on 

sectoral operating hour distributions, (commercial, industrial, and outdoor stationary 

sectors), with the exception of a discrete value (350 hours per year) for the 1500 W 

equipment class that is primarily limited to sports lighting. DOE used operating hour 

(and, by extension, energy use) distributions to better characterize the potential range of 

operating conditions faced by MHLF customers.

4. Energy Prices

For the August 2013 NOPR, DOE estimated electricity prices for commercial, 

industrial and outdoor stationary sectors by state using data from EIA Form 826, 

“Monthly Electric Utility Sales and Revenue Data, 2011.” 78 FR 51464, 51503 (Aug. 20, 

2013). DOE received no comments related to electricity prices and used 2012 data for 

this final rule. For more information, see chapter 8 of the final rule TSD. 

39 Sweets-McGraw Hill Construction. Sweets Electrical Cost Guide 2013. 2012. Vista, CA.

Comment [AGA13]: Change requested by 

OIRA.

169 

 
5. Energy Price Projections

To estimate the trends in energy prices, DOE used the price projections in 

AEO2013. To arrive at prices in future years, DOE multiplied current average prices by 

the projected annual average price changes in AEO2013. Because AEO2013 projects 

prices to 2040, DOE used the average rate of change from 2030 to 2040 to estimate the 

price trend for electricity after 2040. In addition, the spreadsheet tools that DOE used to 

conduct the LCC and PBP analysis allow users to select price forecasts from the AEO

low-growth, high-growth, and reference-case scenarios to estimate the sensitivity of the 

LCC and PBP to different energy price forecasts. 78 FR 51464, 51504 (Aug. 20, 2013). 

DOE received no comments related to energy price projections, and retained its approach 

for this final rule. For more information, see chapter 8 of the final rule TSD.

6. Replacement Costs

In the August 2013 NOPR, DOE addressed ballast and lamp replacements that 

occur within the LCC analysis period. Replacement costs include the labor and materials 

costs associated with replacing a ballast or lamp at the end of their lifetimes and are 

annualized across the years preceding and including the actual year in which equipment 

is replaced. For the LCC and PBP analysis, the analysis period corresponds with the 

fixture lifetime that is assumed to be longer than that of either the lamp or the ballast. For 

this reason, ballast and lamp prices and labor costs are included in the calculation of total 

installed costs. 

170 
DOE received numerous comments indicating that electronic HID lamp ballasts 

require additional voltage transient (surge) protection, in comparison to magnetic ballasts. 

High-voltage transients could result from, e.g., lightning or wind effects and could 

shorten electronic ballast life in outdoor applications. (APPA, No. 51 at pp. 5–7; CA 

IOUs, No. 54 at p. 4; FP&L, Public Meeting Transcript, No. 48 at pp. 232–233; NEMA, 

No. 56 at pp. 16–17; ULT, No. 50 at p. 13; SCE&G, No. 49 at p. 1) NEMA stated that 

voltage transients are also a concern in indoor heavy industrial applications. (NEMA, No. 

56 at p. 16) Several commenters also stated that it is not possible to determine when 

transient protection has reached its end of life, other than when it fails and causes a 

ballast failure in the process. (APPA, No. 51 at p. 5; NEMA, No. 56 at p. 16; Universal, 

No. 50 at p. 13) ASAP and GE suggested that transient-induced failures and maintenance 

should also be addressed in the LCC and PBP analysis. (ASAP, No. 62 at p. 5; GE, 

Public Meeting Transcript, No. 48 at p. 248)

For this final rule, DOE examined the potential effects of voltage transients on 

electronically ballasted fixtures in outdoor and heavy industrial indoor applications. As 

discussed previously in section V.C of this final rule, DOE’s engineering analysis 

considers the additional cost of transient protection in determining the total cost for 

fixtures using electronic ballasts. DOE assumed that outdoor fixtures of all wattages 

could face transient-induced damage, and that industrial indoor fixtures in the 250 W and 

400 W equipment classes were most susceptible to voltage transients, based on 2010 

LMC data for average HID lamp wattages in indoor applications.

171 
For outdoor fixtures, DOE examined data on the frequency and geographic 

distribution of lightning strikes from the National Lightning Safety Institute40 and other 

sources to estimate additional surge protection and ballast replacements due to voltage 

transients. Lightning is more prevalent in the southern and lower midwestern regions of 

the United States, which leaves high concentrations of outdoor lighting fixtures, e.g., in 

western and northeastern metropolitan areas, less affected by lightning. On a national 

level, DOE estimated that direct lightning strikes would be exceedingly rare—

approximately 0.01 strikes per year on average, or approximately 1 direct strike per 100 

years. DOE estimated that “near-strikes,” which occur within a larger radius of the fixture 

and may be survivable by a protected electronic ballast, are also rare—approximately 

0.04 strikes per year on average, or approximately 1 near-strike per 25 years. DOE, 

therefore, considered the probability of lightning-induced ballast replacements to be 

negligible for the average MHLF customer and did not consider this replacement event in 

its main LCC and PBP analysis. DOE expects that MHLF customers in lightning-prone 

areas will experience a higher probability of transient-induced ballast failures, and DOE 

estimated the related LCC and PBP effects in its subgroup analysis (see section V.H of 

this final rule). 

For indoor applications, DOE assumed some 250 W and 400 W electronically 

ballasted fixtures were used in heavy industrial settings susceptible to voltage transients. 

The 2010 Lighting Market Characterization estimates that 434 W is the average wattage 

of metal halide lamps in the industrial sector. This means the vast majority of metal 

40National Lightning Safety Institute. See http://lightningsafety.com. 

172 

 
halide lamp fixtures in the industrial sector range between 250 W to 1000 W. The 

engineering analysis only proposed electronic ballasts for 250 W and 400 W light fixtures 

– thus those fixture types were the only types analyzed the LCC subgroup analysis. 

DOE’s research determined that 60 – 80 percent of interior transients are generated by 

equipment (e.g., elevators, machinery, air-conditioners) within the building. The 

magnitude of the transients generated ranged in size as did the frequency of the 

transients. Transient voltage surge suppressors (known mostly as TVSS) and/or other 

surge protection devices have become more common in industrial buildings. DOE found 

electronic fluorescent ballasts (although a different technology, an example of what can 

be accomplished) that manufacturers claimed could survive in industrial settings. DOE

assumed that transients could reduce the life of electronic metal halide ballasts by 20 

percent and thus modeled this reduction in the LCC subgroup analysis. DOE, therefore, 

considered the probability of transient-induced surge protection and ballast replacements 

to be negligible for the average MHLF customer and did not consider this replacement 

event in its main LCC and PBP analysis. DOE expects that some MHLF customers in 

heavy industrial indoor applications areas will experience a higher probability of 

transient-induced surge protection and ballast failures, and DOE estimated the related 

LCC and PBP effects in its subgroup analysis (see section V.H of this final rule).

For more information regarding replacement costs, see chapter 8 of the final rule 

TSD.

173 
7. Equipment Lifetime

For the August 2013 NOPR, DOE defined equipment lifetime as the age (in hours 

in operation) when a fixture, ballast, or lamp is retired from service. The time period used 

for the LCC and PBP analysis in this rulemaking is the average lifetime of the baseline 

metal halide lamp fixture. For fixtures in all equipment classes, DOE assumed average 

lifetimes for indoor and outdoor fixtures of 20 and 25 years, respectively. 

Metal halide lamp fixtures are operated by either magnetic or electronic ballasts. 

In the August 2013 NOPR, DOE assumed that magnetic ballasts last for 50,000 hours and 

electronic ballasts last for 40,000 hours. Similarly, MH lamp lifetimes vary by lamp 

technology and equipment class. DOE assumed that ballast and lamp lifetimes can vary 

due to both physical failure and economic factors (e.g., early replacements due to 

retrofits); consequently, DOE accounted for variability in lifetimes in LCC and PBP via 

the Monte Carlo simulation, and in the shipments and NIA analyses by assuming a 

Weibull distribution for lifetimes to accommodate failures and replacements.41 78 FR 

51464, 51504 (Aug. 20, 2013).

DOE received comments that its analysis unfairly penalized electronically 

ballasted designs by modeling an additional ballast replacement late in the fixture 

lifetime. For example, a customer with an electronically ballasted indoor fixture (20-year 

lifetime) would have to install a second replacement ballast approximately 2 years before 

41 Weibull distribution is a probability density function; for more information, see 

www.itl.nist.gov/div898/handbook/eda/section3/eda3668.htm. 

174 

 
retiring the fixture, which the commenters considered unrealistic. In comparison, a 

customer with a magnetically ballasted fixture would face only one ballast replacement, 

given the longer ballast lifetime. To more fairly model the late ballast replacements, the 

commenters suggested assigning a residual value to remaining ballast life at the end of 

the fixture’s life. (ASAP, No. 62 at pp. 3–4; CA IOUs, No. 54 at pp. 4–5) DOE agrees 

with this approach, and included the residual value remaining in both lamps and ballasts 

in its LCC and PBP analysis. ASAP also suggested an alternative that uses a distribution 

of fixture lifetimes in the LCC and PBP analysis instead of a single average value. 

(ASAP, No. 62 at p. 4) DOE agrees with the use of a distribution of fixture lifetimes, 

which captures both early fixture failures (avoiding a second ballast replacement) and 

customers using fixtures beyond the average lifetimes (more fully using the second 

replacement ballast). For this final rule, DOE used a distribution of fixture, ballast, and 

lamp lifetimes as inputs to its LCC and PBP analysis.

For more information regarding equipment lifetimes, see chapter 8 of the final 

rule TSD.

8. Discount Rates

The discount rate is the rate at which future expenditures are discounted to 

estimate their present value. In this final rule, DOE estimated separate discount rates for 

commercial, industrial, and outdoor stationary applications. For all related customers,

DOE estimated the cost of capital for commercial and industrial companies by examining 

both debt and equity capital, and DOE developed an appropriately weighted average of 

the cost to the company of equity and debt financing. For this final rule, DOE also

175 
developed a distribution of discount rates for each end-use sector from which the Monte 

Carlo simulation samples.

For each sector, DOE assembled data on debt interest rates and the cost of equity 

capital for representative firms that use metal halide lamp fixtures. DOE determined a 

distribution of the weighted-average cost of capital for each class of potential owners 

using data from the Damodaran online financial database.42 The average discount rates, 

weighted by the shares of each rate value in the sectoral distributions, are 4.9 percent for 

commercial end users, 4.7 percent for industrial end users, and 3.4 percent for outdoor 

stationary end users. 

For more information regarding discount rates, see chapter 8 of the final rule 

TSD.

9. Analysis Period Fixture Purchasing Events

DOE designed the LCC and PBP analysis for this rulemaking around scenarios 

where customers need to purchase a metal halide lamp fixture. The “event” that prompts 

the purchase of a new fixture (either a ballast failure or new construction/renovation) was 

assumed to influence the cost-effectiveness of the customer purchase decision. DOE 

assumed that a customer will replace a failed fixture with an identical fixture in the base 

case, or a new standards-compliant fixture with comparable light output in the standards 

case. DOE analyzed six representative equipment classes for fixtures and presented the 

42 The data are available at pages.stern.nyu.edu/~adamodar. (Last accessed August 21, 2013.)

176 

 
results for each of these representative equipment classes by fixture purchasing event, 

which influenced the LCC and PBP results.

For more information regarding fixture purchasing events for the LCC analysis, 

see chapter 8 of the final rule TSD.

G. National Impact Analysis- National Energy Savings and Net Present Value Analysis

DOE’s NIA assessed the national energy savings (NES) and the national net 

present value (NPV) of total customer costs and savings that would be expected to result 

from new or amended standards at specific efficiency levels.

DOE used a Microsoft Excel spreadsheet model to calculate the energy savings 

and the national customer costs and savings from each TSL. The TSD and other 

documentation for the rulemaking help explain the models and how to use them, enabling 

interested parties to review DOE’s analyses by changing various input quantities within 

the spreadsheet.

DOE used the NIA spreadsheet to calculate the NES, and the NPV of costs and 

savings, based on the annual energy use and total installed cost data from the energy use 

and LCC analyses. DOE projected the energy savings, energy cost savings, equipment 

costs, and NPV of customer benefits for each equipment class for equipment sold from 

2017 through 2046. The projections provided annual and cumulative values for all four 

output parameters.

Comment [AGA14]: Change requested by 

OIRA.

177 
DOE evaluated the impacts of new and amended standards for metal halide lamp

fixtures by comparing base-case projections with standards-case projections. The basecase projections characterize energy use and customer costs for each equipment class in 

the absence of new or amended energy conservation standards. DOE compared these 

projections with projections characterizing the market for each equipment class if DOE 

adopted new or amended standards at specific energy efficiency levels (i.e., the TSLs or 

standards cases) for that class. In characterizing the base and standards cases, DOE 

considered historical shipments, the mix of efficiencies sold in the absence of new 

standards, and how that mix may change over time. Additional information about the 

NIA spreadsheet is in the final rule TSD chapter 11.

Table V.8 summarizes the approach and data DOE used to derive the inputs to the 

NES and NPV analyses for the August 2013 NOPR, as well as the changes to the 

analyses for the final rule. A discussion of selected inputs and changes follows. See 

chapter 11 of the final rule TSD for further details.

Table V.8 Approach and Data Used for National Energy Savings and Customer Net 

Present Value Analyses

Inputs Proposed Rule Changes for the Final Rule

Shipments Developed annual shipments 

from shipments model

See Table V.9

Annual Energy Consumption per 

Unit

Established in the energy use 

analysis (NOPR TSD chapter 

7)

See section V.E

Rebound Effect 0% No change

Electricity Price Forecast AEO2013 No change

Energy Site-to-Source Conversion 

Factor

Used annually variable site 

kWh to source Btu conversion 

factor

No change

Discount Rate 3% and 7% real No change

Present Year 2013 No change

178 
1. Shipments

Equipment shipments are an important component of any estimate of the future 

impact of a standard. Using a three-step process, DOE developed the shipments portion 

of the NIA spreadsheet, a model that uses historical data as a basis for projecting future 

fixture shipments. First, DOE used U.S. Census Bureau fixture shipment data, NEMA 

lamp shipment data, and NEMA ballast sales trends to estimate historical shipments of 

each fixture type analyzed. Second, DOE estimated an installed stock for each fixture in 

2017 based on the average service lifetime of each fixture type. Third, DOE developed 

annual shipment projections for 2017–2046 by modeling fixture purchasing events, such 

as replacement and new construction, and applying growth rate, replacement rate, and 

alternative technologies penetration rate assumptions. For details on the shipments 

analysis, see chapter 10 of the final rule TSD. 

Table V.9 Approach and Data Used for the Shipments Analysis

Inputs Proposed Rule Changes for the Final Rule

Historical Shipments Used historical HID fixture and lamp 

shipments to develop shipments for MH 

fixtures

Revised historical MH fixture 

shipments based on updated NEMA 

MH ballast shipment trends

Fixture Stock Based projections on the shipments that 

survive up to a given date; assumed 

Weibull lifetime distribution

No change

Growth Adjusted based on fixture market No change

Base Case Scenarios Developed “low” and “high” shipments 

scenarios

Revised “low” and “high” 

shipments scenarios based on 

revised historical MH fixture 

shipments

Standards Case 

Scenarios

Analyzed Roll-up only No change

179 
a. Historical Shipments

For the August 2013 NOPR, DOE reviewed U.S. Census Bureau data from 1993 

to 2001 for metal halide lamp fixtures.43 DOE compared the MHLF census data to 

NEMA data for historical metal halide lamp shipments from 1990 to 2008 taken from 

DOE’s final determination for HID lamps published on July 1, 2010. 75 FR 37975. DOE 

found a correlation between metal halide lamp fixture and metal halide lamp shipments. 

From 1993 to 2001, the number of MHLF shipments on average represented 37 percent 

of the amount of lamp shipments, with a standard deviation of 3 percent. Using this 

relationship, DOE multiplied all of the metal halide lamp shipments from 1990 to 2010 

by 37 percent to estimate the historical shipments of metal halide lamp fixtures. DOE 

assumed that shipments for metal halide lamp fixtures would peak somewhere between 

2010 and 2015, and generally decline thereafter. 78 FR 51464, 51506 (Aug. 20, 2013). 

DOE received multiple comments indicating that its shipments analysis 

significantly underestimated the rate of decline in the MHLF market, and thereby 

overestimated total MHLF shipments. (APPA, No. 51 at p. 2; NEMA, No. 56 at pp. 2, 4, 

22; ULT, No. 50 at p. 15) NEMA presented new MH ballast sales trend graphs at the 

NOPR public meeting, suggesting a much steeper decline in fixture shipments from 2008 

to 2013 than assumed in the August 2013 NOPR. (NEMA, No. 44 at p. 15) For this final 

rule, DOE retained its peak in fixture shipments, and revised its trend for subsequent 

historical shipments to approximate the new sales trend information provided by NEMA. 

43 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial Reports, 

Fluorescent Lamp Ballasts, MQ335C. 2008. (Last accessed October 28, 2013). <www.census.gov/mcd/>

180 

 
As a result, total estimated MHLF shipments for 2013 were approximately 31 percent 

lower than in the August 2013 NOPR. By extension, DOE also revised its projected base 

case shipments downward, as discussed in section V.G.1.c of this final rule. 

b. Fixture Stock Projections

In the August 2013 NOPR shipments analysis, DOE calculated the installed 

fixture stock using estimated historical fixture shipments and its projected shipments for 

future years. DOE estimated the installed stock during the analysis period by using 

fixture shipments and calculating how many will survive up to a given year based on a 

Weibull lifetime distribution for each fixture type. 78 FR 51464, 51506 (Aug. 20, 2013). 

DOE received no comments on the August 2013 NOPR regarding its fixture stock 

projection method and retained this approach for this final rule.

c. Base Case Shipment Scenarios

For the August 2013 NOPR, DOE assumed that shipments for MHLFs peaked 

somewhere between 2010 and 2015. For projected fixture shipments in the “low” and 

“high” shipment scenarios, DOE projected a decline that fell back to the levels in 2000 

and 2006, respectively.44 78 FR 51464, 51506 (Aug. 20, 2013). As discussed previously, 

several commenters stated that DOE overestimated total MHLF shipments in its NOPR 

analysis. (APPA, No. 51 at p. 2; NEMA, No. 56 at pp. 2, 4, 22; ULT, No. 50 at p. 15) For 

44 The August 2013 NOPR text at 78 FR 51463, 51506 (August 20, 2013) incorrectly indicated that fixture 

shipments in the “high” scenario in 2040 roughly equaled the shipments in 2006. Several commenters 

stated that the declining MHLF market would not return to 2006 shipment levels. (APPA, No. 51 at p.2; 

NEMA, No. 56 at p. 4) DOE’s actual modeled fixture shipments for 2040 were roughly equal to pre-2000 

shipments, significantly lower than the 2006 peak.

181 

 
this final rule, DOE used new MH ballast sales trend information provided by NEMA to 

revise its historical fixture shipments, resulting in significantly lower shipment estimates 

for 2008 to 2013. As a result, DOE’s projected fixture shipments through 2047 were also 

significantly lower; for example, the “low” scenario shipments for 2020 were 31 percent 

lower than the corresponding NOPR estimate and declined to approximately pre-1990 

levels by the end of the shipments analysis period.

d. Standards-Case Efficiency Scenarios

Several of the inputs for determining NES (e.g., the annual energy consumption 

per unit) and NPV (e.g., the total annual installed cost and the total annual operating cost 

savings) depend on equipment efficiency. For the August 2013 NOPR, DOE used a 

“Roll-up” shipment efficiency scenario, which is a standards case in which all equipment 

efficiencies in the base case that do not meet the standard would “roll up” to the lowest 

level that can meet the new standard level. Equipment efficiencies in the base case above 

the standard level are unaffected in the Roll-up scenario, as these customers are assumed 

to continue to purchase the same base-case fixtures. The Roll-up scenario characterizes 

customers primarily driven by the first cost of the analyzed equipment, which DOE 

believes more accurately characterizes the metal halide lamp fixture marketplace. 78 FR 

51464, 51506 (Aug. 20, 2013).

NEMA and ULT commented on the August 2013 NOPR, stating that setting a 

standard for 150 W fixtures that requires electronic ballasts will steer customers to higher 

wattage, magnetically ballasted fixtures. (NEMA, Public Meeting Transcript, No. 48 at 

182 
pp. 33-34; NEMA, No. 44 at p. 9; NEMA, No. 56 at p. 24; ULT, Public Meeting 

Transcript, No. 48 at pp. 144-145; ULT, No. 50 at p. 2) 

DOE agrees that there is some possibility of a shift between the technologies. The 

ballast types play a role in the decision, but so do initial costs, life-cycle costs, and utility 

features of the light source. DOE assume that customer would not opt for the 175 W 

magnetically ballasted fixture if the 150 W light fixture is cheaper. DOE’s analysis has 

the 175 W metal halide lamp fixture at the baseline and efficiency levels 1 – 3 to be 

greater than the 150 W metal halide lamp fixture at the baseline and efficiency levels 1 – 

3. Therefore, DOE assumes that only if a standard that were set requiring efficiency level 

4 would customers chose to install 175 W metal halide lamp fixtures. In this shift 

scenario, DOE did not assume an overwhelming number of customers would shift to 175 

W because the economics and utility features between the two options were similar. 

Because the options were so similar, there was no an overwhelming reason for customers 

to make large shifts to the 175 W metal halide lamp fixture as a result of a standard 

requiring electronic ballasts for 150 W metal halide lamp fixtures. 

Similarly, DOE modeled a shift of customers migrating from 1000 W probe-start 

fixtures to either 875 W pulse-start or 1000 W pulse-start fixtures as a result of the design 

standard being part of this rule. In order to examine the market shift that would be 

expected to occur under a design standard for the 500 W – 1000 W equipment class, 

DOE developed an econometric-based consumer choice model to estimate the relative 

fraction of 1000 W probe-start fixture customers who migrate to 1000 W pulse-start and 

875 W pulse-start fixtures. The consumer choice model was based on a conditional logit 

183 
model to establish consumer preference between these two options, based on economic 

parameters, coupled with a market diffusion curve to estimate the rapidity of movement 

in the market toward the consumer preference predicted by the logit model. Data 

underlying the consumer choice model reflected that for commercial and industrial 

lighting purchasers as presented in DOE’s General Service Fluorescent Lamps 

preliminary analysis technical support document.45 DOE estimated that approximately 27 

percent of those customers using 1000 W probe-start fixtures in the base case shipment 

forecast would shift to 875 W pulse-start fixtures and the remaining 73 percent of 1000 

W probe-start customers would migrate to 1000 W pulse-start fixtures. These market 

shifts were used in the shipments estimates underlying the calculation of the design 

standard benefits in the NIA. 

DOE also received comments on the August 2013 NOPR stating that additional 

costs resulting from potential standards could increase the rate at which MHLF customers 

migrate to other lighting technologies. (APPA, No. 51 at pp. 2–3; NEMA, No. 56 at p. 

23; ULT, No. 50 at p. 15) NEMA noted that costs for many fixture types had already 

increased to meet recent new National Electrical Code requirements. (NEMA, No. 56 at 

p. 23) NEMA and ULT observed that applications requiring high lumen output and hightemperature operating environments still favor metal halide lamp fixtures, however. 

(NEMA, No. 56 at p. 22; ULT, No. 50 at p. 15) DOE believes that its revised base case 

45 U.S. Department of Energy – Office of Energy Efficiency and Renewable Energy. Energy Conservation 

Program for Consumer Products: Preliminary Technical Support Document: Energy Efficiency Standards 

for Consumer Products: General Service Fluorescent Lamps and Incandescent Reflector Lamps. February 

2013. Washington, D.C. http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-

0022

184 

 
shipments (that incorporate new NEMA sales trend information) capture the main effect 

of migration to other lighting technologies, and illustrate a significant decrease in total 

MHLF shipments compared to the NOPR analysis. DOE reserved the standards-case 

shipments scenario to characterize the purchasing behaviors of remaining MHLF 

customers, and retained its Roll-up approach for this final rule.

2. Site-to-Source Energy Conversion

To estimate the national energy savings expected from appliance standards, DOE 

uses a multiplicative factor to convert site energy consumption into primary or source 

energy consumption (the energy required to convert and deliver the site energy). These 

conversion factors account for the energy used at power plants to generate electricity and 

losses in transmission and distribution, as well as for natural gas losses from pipeline 

leakage and energy used for pumping. For electricity, the conversion factors vary over 

time due to projected changes in generation sources (i.e., the types of power plants 

projected to provide electricity to the country). The factors that DOE developed are 

marginal values, which represent the response of the system to an incremental decrease in 

consumption associated with appliance standards.

For the August 2013 NOPR, DOE used the annually variable site-to-source 

conversion factors based on the version of NEMS that corresponds to AEO2013, which 

provided energy forecasts through 2035. For 2036–2044, DOE used conversion factors 

that remain constant at the 2035 values. 78 FR 51464, 51506 (Aug. 20, 2013). DOE 

received no comments regarding site-to-source conversion factors, and retained its 

approach for today’s final rule.

185 
DOE has historically presented NES in terms of primary energy savings. In 

response to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle 

Measurement Approaches to Energy Efficiency Standards” appointed by the National 

Academy of Science, DOE announced its intention to use FFC measures of energy use 

and greenhouse gas and other emissions in the national impact analyses and emissions 

analyses included in future energy conservation standards rulemakings. 76 FR 51281 

(August 18, 2011) While DOE stated in that notice that it intended to use the Greenhouse 

Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model to 

conduct the analysis, it also said it would review alternative methods, including the use of 

NEMS. After evaluating both models and the approaches discussed in the August 18, 

2011 notice, DOE published a statement of amended policy in the Federal Register in 

which DOE explained its determination that NEMS is a more appropriate tool for its FFC 

analysis and its intention to use NEMS for that purpose. 77 FR 49701 (August 17, 2012). 

DOE received one comment, which was supportive of the use of NEMS for DOE’s FFC 

analysis.46 

The approach used for today’s final rule, and the FFC multipliers that were 

applied, are described in appendix 11B of the final rule TSD. NES results are presented 

in both primary and FFC savings in section VII.B.3.a. 

46 Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk Lundblade.

186 

 
H. Customer Subgroup Analysis

The life-cycle cost subgroup analysis evaluates impacts of standards on 

identifiable groups, such as different customer populations or business types that may be 

disproportionately affected by any national energy conservation standard level. For the 

August 2013 NOPR, DOE estimated LCC savings and payback periods for three 

subgroups: utilities, transportation facility owners, and warehouse owners. These three 

subgroups were distinguished from average MHLF customers by higher maintenance 

costs (utilities), higher operating hours (transportation facility owners), and lower 

operating hours (warehouse owners). 78 FR 51464, 51507 (Aug. 20, 2013).

Several utilities commented that DOE incorrectly assigned the same retail 

electricity rates to all three subgroups, when utilities would instead pay lower wholesale 

rates, resulting in lower energy cost savings and longer payback periods. (APPA, No. 51 

at pp. 8–9; EEI, No. 53 at p. 4; NRECA, No. 61 at p. 2) DOE agrees with this distinction, 

and DOE referenced EIA wholesale electricity prices47 for the utility subgroup in its final 

rule analysis. As discussed previously in section V.F.6 of this final rule, DOE is also

evaluating two new customer subgroups for transient-prone fixtures in outdoor and heavy 

industrial indoor applications. DOE assumed that owners of transient-prone outdoor 

fixtures would face shortened surge protection and electronic ballast lifetimes because of 

lightning-induced voltage transients, resulting in a 15 percent shorter electronic ballast 

life requiring more frequent electronic ballast and surge protection device replacements 

during the fixture lifetime. For indoor fixtures, DOE assumed that fixture owners in 

47 See www.eia.gov/electricity/wholesale/ (Last accessed December 2013).

187 

 
heavy industrial environments would face shortened surge protection and electronic 

ballast lifetimes because of voltage transients, resulting in a 20% shorter electronic 

ballast life requiring more frequent electronic ballast and surge protection device 

replacements during the fixture lifetime. 

For more information regarding the customer subgroup analysis, see chapter 12 of 

the final rule TSD.

I. Manufacturer Impact Analysis

DOE conducted an MIA to estimate the financial impact of new and amended 

energy conservation standards on manufacturers of MHLFs and ballasts, and to estimate 

the impact of new and amended standards on employment and manufacturing capacity. 

The quantitative aspect of the MIA relies on the GRIM, an industry cash-flow model

customized for MHLFs and ballasts covered in this rulemaking. The GRIM is used to 

calculate INPV, which is the key MIA output. In its analysis, DOE used the GRIM to 

calculate cash flows using standard accounting principles and to compare the difference 

in INPV between the base case and various TSLs (the standards cases). The difference in 

INPV between the base and standards cases represents the financial impact of new and 

amended MHLF standards on MHLF and ballast manufacturers. DOE employed different 

assumptions about markups and future shipments to produce ranges of results that 

represent the uncertainty about how the MHLF and ballast industries will respond to 

energy conservation standards.

188 
In the MIA, DOE typically groups its estimates of manufacturer impacts by the 

major equipment types that are produced by the same manufacturers. The covered 

equipment in today’s rulemaking is MHLFs; however, by requiring particular MH ballast 

efficiencies in this regulation, MH ballast manufacturers will also be affected by new and 

amended MHLF standards. The MHLF and ballast markets are served by separate groups 

of manufacturers. DOE therefore presents impacts on MHLF manufacturers and MH 

ballast manufacturers separately.

DOE outlined its complete methodology for the MIA in the previously published 

NOPR. The complete MIA is presented in chapter 13 of this final rule TSD.

1. Manufacturer Production Costs

Manufacturing higher-efficiency equipment is typically more expensive than 

manufacturing baseline equipment due to the need for more costly components. The 

resulting changes in the MPCs of the analyzed equipment can affect the revenues, gross 

margins, and cash flows of manufacturers. DOE strives to accurately model the potential 

changes in these equipment costs, as they are a key input for the GRIM and DOE’s 

overall analysis. For the final rule, DOE updated the MHLF and some ballast MPCs 

based on stakeholder comments. For a complete description of the changes made to the 

MPCs see section V.C.12 of this final rule.

2. Shipment Projections

Changes in sales volumes and efficiency distribution of equipment over time can 

significantly affect manufacturer finances. The GRIM estimates manufacturer revenues 

189 
based on total unit shipment projections and the distribution of shipments by efficiency 

level. For the final rule, DOE reduced the number of shipments of MHLFs in both the 

low- and high-shipment scenarios based on stakeholder comments. For the MIA, the 

GRIM uses the NIA’s annual shipment projections from the base year, 2014, to 2046, 

which is the end of the analysis period. For a complete description of the changes made 

to the shipment analysis see section V.G.1 of this final rule.

3. Markup Scenarios

For the MIA, DOE modeled two standards case markup scenarios to represent the 

uncertainty regarding the potential impacts on prices and profitability for manufacturers 

following the implementation of new and amended energy conservation standards: (1) a 

flat, or preservation of gross margin, markup scenario and (2) a preservation of operating 

profit markup scenario. These scenarios lead to different markup values, which when 

applied to the inputted MPCs, result in varying revenue and cash-flow impacts.

For the final rule, DOE did not alter the markup scenarios, values, or 

methodology used in the NOPR analysis.

4. Production and Capital Conversion Costs

New and amended energy conservation standards will cause manufacturers to 

incur one-time conversion costs to bring their production facilities and equipment designs 

into compliance. For the MIA, DOE classified these one-time conversion costs into two 

major groups: (1) product conversion costs and (2) capital conversion costs. Product 

conversion costs are one-time investments in research, development, testing, marketing, 

190 
and other non-capitalized costs necessary to make equipment designs comply with the 

new and amended standards. Capital conversion costs are one-time investments in 

property, plant, and equipment necessary to adapt or change existing production facilities 

such that new equipment designs can be fabricated and assembled. DOE created separate 

conversion costs for MHLF and ballast manufacturers.

In response to the NOPR, Acuity stated they believed the conversion costs for 

fixture manufacturers seemed surprisingly low. (Acuity, Public Meeting Transcript, No. 

48 at p. 285) DOE assumed that there would not be any capital conversion costs for 

fixture manufacturers at efficiency levels requiring more efficient magnetic ballasts. This 

is based on DOE’s assumption in the engineering analysis that the size of the magnetic 

ballast would not need to be increased at those efficiency levels and therefore, fixture 

manufacturers would not need to redesign their MHLFs to be compatible with the higher 

efficiency magnetic ballasts. Fixture manufacturers would, however, incur product 

conversion costs at efficiency levels requiring magnetic ballasts. Higher ballast efficiency 

levels would require fixture manufacturers to re-test and re-certify fixtures with ballasts 

that were redesigned to meet standards. DOE believes that there would be both product 

conversion costs, as well as capital conversion costs, for fixture manufacturers at all 

efficiency levels requiring electronic ballasts since fixture manufacturers producing 

MHLFs containing magnetic ballasts would need to redesign their fixture production 

process.

Several manufacturers stated there would be significant conversion costs to 

comply with the MHLF standards proposed in the NOPR. Cooper, for example stated that 

191 
they would have to make substantial investments to comply with the standards proposed 

in the NOPR. (Cooper, Public Meeting Transcript, No. 48 at p. 58) ULT expressed 

concern that complying with the proposed standards would consume significant company 

time and resources. They commented that from a design cycle standpoint, one fixture 

could take eight to 12 months to redesign and test, which includes design validation 

testing, UL testing, and life-cycle testing. (ULT, Public Meeting Transcript, No. 48 at p. 

201) DOE acknowledges that manufacturers would have to make investments to comply 

with MHLF standards. As part of the MIA, DOE attempts to quantify the time and 

monetary expenditures that would comprise the capital and product conversion costs, 

which MHLF and ballast manufacturers would need to incur to convert all their 

equipment to meet the standards. These conversion cost estimates were based on DOE’s 

research and modified based on manufacturer feedback during interviews.

DOE modified the capital conversion costs for the final rule based on the 

reduction in shipments modeled in the final rule shipments analysis. Consequently, DOE 

reduced the capital conversion costs proportionally to the reduction in shipments of the 

final rule, since capital conversion costs are correlated to the shipment volume in the year 

standards require compliance. DOE did not alter the product conversion costs since these 

costs are correlated with the number of product designs impacted by standards, not 

necessarily the shipment volume in the year standards require compliance.

5. Other Comments from Interested Parties

During the NOPR public meeting and comment period, interested parties 

commented on the assumptions, methodology, and results of the NOPR MIA. DOE 

192 
received comments about the compliance period, alternative technologies, the 

opportunity cost of investments, the replacement ballast market, and potential impact on 

MH lamp manufacturers. These comments are addressed below.

a. Compliance Period

NEMA stated that based on its analysis, a three-year compliance period would be 

inadequate for the extensive R&D effort that MHLF and ballast manufacturers would 

have to undergo in order to redesign all equipment to be compliant with the efficiency 

levels proposed in the NOPR. NEMA stated that in their analysis, they found that 

manufacturers would face significant technical obstacles when trying to produce high 

volumes of compliant MHLFs and ballasts due to the challenging nature of processing 

higher-grade materials, such as M6 steel. NEMA does not believe that lighting 

manufacturers are willing to dedicate enough resources to MHLF and ballast technology 

to be able to redesign all wattages during a three-year time period. (NEMA, No. 56 at p. 

3) While DOE acknowledges there are difficulties and costs associated with 

manufacturing higher efficiency products, all efficiency levels analyzed in DOE’s 

engineering analysis, including max tech, are technologically feasible to manufacture. 

For a complete description of MHLFs and ballasts and analyzed in the engineering 

analysis see section V.C of this final rule.

NEMA also commented that the MHLF NOPR proposed expanding the scope of 

covered equipment to include wattage ranges previously not covered by the standards 

prescribed in EISA 2007, as well as eliminating exemptions for certain equipment that 

were granted by EISA 2007. According to NEMA, the number of MHLFs impacted 

193 
would be significant and bringing them into compliance would be time-consuming and 

costly. NEMA listed some of the most significant compliance obstacles that 

manufacturers would face including: evaluating ballast performance to identify compliant 

ballasts; determining if ballasts in fixtures need to be replaced; modifying order and 

quotation systems; obtaining the test data for CCE; educating manufacturing staff; 

educating customers; and managing order backlogs. NEMA believes that managing these 

logistics would divert limited resources within lighting divisions and would prevent 

manufacturers from focusing on developing and selling more efficient lighting 

technology, such as LEDs. According to NEMA, the proposed standards would delay the 

market transition to technologies that are more efficient than those established by this 

rulemaking. (NEMA, No. 56 at p. 20)

During the NOPR public meeting, NEMA further emphasized the complex 

logistics manufacturers would face in complying with new and amended energy 

conservation standards. NEMA stated that a large amount of equipment would have to be 

redesigned and several sales channels would be impacted if DOE expanded the scope of 

covered MHLFs beyond what was included in EISA 2007. (NEMA, Public Meeting 

Transcript, No. 48 at pp. 19-20) According to NEMA, manufacturers would have to 

employ significant company resources to educate internal staff, such as marketing and 

sales representatives, about new equipment available for purchase. Time and money 

would also have to be spent updating IT systems due to changes in order processing and 

inventory management software. (NEMA, Public Meeting Transcript, No. 48 at p. 22)

194 
NEMA further argued that manufacturers would have to use company resources 

to educate their customers about redesigned compliant equipment. For fixture 

manufacturers, customers include OEMs, distributors, contractors, designers, home 

centers, and showrooms. Manufacturers would have to modify marketing materials and 

manage orders and contracts which might extend one to two years into the future. 

According to NEMA, managing these contracts would be complicated, as the prices and 

performances of the MHLFs are generally guaranteed and would change due to 

standards. (NEMA, Public Meeting Transcript, No. 48 at p. 26) Ballast manufacturers 

also often have one or two-year contracts with their customers, who agree to buy ballasts 

that achieve particular performance levels for an agreed upon price. Ballast 

manufacturers would have to renegotiate these contracts, which would be difficult 

because prices and ballast performances would change due to standards. (NEMA, Public 

Meeting Transcript, No. 48 at p. 23)

NEMA also stated that fixture manufacturers would not be able to start preparing 

for energy conservation standards until ballast manufacturers had completed their 

redesign and compliance efforts. Fixture manufacturers would have to assess whether 

redesigned ballasts were the same form and size and whether they had the same thermal 

characteristics before they would be able to begin redesigning fixtures. According to 

NEMA, if a particular ballast needed to be redesigned, that could mean dozens, if not 

hundreds, of unique fixtures using that particular ballast would also need to be 

redesigned. NEMA stated any change in a ballast’s form or thermal characteristics would 

require a tremendous redesign effort for fixture manufacturers. (NEMA, Public Meeting 

Transcript, No. 48 at p. 25)

195 
NEMA further commented that MHLFs and ballasts would also have to go 

through electrical, safety, thermal, and photometric testing, all of which would consume 

manufacturers’ time and resources. NEMA expressed concern that testing of the new and 

modified ballasts and fixtures would take a significant amount of time and would further 

complicate manufacturers’ efforts to abide by the three-year compliance period. NEMA 

pointed out that when the DOE CCE rule went into effect, manufacturers took six months 

to obtain accurate samples for certification. Manufacturers would have to redesign and 

test modified ballasts and fixtures before even beginning to collect samples for the CCE 

rule. NEMA argued that this would be difficult to achieve within the three-year 

compliance period. (NEMA, Public Meeting Transcript, No. 48 at p. 22) NEMA also 

questioned whether UL could handle the volume of testing that would be necessary to 

comply with standards in such a short period of time since all redesigned MHLFs and 

ballasts would need to be certified. (NEMA, Public Meeting Transcript, No. 48 at p. 26) 

DOE acknowledges that new and amended energy conservation standards will 

require MHLF and ballast manufacturers to undergo changes to their production 

processes, modify existing equipment, develop new models, and make a series of 

complex logistical decisions. In the NOPR, DOE assumed ballast and fixture 

manufacturers must comply with standards as of January 1, 2015. However, as described 

in section VI.C, DOE has revised the compliance date in the final rule to be consistent 

with the three-year time frame specified in EISA 2007. DOE assumes a three-year 

compliance period when estimating all capital and product conversion costs, which DOE 

included as potential burdens when selecting standards for MHLFs.

196 
b. Alternative Technologies

DOE recognizes that there are alternative lighting technologies that can be used in 

the same applications as MHLFs and that MHLF shipments are on the decline. Lighting 

manufacturers, for example are heavily investing in R&D for LEDs, an advanced and 

highly efficient lighting technology for which demand is growing rapidly. LED 

technology has matured to the point that it can be used in a number of applications in 

which MHLFs are typically used, predominantly at lower wattages. However at higher 

wattages, it is more difficult for customers to switch from MH to LED.

At the NOPR public meeting, Philips pointed out that a majority of R&D 

resources within the lighting industry have already been transferred to LEDs and away 

from traditional lighting technologies. (Philips, Public Meeting Transcript, No. 48 at p. 

50) ULT stated that by creating new standards for a technology with declining market 

share, DOE is hindering this trend, as manufacturers will have to divert resources away 

from developing more advanced and efficient technologies to convert their metal halide 

product lines. (ULT, Public Meeting Transcript, No. 48 at p. 61) Acuity noted, however, 

that in the higher-wattage applications, LED technology has not yet developed a highintensity lighting solution, and therefore the market will be forced to continue to develop 

MH lamps for those applications. (Acuity, Public Meeting Transcript, No. 48 at p. 24)

APPA, NRECA, and EEI all noted that due to market conditions and the existence 

of other lighting technologies, manufacturers may have no incentive to make replacement 

ballasts for existing MHLFs. (APPA, No. 51 at p. 7; NRECA, No. 61 at p. 2; EEI, No. 53 

197 
at p. 3) APPA pointed out that MH ballast production has been declining since 2008 and 

that manufacturers may decide to halt the production of replacement ballasts to focus on 

LEDs. APPA argued that if replacement ballasts became commercially unavailable, the 

original intent of the rule, which was not to force the implementation of new fixtures, 

would be lost. (APPA, No. 51 at p. 7) NEEA argued that to avoid this problem, 

regulations are needed for LEDs so that manufacturers would have incentive to perform 

research and development on MHLFs to make them more efficient. (NEEA, Public 

Meeting Transcript, No. 48 at p. 53)

DOE acknowledges that the MHLF market is currently in decline and has 

modeled this decline into its projections of future MHLF and ballast shipments. Any 

effects of increased R&D of technologies not covered by this rulemaking and the market 

penetration of those technologies into the MHLF market are discussed in the following 

section of the MIA (V.I.5.c) DOE agrees that there are a number of applications in which 

LED cannot provide equivalent lumen output to MHLF light levels and that there will be 

a continued market for this equipment. DOE expects that even with the standards adopted 

by this final rule there will be a market for manufacturers to make replacement ballasts.

c. Opportunity Cost of Investments

Several manufacturers commented that developing MHLFs to meet energy 

conservation standards would have opportunity costs. NEMA argued that diverting 

resources to convert MHLFs and ballasts to comply with new and amended standards 

would negatively impact the lighting market by delaying the introduction of products 

with potentially higher efficiency, better utility, and more responsive controls. (NEMA, 

198 
No. 56 at p. 24) Musco Lighting commented that the proposed standard requiring pulsestart lamps would divert critical R&D resources to attempt to develop a technology that 

does not exist and to this point has not been determined as commercially achievable. 

Musco Lighting stated R&D resources in the lighting industry should remain focused on 

technologies that have significant opportunities for energy reduction, such as LEDs. 

Musco Lighting believes the proposed MHLF standards would not achieve significant 

energy savings and would potentially hold back substantial lighting efficiency gains by 

diverting resources. (Musco Lighting, No. 55 at p. 3) 

Most manufacturers agreed that LEDs are the future of the lighting industry, and 

therefore are primarily focusing R&D resources on this technology as opposed to MH 

technology. As a result, NEMA pointed out that lighting manufacturers are working with 

fewer human resources dedicated to MH than they were when they first had to come into 

compliance with EISA 2007 MH standards. Meeting those standards was very 

complicated for manufacturers even with the more abundant resources that were 

available. It will be difficult for companies to simultaneously develop LEDs and upgrade 

MHLFs and ballasts (NEMA, Public Meeting Transcript, No. 48 at p. 20)

ULT pointed out that while LEDs are growing in market share, they are still not 

mature enough to work well in all applications; however, manufacturers are getting closer 

to achieving this through R&D. According to ULT, lighting manufacturers are working 

on developing fixtures that are designed to remove heat, keep water out, and help protect 

against surges to allow the use of LEDs in all fixtures. ULT believes that MHLF 

standards requiring manufacturers to spend over a year designing, testing, and validating 

199 
MHLFs and ballasts would slow the integration of LEDs into the market and force 

manufacturers to work on lighting technologies that may not be in the market in the next 

five to 10 years. (ULT, No. 50 at p. 16-17) NEMA commented that if manufacturers 

chose to convert their MH equipment to the proposed efficiency levels, the higher priced 

MHLFs could cause customers to shift to LEDs anyway, which would mean that 

manufacturers would not recoup the cost of investment into MHLFs. (NEMA, Public 

Meeting Transcript, No. 48 at p. 150) Several manufacturers and NEMA said that these 

considerations could cause some fixture and ballast manufacturers to exit the MH market. 

(NEMA, Public Meeting Transcript, No. 48. 283) 

NEMA argued that manufacturers may choose to exit the market due to the fact 

that the proposed standards could have severe impacts on manufacturers. They noted that 

in DOE’s NOPR analysis, MH ballast manufacturers would need to invest up to 29 

million dollars at the proposed TSL and this could result in up to a 25 percent loss of base 

case INPV. According to NEMA, the impacts will be more severe than DOE projected in 

the NOPR because NEMA believes that shipments of MHLFs and ballasts will decline 

much faster than DOE projected. NEMA argued that the rapidly declining MH market 

makes it difficult for manufacturers to justify the significant investments necessary to 

comply with MHLF standards. (NEMA, No. 56 at p. 23) DOE has adjusted the projected 

volume of shipments based on stakeholder feedback. In the final rule shipment analysis, 

there is a sharper decline in MHLF shipments as suggested by NEMA’s comment. For a 

complete description of the changes made to the shipment analysis see section V.G.1 of 

this final rule.

200 
DOE recognizes the opportunity cost associated with any investment, and agrees 

that manufacturers would need to spend capital and company resources to meet today’s 

standards that they would not have to spend in the absence of standards. As a result, 

manufacturers must determine the extent to which they will balance investment in the 

MH market with investment in emerging technologies, such as LEDs. These companies 

will have to weigh tradeoffs between deferring investments and deploying additional 

capital. DOE includes the costs of meeting today’s standard in the conversion costs 

portion of the MIA.

d. Replacement Ballast Market

As noted in the scope of coverage section, this rulemaking covers new MHLFs. 

Even though the metric being regulated is ballast efficiency, the standards set in this 

rulemaking only apply to ballasts sold with new fixtures. Ballasts sold separately, to be 

used as replacement ballasts for existing fixtures, are not required to comply with these 

standards.

There was some concern among stakeholders that manufacturers might not choose 

to manufacture similar wattage ballasts at multiple efficiency levels due to lack of 

economic viability. ULT and Cooper both commented that the proposed standard for new 

MHLFs would affect all MH ballasts and not just new MHLFs because it is economically 

infeasible to maintain two different ballast product lines – one that services the 

replacement market that would not be subject to standards and another that services the 

new MHLF market that would be subject to standards. (ULT, Public Meeting Transcript, 

No. 48 at p. 65-66; Cooper, Public Meeting Transcript, No. 48 at p. 67) NEEA argued 

201 
that while this was probably true, as long as there is a market for replacement MH 

ballasts, some companies would manufacture those replacement ballasts to fulfill that 

market. According to NEEA, a manufacturer could continue their current MH ballast 

production line which would only service the replacement MH ballast market and not 

manufacture ballasts for new MHLFs. (NEEA, Public Meeting Transcript, No. 48 at p. 

72) ULT responded by commenting that manufacturers are not going to want to redesign 

and manufacture two production lines for MH ballasts which would increase their 

inventory and carrying costs for MH ballasts and rather will continue to focus on solid 

state lighting. ULT believes this could open up the replacement ballasts market to 

offshore MH ballast manufacturers and result in an increase in products that will have 

quality and warranty problems, which is bad for end-users. (ULT, Public Meeting 

Transcript, No. 48 at p. 73)

Also several organizations commented on the impact of MHLF standards on the 

portfolio of ballasts available for the replacement market. APPA requested confirmation 

that the standards proposed in the NOPR would not eliminate the production of 

replacement ballasts for existing and future MHLFs. (APPA, No. 51 at p. 1) NEMA, 

ULT, and APPA stated manufacturers could not be expected to maintain product lines for 

both new fixture ballasts and for the replacement or repair of old fixtures. Therefore, 

customers with MHLFs currently installed might be left with stranded assets. However, 

NEMA, ULT, and APPA noted that if standards do not force customers to switch to 

electronic ballasts or magnetic ballasts to incur physical changes, the market could 

continue to be adequately serviced by manufacturers. (NEMA, No. 56 at pp. 10, 24; ULT, 

No. 50 at pp. 17-18; APPA, No. 51 at p. 8) GE noted that if the standard were to require 

202 
larger ballasts, it would mean having no direct replacement for the installed base, 

especially in a situation such as a natural disaster, where the majority of lighting in a 

subdivision would need to be replaced. (GE, Public Meeting Transcript, No. 48 at p. 89) 

Conversely, the Joint Comment stated that there will always be a market for these 

replacement ballasts, regardless of the efficiency requirements, and that it would be a 

business decision whether manufacturers would want to fill that niche market. (Joint 

Comment, No. 62 at p. 7)

DOE’s market analysis found that several of the largest manufacturers of MH 

ballasts responded to the standards mandated by EISA 2007 for 150 W – 500 W ballasts 

sold with new fixtures by offering ballasts with efficiencies that comply with EISA 2007 

standard levels, and replacement ballasts with efficiencies that do not comply with EISA 

2007, at the same wattages. While DOE predicts a similar response to the standards 

adopted in this final rule, the financial viability of offering ballasts that fall above and 

below these standards will be a business decision for each manufacturer. For the MIA, 

DOE includes the costs of upgrading MH ballast production for new MHLFs (and not 

upgrading replacement ballasts) to meet the standards in its analysis and any other course 

of action would be a business decision made by manufacturers which is not modeled by 

DOE.

e. Potential Impact on Metal Halide Lamp Manufacturers

Philips commented that there could be a negative impact on MH lamp 

manufacturers due to MHLF standards. Philips stated as the cost of MHLFs increase due 

to standards more people are going to purchase LEDs and as a result, the volume of 

203 
MHLFs and MH lamps will decrease. Therefore, Philips believes that DOE should take 

into account costs imposed on MH lamp manufacturers associated with MHLF standards. 

(Philips, Public Meeting Transcript, No. 48 at p. 277) DOE recognizes that LEDs are 

continuing to capture more and more of the lighting markets serviced by MHLFs and 

accounts for this shift to LEDs in the shipment analysis for this rulemaking. DOE does 

not believe that MHLF standards will hasten this shift to LEDs, as LEDs are not 

appropriate substitutes for all MHLFs given the large lumen output of the higher wattage 

MHLFs. Therefore, this market shift to LEDs is captured in the base case shipment 

scenario and is not modeled as a standards-induced market shift.

6. Manufacturer Interviews

DOE interviewed manufacturers representing more than 65 percent of MHLF 

sales and 90 percent of MH ballast sales. The NOPR interviews were in addition to the 

preliminary interviews DOE conducted as part of the interim analysis. DOE outlined the 

key issues for the rulemaking for manufacturers in the NOPR. DOE considered the 

information received during these interviews in the development of the NOPR and this 

final rule. Comments on the NOPR regarding the impact of standards on manufacturers 

were discussed in the preceding sections. DOE did not conduct interviews with 

manufacturers between the publication of the NOPR and this final rule. 

J. Employment Impact Analysis

DOE considers employment impacts in the domestic economy as one factor in 

selecting a standard. Employment impacts consist of direct and indirect impacts. Direct 

employment impacts are any changes in the number of employees working for 

204 
manufacturers of the equipment subject to standards, their suppliers, and related service 

firms. The MIA addresses those impacts. Indirect employment impacts from standards 

consist of the net jobs created or eliminated in the national economy, other than the 

manufacturing sector being regulated, caused by: (1) reduced spending by end users on 

energy; (2) reduced spending on new energy supplies by the utility industry; (3) increased 

spending on new equipment to which the new standards apply; and (4) the effects of 

those three factors throughout the economy.

One method for assessing the possible effects of such shifts in economic activity 

on the demand for labor is to compare sector employment statistics developed by the 

Labor Department’s Bureau of Labor Statistics (BLS).48 The BLS regularly publishes its 

estimates of the number of jobs per million dollars of economic activity in different 

sectors of the economy, as well as the jobs created elsewhere in the economy by this 

same economic activity. Data from the BLS indicate that expenditures in the utility sector 

generally create fewer jobs (both directly and indirectly) than expenditures in other 

sectors of the economy.49 There are many reasons for these differences, including wage 

differences and the fact that the utility sector is more capital-intensive and less laborintensive than other sectors. Energy conservation standards have the effect of reducing 

customer utility bills. Because reduced customer expenditures for energy likely lead to 

increased expenditures in other sectors of the economy, the general effect of efficiency 

48 Data on industry employment, hours, labor compensation, value of production, and the implicit price 

deflator for output for these industries are available upon request by calling the Division of Industry 

Productivity Studies (202-691-5618) or by sending a request by e-mail to dipsweb@bls.gov. Available at:

www.bls.gov/news.release/prin1.nr0.htm. (Last accessed October 2013.) 49 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional InputOutput Modeling System (RIMS II), Washington, DC., U.S. Department of Commerce, 1992.

205 

 
standards is to shift economic activity from a less labor-intensive sector (i.e., the utility 

sector) to more labor-intensive sectors (e.g., the retail and manufacturing sectors). Thus, 

based on the BLS data alone, DOE believes that net national employment will increase 

due to shifts in economic activity resulting from new and amended standards for metal 

halide lamp fixtures.

For the standard levels considered in today’s final rule, DOE estimated indirect 

national employment impacts using an input/output model of the U.S. economy called 

Impact of Sector Energy Technologies (ImSET), version 3.1.1.50 ImSET is a specialpurpose version of the “U.S. Benchmark National Input-Output” (I–O) model, which was 

designed to estimate the national employment and income effects of energy-saving 

technologies. The ImSET software includes a computer-based I–O model having 

structural coefficients that characterize economic flows among 187 sectors most relevant 

to industrial, commercial, and residential building energy use.

DOE received several general comments at the NOPR public meeting questioning 

the validity of its employment analysis results. (Acuity, Public Meeting Transcript, No. 

48 at p. 306; EEI, Public Meeting Transcript, No. 48 at pp. 298–301; GE, Public Meeting 

Transcript, No. 48 at p. 306; NEEA, Public Meeting Transcript, No. 48 at pp. 304–305; 

NEMA, Public Meeting Transcript, No. 48 at p. 302) DOE notes that ImSET is not a 

general equilibrium projection model and understands the uncertainties involved in 

50 Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies (PNNL18412 Pacific Northwest National Laboratory) (2009). Available at 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf. (Last accessed October 

2013.)

206 

 
projecting employment impacts, especially changes in the later years of the analysis. 

Because ImSET does not incorporate price changes, the employment effects predicted by 

ImSET may overestimate actual job impacts over the long run for this rule. Because 

ImSET predicts small job impacts resulting from this rule, regardless of these 

uncertainties, the actual job impacts are likely to be negligible in the overall economy. 

DOE may consider the use of other modeling approaches for examining long-term 

employment impacts. DOE also notes that the indirect employment impacts estimated 

with ImSET for the entire economy differ from the direct employment impacts in the 

lighting manufacturing sector estimated using the GRIM in the MIA, as described at the 

beginning of this section. The methodologies used and the sectors analyzed in the ImSET 

and GRIM models are different. 

For more details on the employment impact analysis, see chapter 14 of the final 

rule TSD.

K. Utility Impact Analysis

The utility impact analysis estimates several important effects on the utility 

industry of the adoption of new or amended standards. For this analysis, DOE used the 

NEMS-BT model to generate forecasts of electricity consumption, electricity generation 

by plant type, and electric generating capacity by plant type, that would result from each 

considered TSL. DOE obtained the energy savings inputs associated with efficiency 

improvements to considered equipment from the NIA. DOE conducts the utility impact 

analysis as a scenario that departs from the latest AEO Reference Case. For the August 

2013 NOPR analysis, the estimated impacts of standards were the differences between 

207 
values forecasted by NEMS-BT and the values in the AEO2013 Reference Case. 78 FR 

51464, 51512 (Aug. 20, 2013). DOE received no comments related to its utility impact 

analysis and retained its approach for this final rule. Chapter 15 of the final rule TSD 

describes the utility impact analysis.

L. Emissions Analysis

In the emissions analysis, DOE estimated the reduction in power sector emissions 

of CO2, NOx, SO2, and Hg from potential energy conservation standards for metal halide 

lamp fixtures. In addition to estimating impacts of standards on power sector emissions, 

DOE estimated emissions impacts in production activities that provide the energy inputs 

to power plants. These are referred to as “upstream” emissions. In accordance with the 

FFC Statement of Policy (76 FR 51281 [August 18, 2011]), as amended at 77 FR 49701 

(Aug. 17, 2012), this FFC analysis includes impacts on emissions of methane (CH4) and 

nitrous oxide (N2O), both of which are recognized as greenhouse gases. 

DOE primarily conducted the emissions analysis using emissions factors for CO2

and most of the other gases derived from data in AEO2013. Combustion emissions of 

CH4 and N2O were estimated using emissions intensity factors published by the 

Environmental Protection Agency (EPA), GHG Emissions Factors Hub.51 Site emissions 

of CO2 and NOX were estimated using emissions intensity factors from an EPA 

51 See www.epa.gov/climateleadership/guidance/ghg-emissions.html. 

208 

 
publication.52 DOE developed separate emissions factors for power sector emissions and 

upstream emissions. The method that DOE used to derive emissions factors is described 

in chapter 16 of the final rule TSD.

For CH4 and N2O, DOE calculated emissions reduction in tons and also in terms 

of units of carbon dioxide equivalent (CO2eq). Gases are converted to CO2eq by 

multiplying the physical units by the gas' global warming potential (GWP) over a 100-

year time horizon. Based on the Fourth Assessment Report of the Intergovernmental 

Panel on Climate Change,53 DOE used GWP values of 25 for CH4 and 298 for N2O.

EIA prepares the Annual Energy Outlook using NEMS. Each annual version of 

NEMS incorporates the projected impacts of existing air quality regulations on emissions. 

AEO2013 generally represents current legislation and environmental regulations, 

including recent government actions, for which implementing regulations were available 

as of December 31, 2012.

SO2 emissions from affected electricity-generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act 

52 U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, AP-42, Fifth 

Edition, Volume I: Stationary Point and Area Sources. 1998. www.epa.gov/ttn/chief/ap42/index.html 53 Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. 

Lowe, G. Myhre, J. Nganga, R. Prinn,G. Raga, M. Schulz and R. Van Dorland. 2007: Changes in 

Atmospheric Constituents and in Radiative Forcing. In Climate Change 2007: The Physical Science Basis. 

Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on 

Climate Change. S. Solomon, D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. 

Miller, Editors. 2007. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 

p. 212.

209 

 
sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous states and 

the District of Columbia (D.C.). SO2 emissions from 28 eastern states and D.C. were also 

limited under the Clean Air Interstate Rule (CAIR; 70 FR 25162 [May 12, 2005]), which 

created an allowance-based trading program. CAIR was remanded to the EPA by the U.S. 

Court of Appeals for the District of Columbia Circuit, but it remained in effect. See North 

Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 

(D.C. Cir. 2008). On July 6, 2011 EPA issued a replacement for CAIR, the Cross-State 

Air Pollution Rule (CSAPR). 76 FR 48208 (Aug. 8, 2011). On August 21, 2012, the D.C. 

Circuit issued a decision to vacate CSAPR. See EME Homer City Generation, LP v. 

EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). The court ordered EPA to continue administering 

CAIR. The AEO2013 emissions factors used for today’s NOPR assume that CAIR 

remains a binding regulation through 2040.

The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Under existing 

EPA regulations, any excess SO2 emissions allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to 

permit offsetting increases in SO2 emissions by any regulated EGU. In past rulemakings, 

DOE recognized that there was uncertainty about the effects of efficiency standards on 

SO2 emissions covered by the existing cap-and-trade system, but it concluded that 

negligible reductions in power sector SO2 emissions would occur as a result of standards.

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury 

and Air Toxics Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012). In the 

210 
final MATS rule, EPA established a standard for hydrogen chloride as a surrogate for 

acid gas hazardous air pollutants (HAP), and also established a standard for SO2 (a nonHAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The 

same controls are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will 

be reduced as a result of the control technologies installed on coal-fired power plants to 

comply with the MATS requirements for acid gas. AEO2013 assumes that, in order to 

continue operating, coal plants must have either flue gas desulfurization or dry sorbent 

injection systems installed by 2015. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in 

SO2 emissions when electricity demand decreases (e.g., as a result of energy efficiency 

standards). Emissions will be far below the cap that would be established by CAIR, so it 

is unlikely that excess SO2 emissions allowances resulting from the lower electricity 

demand would be needed or used to permit offsetting increases in SO2 emissions by any 

regulated EGU. Therefore, DOE believes that efficiency standards will reduce SO2

emissions in 2015 and beyond.

CAIR established a cap on NOx emissions in 28 eastern states and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOx

emissions in those states covered by CAIR because excess NOx emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases 

in NOx emissions. However, standards would be expected to reduce NOx emissions in the 

states not affected by the caps, so DOE estimated NOx emissions reductions from the 

standards considered in today’s final rule for these states.

211 
The MATS limit mercury emissions from power plants, but they do not include 

emissions caps and, as such, DOE’s energy conservation standards would likely reduce 

Hg emissions. DOE estimated mercury emissions reduction using NEMS-BT based on 

AEO2013, which incorporates the MATS. 

DOE received comments regarding the emissions analysis during the NOPR 

public meeting. EEI noted that the EPA recently proposed greenhouse gas emissions 

standards for new EGUs54 and would issue standards for existing EGUs in 2014. EEI 

commented that these standards would have a significant effect on DOE’s emission 

analysis and that they should be considered in the final rule. (EEI, Public Meeting 

Transcript, No. 48 at pp. 307–309) In a joint comment, the U.S. Chamber of Commerce 

and cosignatories55 (hereafter the “U.S. Chamber et al.”) agreed. (U.S. Chamber et al., 

No. 58 at p. 7) As discussed previously in this section, the AEO2013 emissions factors 

available for this final rule analysis reflect regulations implemented as of December 31, 

2012, and DOE cannot consider proposed emission standards in setting potential 

equipment efficiency standards.56 GE encouraged DOE to consider the additional 

emissions produced in manufacturing the larger fixtures needed to meet potential 

efficiency standards, and GE indicated that NEMA intended to evaluate the “carbon 

54 Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility 

Generating Units – Proposed Rule (September 20, 2013); pre-publication version at 

www2.epa.gov/sites/production/files/2013-09/documents/20130920proposal.pdf (Last accessed November 

22, 2013).

55 Cosignatories include the American Forest & Paper Association, American Fuel & Petrochemical 

Manufacturers, American Petroleum Institute, Council of Industrial Boiler Owners, National Association of 

Manufacturers, National Mining Association, and the Portland Cement Association.

56 APPA commented that EPA new source performance standards are effective upon issuance of the 

proposed rule. (APPA, Public Meeting Transcript, No. 48 at p. 310) DOE disagrees, citing section III.B of 

the proposed rule that states the emission limit would apply to affected sources on the effective date of the 

final action.

212 

 
footprint” of its manufacturing processes. (GE, Public Meeting Transcript, No. 48 at pp. 

311–312) DOE received no related emissions estimates in written comments; further, as 

discussed previously in section V.C of this final rule, DOE’s engineering analysis 

indicated that higher efficiency fixtures would not be significantly larger than baseline 

fixtures. DOE believes that any incremental emissions increases from the manufacture of 

higher efficiency fixtures would be negligible in comparison to its overall emissions 

estimates, and DOE retained its AEO-based approach for this final rule emissions 

analysis.

M. Monetizing Carbon Dioxide and Other Emissions Impacts

As part of the development of this final rule, DOE considered the estimated 

monetary benefits likely to result from the reduced emissions of CO2 and NOX that are 

expected to result from each of the TSLs considered. In order to make this calculation, 

similar to the calculation of the NPV of customer benefit, DOE considered the reduced 

emissions expected to result over the lifetime of equipment shipped in the projection 

period for each TSL. This section summarizes the basis for the monetary values used for 

each of these emissions and presents the values considered in this rulemaking.

For today’s final rule, DOE is relying on a set of values for the SCC that was 

developed by an interagency process. A summary of the basis for these values is provided 

in the following section, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 17 of the final rule TSD.

213 
1. Social Cost of Carbon

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of CO2. A domestic SCC value is meant to reflect the 

value of damages in the United States resulting from a unit change in CO2 emissions, 

while a global SCC value is meant to reflect the value of damages worldwide.

Under section 1(b) of E.O. 12866, agencies must, to the extent permitted by law, 

“assess both the costs and the benefits of the intended regulation and, recognizing that 

some costs and benefits are difficult to quantify, propose or adopt a regulation only upon 

a reasoned determination that the benefits of the intended regulation justify its costs.” The 

purpose of the SCC estimates presented here is to allow agencies to incorporate the 

monetized social benefits of reducing CO2 emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed these SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

214 
using a defensible set of input assumptions grounded in the existing scientific and 

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

When attempting to assess the incremental economic impacts of CO2 emissions, 

the analyst faces a number of serious challenges. A recent report from the National 

Research Council57 points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about (1) future emissions of GHGs, (2) the effects 

of past and future emissions on the climate system, (3) the impact of changes in climate 

on the physical and biological environment, and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and 

monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics and should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing CO2 emissions. Most Federal 

regulatory actions can be expected to have marginal impacts on global emissions. For 

such policies, the agency can estimate the benefits from reduced emissions in any future 

year by multiplying the change in emissions in that year by the SCC value appropriate for 

that year. The net present value of the benefits can then be calculated by multiplying each 

57 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press: Washington, DC (2009).

215 

 
of these future benefits by an appropriate discount factor and summing across all affected 

years. This approach assumes that the marginal damages from increased emissions are 

constant for small departures from the baseline emissions path, an approximation that is 

reasonable for policies that have effects on emissions that are small relative to cumulative 

global CO2 emissions. For policies that have a large (non-marginal) impact on global 

cumulative emissions, there is a separate question of whether the SCC is an appropriate 

tool for calculating the benefits of reduced emissions. This concern is not applicable to 

this notice, however.

It is important to emphasize that the interagency process is committed to updating 

these estimates as the science and economic understanding of climate change and its 

impacts on society improves over time. In the meantime, the interagency group will 

continue to explore the issues raised by this analysis and consider public comments as 

part of the ongoing interagency process.

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

Economic analyses for Federal regulations used a wide range of values to estimate 

the benefits associated with reducing CO2 emissions. The model year 2011 Corporate 

Average Fuel Economy final rule used both a “domestic” SCC value of $2 per metric ton 

of CO2 and a “global” SCC value of $33 per metric ton of CO2 for 2007 emission 

reductions (in 2007$), increasing both values at 2.4 percent per year. It also included a 

216 
sensitivity analysis at $80 per metric ton of CO2.

58 The proposed rule for Model Years 

2011–2015 assumed a domestic SCC value of $7 per metric ton of CO2 (in 2006$) for 

2011 emission reductions (with a range of $0−$14 for sensitivity analysis), also 

increasing at 2.4 percent per year.59 A regulation for packaged terminal air conditioners 

and packaged terminal heat pumps finalized by DOE in 2008 used a domestic SCC range 

of $0 to $20 per metric ton CO2 for 2007 emission reductions (in 2007$). 73 FR 58772, 

58814 (Oct. 7, 2008) In addition, EPA’s 2008 Advance Notice of Proposed Rulemaking 

on Regulating Greenhouse Gas Emissions Under the Clean Air Act identified what it 

described as “very preliminary” SCC estimates subject to revision. 73 FR 44354 (July 30, 

2008). EPA’s global mean values were $68 and $40 per metric ton CO2 for discount rates 

of approximately 2 percent and 3 percent, respectively (in 2006$ for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing CO2emissions. To ensure consistency in 

how benefits are evaluated across agencies, the Administration sought to develop a 

transparent and defensible method, specifically designed for the rulemaking process, to 

quantify avoided climate change damages from reduced CO2 emissions. The interagency 

group did not undertake any original analysis. Instead, it combined SCC estimates from 

the existing literature to use as interim values until a more comprehensive analysis could 

58 See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 

(March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

www.nhtsa.gov/fuel-economy). 59 See Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 

FR 24352 (May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) 

(Available at: www.nhtsa.gov/fuel-economy).

217 

 
be conducted. The outcome of the preliminary assessment by the interagency group was a 

set of five interim values: global SCC estimates for 2007 (in 2006$) of $55, $33, $19, 

$10, and $5 per ton of CO2. These interim values represent the first sustained interagency 

effort within the U.S. government to develop an SCC for use in regulatory analysis. The 

results of this preliminary effort were presented in several proposed and final rules.

c. Current Approach and Key Assumptions

Since the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates. The group considered public 

comments and further explored the technical literature in relevant fields. The interagency 

group relied on three integrated assessment models commonly used to estimate the SCC: 

the FUND, DICE, and PAGE models. These models are frequently cited in the peerreviewed literature and were used in the last assessment of the Intergovernmental Panel 

on Climate Change. Each model was given equal weight in the SCC values that were 

developed. 

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socioeconomic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

218 
socioeconomic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

The interagency group selected four sets of SCC values for use in regulatory 

analyses. Three values were based on the average SCC from three integrated assessment 

models, at discount rates of 2.5, 3, and 5 percent. The fourth value, which represents the 

95th percentile SCC estimate across all three models at a 3-percent discount rate, were 

included to represent higher-than-expected impacts from temperature change further out 

in the tails of the SCC distribution. The values estimated for 2010 grow in real terms over 

time. Additionally, the interagency group determined that a range of values from 7 

percent to 23 percent should be used to adjust the global SCC to calculate domestic 

effects, although preference is given to consideration of the global benefits of reducing 

CO2 emissions. Table V.10 presents the values in the 2010 interagency group report,60

which is reproduced in appendix 17A of the final rule TSD.

60 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government, 2010.

219 

 
Table V.10 Annual SCC Values from 2010 Interagency Report, 2010–2050 (in 2007 

dollars per metric ton CO2) 

Discount Rate

5%

Avg.

3%

Avg.

2.5%

Avg.

3%

95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used for today’s notice were generated using the most recent 

versions of the three integrated assessment models that have been published in the peerreviewed literature.61 Table V.11 shows the updated sets of SCC estimates in five-year 

increments from 2010 to 2050. The full set of annual SCC estimates between 2010 and 

2050 is reported in appendix 17B of the final rule TSD. The central value that emerges is 

the average SCC across models at the 3 percent discount rate. However, for purposes of 

capturing the uncertainties involved in regulatory impact analysis, the interagency group 

emphasized the importance of including all four sets of SCC values.

61 Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency Working Group on Social Cost of Carbon, United 

States Government, May 2013 (Revised November 2013). 

www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf.

220 

 
Table V.11 Annual SCC Values from 2013 Interagency Update, 2010–2050 (in 2007 

dollars per metric ton CO2) 

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 32 51 89

2015 11 37 57 109

2020 12 43 64 128

2025 14 47 69 143

2030 16 52 75 159

2035 19 56 80 175

2040 21 61 86 191

2045 24 66 92 206

2050 26 71 97 220

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of CO2

emissions and the limits of existing efforts to model these effects. There are a number of 

concerns and problems should be addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC. The interagency group intends to periodically 

review and reconsider those estimates to reflect increasing knowledge of the science and 

economics of climate impacts, as well as improvements in modeling.

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the values from the 2013 interagency report , adjusted to 

221 
2012$ using the Gross Domestic Product price deflator. For each of the four cases 

specified, the values used for emissions in 2015 were $11.8, $39.7, $61.2, and $117 per 

metric ton avoided (values expressed in 2012$).62 DOE derived values after 2050 using 

the growth rate for the 2040–2050 period in the interagency update.

DOE multiplied the CO2 emissions reduction estimated for each year by the SCC 

value for that year in each of the four cases. To calculate a present value of the stream of 

monetary values, DOE discounted the values in each of the four cases using the specific 

discount rate that had been used to obtain the SCC values in each case.

In responding to the MHLF NOPR, many commenters questioned the scientific 

and economic basis of the SCC values. These commenters made extensive comments 

about: the alleged lack of economic theory underlying the models; the sufficiency of the 

models for policy-making; potential flaws in the models’ inputs and assumptions 

(including the discount rates and climate sensitivity chosen); whether there was adequate 

peer review of the three models; whether there was adequate peer review of the TSD 

supporting the 2013 SCC values; whether the SCC estimates comply with OMB’s “Final 

Information Quality Bulletin for Peer Review”63 and DOE’s own guidelines for ensuring 

and maximizing the quality, objectivity, utility and integrity of information disseminated 

by DOE; whether DOE’s use of the updated SCC values has precedential effect for other 

agency rulemakings; and why DOE is considering global benefits of carbon dioxide 

62 The interagency report presents SCC values through 2050. DOE derived values after 2050 using the 3-

percent per year escalation rate used by the interagency group. 63 Available at: http://www.cio.noaa.gov/services_programs/pdfs/OMB_Peer_Review_Bulletin_m05-

03.pdf

222 

 
emission reductions rather than solely domestic benefits. (Mercatus Center, No. 57 at pp. 

1-6; NEMA, No. 56 at pp. 25-31, U.S. Chamber et al., No.58 at pp. 4-8) 

On November 26, 2013, the Office of Management and Budget (OMB) 

announced minor technical corrections to the 2013 SCC values and a new opportunity for 

public comment on the revised TSD underlying the SCC estimates. Comments regarding 

the underlying science and potential precedential effect of the SCC estimates resulting 

from the interagency process should be directed to that process. See 78 FR 70586. 

Additionally, several current rulemakings also use the 2013 SCC values and the public is 

welcome to comment on the values as applied in those rulemakings just as the public was 

welcome to comment on the use and application of the 2010 SCC values in the many 

rules that were published using those values in the past three years. 

The U.S. Chamber et al. also stated that DOE calculates the present value of the 

costs of the NOPR to customers and manufacturers over a 30-year period. The SCC 

values, on the other hand, reflect the present value of future climate related impacts well 

beyond 2100. According to the U.S. Chamber et al., DOE’s comparison of 30 years of 

cost to hundreds of years of presumed future benefits is inconsistent and improper. (U.S. 

Chamber et al., No.58 at pp. 5-6)

For the analysis of national impacts of the adopted standards, DOE considered the 

lifetime impacts of fixtures shipped in a 30-year period. With respect to energy and 

energy cost savings, impacts continue past 30 years until all of the fixtures shipped in the 

30-year period are retired. With respect to the valuation of CO2 emissions reductions, 

223 
DOE considers the avoided emissions over the same period as the energy savings. CO2

emissions have on average a very long residence time in the atmosphere. Thus, emissions 

in the period considered by DOE would contribute to global climate change over a very 

long time period, with associated social costs. The SCC for any given year represents the 

discounted present value, in that year and expressed in constant dollars, of a lengthy 

stream of future costs estimated to result from emission of a ton of CO2. It is worth 

pointing out that because of discounting, the present value of costs in the distant future is 

very small. DOE’s accounting of energy cost savings and the value of avoided CO2

emissions reductions is consistent: both consider the complete impacts associated with 

products shipped in the 30-year period.

2. Valuation of Other Emissions Reductions

DOE investigated the potential monetary benefit of reduced NOx emissions from 

the TSLs it considered. As noted in section V.L, DOE has taken into account how new 

energy conservation standards would reduce NOx emissions in those 28 states that are not 

affected by emissions caps. DOE estimated the monetized value of NOx emissions 

reductions resulting from each of the TSLs considered for today’s final rule based on 

estimates found in the relevant scientific literature. Estimates of monetary value for 

reducing NOx from stationary sources range from $468 to $4,809 per ton (in 2012$).64

DOE calculated the monetary benefits using a medium value for NOx emissions of $2,639 

per short ton (in 2012$) and real discount rates of 3 percent and 7 percent. 

64 U.S. Office of Management and Budget, Office of Information and Regulatory Affairs, 2006 Report to 

Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and 

Tribal Entities, Washington, DC.

224 

 
DOE is evaluating appropriate monetization of avoided SO2 and Hg emissions in 

energy conservation standards rulemakings. It has not included monetization in the 

current analysis.

VI. Other Issues for Discussion

A. Proposed Standard Levels in August 2013 NOPR 

In the NOPR, DOE proposed new and revised energy conservation standards for 

all equipment classes. Specifically, DOE proposed TSL 3, which comprised EL2 for all 

equipment classes except the 100 W – 150 W indoor and outdoor equipment classes, for 

which DOE proposed EL4. DOE received comment from several interested parties 

regarding these proposals.

ULT noted the proposal that 150 W MHLFs exempted by EISA 2007 (fixtures 

designed for use in high temperature and wet environments) were subject to EL4, while 

150 W MHLFs not exempted by EISA 2007 were only subject to EL2. ULT questioned 

why the NOPR proposed lower efficiencies for fixtures that operate in less severe 

conditions. (ULT, No. 50 at p. 2) As discussed previously in section V.A.2 of this notice, 

the EISA 2007 exemption for certain 150 W MHLFs led to a difference in the 

commercially available efficiencies in MH ballasts that are exempt or are not exempt 

from EISA 2007. As a result, DOE proposed that 150 W MHLFs previously exempt by 

EISA 2007 be included in the 101 W – 150 W range, while 150 W MHLFs subject to 

EISA 2007 standards continue to be included in the 150 W – 250 W range. For the 101 

225 
W – 150 W MHLFs, DOE found that EL4, the max-tech level, was economically 

justified. However, for the 150 W – 250 W MHLFs, DOE found that the maximum EL 

achievable with positive NPV was the magnetic ballast max-tech level, EL2 at 88.0 

percent. Therefore, in the NOPR, the economic results for the nation supported a higher 

standard for MHLFs included in the 101 W – 150 W range. 

ULT commented that NOPR TSL 3 requires a shift to electronic ballasts, which 

will not work very well in outdoor applications. Further, ULT noted that the NOPR TSLs 

all appeared to be modeled or mandated without regard to the application, and seemed 

not to make practical sense. (ULT, Public Meeting Transcript, No. 48 at p. 215). NEMA 

and ULT commented that NOPR TSL 3 would require a shift to electronic ballasts in 70 

W, 150 W, and 250 W fixtures, ban probe-start ballasts, and eliminate many of the 

magnetic ballast performance features, as these are not feasible in the mandated 

electronic HF ballasts. (NEMA, No. 56 at p. 24; ULT, No. 50 at p. 16). ULT commented 

that there should be some way to validate the TSLs. ULT suggested that DOE should 

build these models, and then allow the manufacturers to test them. They explained that 

results are much different in a lab environment with more resources and time than in 

manufacturing facilities that make hundreds of ballasts every 15 minutes. In situations 

with many variable materials, modeled and laboratory efficiencies differ greatly from 

those feasibly possible in a manufacturing facility. (ULT, Public Meeting Transcript, No. 

48 at pp. 216, 218) ULT stated that overall the NOPR TSLs are too stringent, and 

proposed different standards. (ULT, No. 50 at p. 16)

226 
DOE acknowledges that standards proposed for 100 W – 150 W MHLFs in the 

NOPR would require a shift to electronic ballasts. While DOE recognizes that magnetic 

ballasts are inherently more robust than electronic ballasts, the NOPR accounted for the 

cost of added protection to electronic ballasts in outdoor applications. DOE continues to 

use this methodology in this final rule. For details of the determination that electronic 

ballasts could be used in these same applications with certain cost adders, see section 

V.C.8.b. For details of the cost adders required by electronic ballasts being used in the 

same application as magnetic ballasts, see section V.C.12. 

DOE has modeled ballasts in both the NOPR and final rule, utilizing teardown 

data and manufacturer input. Further research and refinement was performed for the 

modeled ballasts for this final rule in response to comments. See section V.C.8 for 

discussion of these models. DOE has not included high-frequency electronic ballasts in 

the scope of this rulemaking because there is no test method for them. See section III.A.4

for more details. As a result, none of the ELs analyzed in this final rule require highfrequency electronic ballasts. A more detailed discussion of the TSLs newly analyzed and 

chosen in this final rule is available later in this section.

ASAP urged DOE to adopt the maximum cost-effective ELs. (ASAP, Public 

Meeting Transcript, No. 48 at p. 17) DOE analyzed several combinations of ELs in the 

NOPR and in the final rule. These combinations of ELs, called TSLs, can represent many 

criteria, including maximum energy savings, technology descriptions (such as all maxtech magnetic ELs), or maximum energy savings with cost effective ELs. As discussed in 

section VII.C of this notice, DOE adopted the TSL that saved the most energy and was 

227 
economically justified for customers, manufactures, and the nation based on a weighing 

of costs and benefits. 

ULT commented that NOPR TSL 3 did not meet the requirement of a three-year 

PBP, but instead PBPs seemed to range from 4 to 14 years (ULT, No. 50 at p. 15). DOE 

does not have a specific minimum PBP requirement. Each equipment class is analyzed 

individually based on the market and economic analyses and the cost and benefits of all 

results are weighted. See section VII.B.1.a for discussions of the PBPs associated with 

the levels analyzed in this final rule.

NEMA commented that it is very difficult to determine the final net benefit of 

TSL 3 from NOPR Tables VI.47 and VI.48, and DOE has not aided the reader in 

understanding its conclusion. (NEMA, No. 56 at p. 25). NEMA commented that DOE 

appropriately considered a range of values for carbon emissions reductions, but noted that 

these values are only informative and should not be used for regulatory decision-making. 

(NEMA, No. 56 at p. 26). 

In this final rule, DOE analyzed the benefits and burdens of a number of TSLs for 

the metal halide lamp fixtures that are the subject of today’s final rule. In accordance with 

(42 U.S.C. 6295(o)(2)(B)(i)), DOE must weigh the cost and benefits of seven factors, 

including other factors the Secretary considers relevant. DOE continues to present and 

consider a range of carbon emission reduction values in its weighing of the costs and 

benefits of any adopted standard. Regarding presentation of a final net benefit value, 

DOE directs NEMA to Table I.4. 

228 
The Joint Comment suggested that DOE evaluate an additional TSL, identical to 

NOPR TSL 5 except that efficiency levels for 250 – 500 W ballasts would be based on 

EL3, which represents low-frequency electronic ballasts. (Joint Comment, No. 62 at p. 5). 

As discussed in section III.A.4, DOE is no longer considering standards that require use 

of high-frequency electronic ballasts because they are not in the scope of this rulemaking. 

Therefore, the max-tech levels for 50 W – 1000 W fixtures are all represented by lowfrequency ballasts, removing the need for the additional TSL suggested by the Joint 

Comment.

B. Reported Value 

The sampling and reporting for the testing of MHLFs and, by extension, MH 

ballasts are provided for in 10 CFR 429.54. The reported value for the tested ballast 

efficiency of a model must be less than or equal to the lower of the mean of the samples 

tested or the lower 99 percent confidence limit (LCL) of the true mean divided by 0.99.

CA IOUs supported DOE’s proposal to apply a confidence interval, which is 

consistent with the approach used for other products and accounts for variation in product 

testing and manufacturing. (CA IOUs, No. 54 at p. 3). Some stakeholders commented 

that because of the variation present in MHLFs, standard levels should be rounded to the 

nearest whole number rather than tenth of a percent (i.e., 88 percent rather than 88.0 

percent). ULT and NEMA noted the variations in wire cross sections (up to 3 percent) 

and core lamination thickness (up to 10 percent) create efficiency losses in the ballasts. 

The combination of efficiency losses in these two areas and variability in manufacturing 

229 
combined with the 99 percent confidence factor, makes the precise proposed levels 

unachievable in full-scale manufacturing facilities. (ULT, Public Meeting Transcript, No. 

48 at pp. 34, 90; NEMA, Public Meeting Transcript, No. 48 at p. 34; NEMA, No. 44 at 

pp. 10, 13; ULT, No. 50 at pp. 3-4, 25-29). Further, NEMA noted that its white paper 

NEMA LSD-63-2012 on variability estimated the tolerance for a sample of four magnetic 

ballasts to be 4.7 percent when a confidence factor of 99 percent is required. (NEMA, 

No. 56 at p. 8) Due to the variability of raw material properties resulting in varied 

efficiencies, NEMA, Musco Lighting, and ULT suggested a less precise designation of 

the efficiency threshold. NEMA and ULT suggested carrying out all calculations to the 

tenth of a decimal place, with the result then rounded to the nearest integer using the 

round half up rule. Musco Lighting agreed, suggesting reporting ballast efficiency as a 

whole integer. (NEMA, No. 56 at p. 8; Musco Lighting, No. 55 at p. 4; ULT, No. 50 at 

pp. 3, 4, 25; ULT, Public Meeting Transcript, No. 48 at p. 38). NEMA also commented 

that it would be better to have less precise standards initially, so that tolerances would not 

have to be created when verification and enforcement actions are made by DOE. 

(NEMA, Public Meeting Transcript, No. 48 at p. 82) 

ULT and NEMA noted that certain ballasts they manufacture, which are currently 

compliant with EISA 2007, would not meet the same requirements under the proposed 

rounding system (to the nearest tenth of a percent). (ULT, No. 50 at pp. 3-4; ULT, No. 50 

at p. 25; ULT, Public Meeting Transcript, No. 48 at p. 38; NEMA, No. 44 at p. 14). 

Earthjustice asserted that current equipment that would not meet standards with the new 

rounding regulations should not be grandfathered in under the new statute. (Earthjustice, 

Public Meeting Transcript, No. 48 at p. 86). 

230 
As discussed in section IV.A of this notice, DOE has determined that the 

calculation of ballast efficiency is possible to the a tenth of a percent. In addition to 

information available in industry standards, data submitted by manufacturers has 

substantiated this conclusion in that it is represented to the tenth of a percent for some 

ballasts and fixtures in DOE’s CCE database. DOE will establish energy conservation 

standards using the same number of significant figures (three) as the test procedure 

provides. Test data collected in support of the energy conservation standard was 

conducted in accordance with the test procedure in 10 CFR 431.324. The certification 

requirements of 10 CFR 429.54 includes sampling plans that are designed to create 

conservative ratings, which ensures that customers get—at a minimum—the efficiency 

indicated by the certified rating. Therefore, DOE’s analysis considers levels of efficiency 

achievable given current manufacturing and material variability. Thus, standards are 

established and compliance with the standards determined by rounding the reported value 

to three significant figures. For 150 W – 200 W fixtures that will be subject to a standard 

of 88.0 percent, DOE has accounted for redesign and retesting costs in the MIA by 

estimating that all MH ballasts at the baseline efficiency level for this wattage range will 

need to be redesigned if higher efficiency standards are adopted. DOE includes the 

redesign, retesting, and recertification costs as part of conversion costs of the MIA (see 

section V.I.4 of this notice for a complete description of the conversion costs used in the 

MIA).

231 
C. Three-Year Compliance Date

In the NOPR, DOE noted that EPCA, as amended by EISA 2007, contains 

guidelines for the compliance date of the standards adopted by this rulemaking. EPCA 

required DOE to determine whether to amend the standards in effect for metal halide 

lamp fixtures and whether any amended standards should apply to additional metal halide 

lamp fixtures. The Secretary was 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, with any amendment applicable to 

products manufactured after January 1, 2015. (42 U.S.C. 6295(hh)(2)(B)) In the NOPR 

public meeting, DOE presented the planned publication date of the final rule to be in 

January 2014 and proposed a compliance date of January 1, 2015.

Several stakeholders commented on DOE’s plan to publish a final rule in January 

2014. APPA noted that the compliance date proposed in the NOPR is unreasonable from 

a process standpoint. DOE would have three months between the end of the NOPR 

comment period to the publication of the final rule, which is a much faster turnaround 

than previous rules. (APPA, No. 51 at p. 3) EEI also clarified that based on a January 

2014 publication, DOE is only giving itself three months between receiving comments 

and issuing a final rule. (EEI, Public Meeting Transcript, No. 48 at p. 44) Musco Lighting 

commented that issuing the final rule in January 2014 would not provide sufficient time 

to appropriately review comments and modify analyses. (Musco Lighting, No. 55 at p. 4) 

APPA commented that it is important to consider how long the review processes of the 

Office of Management and Budget have taken in previous rulemakings. (APPA, No. 51 at 

p. 3) 

232 
DOE has had sufficient time for this particular rulemaking to consider and 

develop responses to the comments received on the NOPR and complete the final rule 

analyses.

DOE received several comments regarding the proposed amount of time between 

the publication of the final rule and the date manufacturers are required to comply with 

any amended standards. APPA and EEI commented that, according to workshop 

handouts and based on language in EISA 2007, DOE plans to issue a final rule in January 

2014 with an effective date of January 1, 2015. (APPA, No. 51 at p. 3; EEI, No. 53 at p. 

2, 3) Considering this, APPA and Musco Lighting found that manufacturers could 

possibly be given less than 11 months to comply with the new final rule. (APPA, No. 51 

at p. 3; Musco Lighting, No. 55 at p. 4) NEMA, ASAP, and NRCA noted that, while the 

2015 date was stipulated by 42 U.S.C. 6295(hh)(2), this was assuming the final rule 

would be completed by January 1, 2012 and the intent of EISA 2007 was to provide 

manufacturers with a three-year period before compliance to allow for investments and 

manufacturing conversion, as well as allowing customers sufficient time to make any 

necessary changes. NEMA, APPA, and NRCA stated that adopting anything shorter than 

three years is not reasonable. (NEMA, No. 56 at p. 3, 20; NEMA, Public Meeting 

Transcript, No. 48 at p. 21; NEMA, No. 44 at p. 2; APPA, No. 51 at p. 3; NRCA, No. 61 

at p. 1) ASAP agreed that it is not reasonable to provide less than one year for

manufacturers to adjust for compliance, especially considering DOE did not comply with 

the provisions included in EISA 2007 by not issuing a final rule by January 1, 2012. 

(APPA, No. 51 at p. 3) ULT commented that standard practice is three years after final 

233 
rule and APPA urged DOE to provide manufacturers and customers with a three-year 

period between publication of the final rule and the effective date. (ULT, No. 50 at p. 14; 

APPA, No. 51 at p. 3)

Stakeholders provided several reasons to support the need for a three-year interval 

between the publication of the final rule and the date of compliance. NEMA and UL 

noted this standard is much more complex and has a broader scope than the ones 

specified in EISA 2007, and that this standard has implications on both ballast and fixture 

manufacturers. (NEMA, Public Meeting Transcript, No. 48 at p. 19; NEMA, No. 44 at p. 

2; ULT, No. 50 at p. 14) NEMA noted that, with this rulemaking’s expanded scope, 

manufacturers would have to evaluate products not previously covered by EISA 2007, 

determine what products can be redesigned and which need to be eliminated, test new 

and modified ballasts for performance and safety, educate internal staff and customers, 

reevaluate inventory management, reevaluate manufacturing strategies, modify marketing 

materials, and work with suppliers and sellers. All of those logistics are required to take 

place and make January 2015 an unreasonable compliance date, according to NEMA. 

(NEMA, Public Meeting Transcript, No. 48 at pp. 21, 27; NEMA, No. 44 at pp. 2-3, 5) 

NEMA also commented that while the standards specified in EISA 2007 primarily 

impacted industrial and outdoor channels, this rulemaking would impact new channels, 

such as retail consumer products and commercial offices with the lower wattage 

products. (NEMA, Public Meeting Transcript, No. 48 at p. 19; NEMA, No. 44 at p. 2) 

NEMA and Musco Lighting noted that with any increased efficiency numbers 

there are numerous product redesigns required, so it is imperative that DOE provide 

234 
industry with the full three years to bring their products to compliance. (NEMA, No. 56 

at pp. 20-21; Musco Lighting, No. 55 at p. 4) ULT noted the commercial market is far 

from the NOPR proposed levels, so there will need to be time for R&D and to prototype 

potential solutions. ULT commented that typical design time, taking into consideration 

Design Validation Testing, Life Test, UL, and other aspects of the process, is typically 

eight to twelve months. Even if they were moving three projects at once they would not 

be able to fully redesign the necessary products before January 2015, and they would run 

out of raw materials. (ULT, No. 50 at p. 14) NEMA and ULT also commented that DOE 

has to account for fixture manufacturers who would not be able to redesign their products 

until they had samples produced on a commercial scale from the ballast manufacturers. 

(NEMA, Public Meeting Transcript, No. 48 at p. 19; ULT, No. 50 at p. 14) 

NEMA noted that the difficulties with completing all of these redesigns with such 

a short compliance period include having fewer employees working on MHLFs than 

there were in 2007 and having resources focused on R&D for other technologies. Taking 

resources from these areas to complete the necessary redesigns would also divert the 

speed of the market transition to more efficient technologies. (NEMA; No. 44 at p. 2) 

Southern Company also expressed concern that a compliance date of January 1, 2015, 

would force manufacturers to divert resources from the development and implementation 

of energy efficient technologies, such as LED, and this would increase the cost to 

customers and slow the conversion to LED. (Southern Company, No. 64 at p. 3)

The Joint Comment noted that if the compliance date of the rulemaking is three 

years after the final rule is published, the delayed compliance date would decrease the 

235 
potential energy savings from the rulemaking. While the Joint Comment recognizes that 

compliance with standards with a one-year compliance period may not be feasible, the 

Joint Comment urged DOE to attempt to balance additional energy savings from an 

earlier effective date with the impacts on manufacturers. (Joint Comment, No. 62 at p. 

10) 

DOE recognizes that any compliance date subsequent to January 1, 2015, will 

lead to reduced energy savings compared to the NOPR. However, DOE believes that it 

would be difficult for both ballast and fixture manufacturers to redesign their product 

lines given the compliance date proposed in the NOPR. As such, this final rule has 

revised the compliance date to be three years after publication of this final rule. in the 

Federal Register.

VII. Analytical Results

A. Trial Standard Levels

In the following sections, DOE presents the analytical results for the TSLs of the 

equipment classes that DOE analyzed directly. DOE scaled the ELs for these 

representative equipment classes to create ELs for other equipment classes that were not 

directly analyzed as set forth in chapter 5 of the TSD. For more details on the 

representative equipment classes, please see section V.C.2. 

Comment [AGA15]: Change requested by 

OIRA.

236 
Table VII.1 Trial Standard Levels

Rep. Wattage TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

70 W Indoor EL1 EL2 EL2 EL3 EL4

70 W Outdoor EL1 EL2 EL2 EL3 EL4

150 W Indoor EL1 EL2 EL2 EL3 EL4

150 W Outdoor EL1 EL2 EL2 EL3 EL4

250 W Indoor EL1 EL1 EL2 EL3 EL4

250 W Outdoor EL1 EL1 EL2 EL3 EL4

400 W Indoor EL1 EL2 EL2 EL3 EL4

400 W Outdoor EL1 EL2 EL2 EL3 EL4

1000 W Indoor EL2+DS EL2+DS EL2+DS EL2+DS EL2+DS

1000 W Outdoor EL2+DS EL2+DS EL2+DS EL2+DS EL2+DS

1500 W Indoor Baseline Baseline Baseline EL1 EL2

1500 W Outdoor Baseline Baseline Baseline EL1 EL2

*DS is a design standard that bans the use of probe-start ballasts in new metal halide lamp fixtures.

 

TSL 5 represents the max-tech efficiency levels available. TSL 5 would set 

energy conservation standards at EL4 for indoor and outdoor fixtures at 70 W, 150 W, 

250 W, and 400 W. Energy conservation standards for indoor and outdoor fixtures at 

1000 W, and 1500 W are set at EL2. TSL 5 also includes a design standard for indoor and 

outdoor 1000 W fixtures that prohibits the sale of probe-start ballasts in new fixtures. 

Standards included in TSL 5 require fixtures that contain max-tech electronic ballasts 

using high-grade electronic components, while indoor and outdoor fixtures at 1000 and 

1500 W require max-tech magnetic ballasts using high-grade steel and copper windings. 

All ballasts required by TSL 5 are commercially available, except indoor and outdoor 

237 
1000 W and 1500 W ballasts, which are modeled. 65 TSL 5 sets the same standards for 

indoor and outdoor representative equipment classes at the same wattage.

TSL 4 represents the next highest efficiency levels in classes where efficiency 

levels were not justified at TSL 5. TSL 4 would set energy conservation standards at EL3 

for indoor and outdoor fixtures at 70 W, 150 W, 250 W, and 400 W. Energy conservation 

standards for indoor and outdoor fixtures at 1000 W are set at EL2, and standards for 

indoor and outdoor fixtures at 1500 W are set at EL1. TSL 4 also includes a design 

standard for indoor and outdoor 1000 W fixtures that prohibits the sale of probe-start 

ballasts in new fixtures. Standards included in TSL 4 require fixtures that include 

standard-grade electronic ballasts, while indoor and outdoor fixtures at 1000 W require 

max-tech magnetic ballasts using high grade steel and copper windings, and 1500 W 

ballasts are mid-grade magnetic ballasts requiring mid-grade steel and copper wiring. At 

TSL 4, all ballasts are commercially available, with the exception of the 1000 W ballasts, 

which are modeled.65 TSL 4 sets the same standards for indoor and outdoor 

representative equipment classes at the same wattage.

TSL 3 represents the next highest efficiency levels in classes where efficiency 

levels were not justified at TSL 4, while also requiring the same EL for both indoor and 

outdoor fixtures at the same wattage. TSL 3 would set energy conservation standards at 

EL2 for all classes except 1500 W, which would remain at baseline levels. TSL 3 also 

65 The 501 W – 1000 W equipment class requires modeled 1000 W ballasts, but 875 W ballasts are 

commercially available.

238 

 
includes a design standard for indoor and outdoor 1000 W fixtures that prohibits the sale 

of probe-start ballasts in new fixtures. Except for 1500 W fixtures, the standards included 

in TSL 3 require fixtures that include max-tech magnetic ballasts using high-grade steel 

and copper windings. Any ballast could be used with 1500 W fixtures because no 

efficiency level is proposed for them. At TSL 3 only the 1500 W ballasts are 

commercially available, while the other wattages were modeled. 65 TSL 3 sets the same 

standards for indoor and outdoor representative equipment classes at the same wattage.

TSL 2 represents the highest magnetic ELs that have positive NPVs, and also 

requires the same EL for both indoor and outdoor fixtures at the same wattage. TSL 2 

would set energy conservation standards at EL2 for indoor and outdoor fixtures at 70 W, 

150 W, 400 W, and 1000 W. TSL 2 would require EL1 for 250 W indoor and outdoor 

fixtures, while all 1500 W fixtures would have no energy conservation standards 

(baseline). TSL 2 also includes a design standard for indoor and outdoor 1000 W fixtures 

that prohibits the sale of probe-start ballasts in new fixtures. Standards included in TSL 2 

require fixtures that include max-tech magnetic ballasts requiring high-grade steel and 

copper windings, although 250 W ballasts typically require mid-grade steel and copper 

windings, and any ballast could be used with the unregulated 1500 W fixtures. At TSL 2 

the 70 W, 150 W, 400 W, and 1000 W indoor and outdoor ballasts are not commercially 

available, and have been modeled,65 while 250 W and 1500 W indoor and outdoor 

ballasts are commercially available. TSL 2 sets the same standards for indoor and outdoor 

representative equipment classes at the same wattage.

239 
TSL 1 represents EL1 at all equipment classes, except at 1000 W, in which EL2 

and a design standard is required, and 1500 W, in which no standards are established. 

TSL 1 would set energy conservation standards at EL1 for indoor and outdoor fixtures at 

70 W, 150 W, 250 W, and 400 W, while setting standards at EL2 for indoor and outdoor 

1000 W fixtures, and no standards for 1500 W fixtures. TSL 1 also includes a design 

standard for indoor and outdoor 1000 W fixtures that prohibits the sale of probe-start 

ballasts in new fixtures. TSL 1 requires fixtures that include magnetic ballasts using midgrade steel and copper windings, although 1000 W will require max-tech ballasts using 

high-grade steel and copper windings. At TSL 1 the only ballasts that are not 

commercially available are in the 400 W and 1000 W classes, which have been 

modeled.65 TSL 1 sets the same standards for indoor and outdoor representative 

equipment classes at the same wattage.

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Customers

a. Life-Cycle Cost and Payback Period

To evaluate the net economic impact of standards on customers, DOE conducted 

LCC and PBP analyses for each TSL. In general, a higher efficiency product would affect 

consumers in two ways: (1) Annual operating expense would decrease; and (2) purchase 

price would increase. Section V.F of this rulemaking discusses the inputs DOE used for 

calculating the LCC and PBP.

The key outputs of the LCC analysis are a mean LCC savings relative to the 

baseline case, as well as a probability distribution or likelihood of LCC reduction or 

240 
increase, for each TSL and equipment class. These values are reported by equipment 

class in Table VII.2 through Table VII.15.. The LCC analysis also estimates the fraction 

of customers for which the LCC will decrease (net benefit) or increase (net cost) relative 

to the baseline case. The last column in each table contains the median PBPs for the 

customer purchasing a design compliant with the TSL. DOE assumed that, on average, 

indoor and outdoor fixtures have 20- and 25-year lifetimes, respectively.

Table VII.2 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Indoor, 

Magnetic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 442.74 955.48 1398.23 -- -- -- --

1 1 445.68 925.58 1371.26 26.97 0 100 1.4

2, 3 2 454.07 917.16 1371.23 27.00 0 100 4.5

4 3 459.38 896.35 1355.72 42.50 18 82 3.7

5 4 472.78 888.19 1360.97 37.25 21 79 6.0

Table VII.3 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Indoor, 

Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3, 4 Baseline / 3 459.38 896.35 1355.72 -- -- -- --

5 4 472.78 888.19 1360.97 -5.25 90 10 31.5

Comment [AGA16]: Change requested by 

OIRA.

241 
Table VII.4 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Outdoor, 

Magnetic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 793.69 2195.72 2989.41 -- -- -- --

1 1 796.50 2158.67 2955.17 34.24 2 98 1.4

2, 3 2 804.53 2149.99 2954.53 34.88 3 97 4.5

4 3 834.98 2159.40 2994.38 -4.98 49 51 12.0

5 4 847.83 2152.73 3000.55 -11.15 51 49 14.7

Table VII.5 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Outdoor, 

Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3, 4 Baseline / 3 834.98 2159.40 2994.38 -- -- -- --

5 4 847.83 2152.73 3000.55 -6.17 88 12 55.8

Table VII.6 Equipment Class 2 - 150 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 483.03 1521.22 2004.25 -- -- -- --

1 1 491.93 1489.89 1981.82 22.43 0 100 4.3

2, 3 2 504.66 1474.96 1979.62 24.63 1 99 7.3

4 3 503.20 1411.38 1914.58 89.67 6 94 2.5

5 4 522.42 1405.72 1928.14 76.11 11 89 4.8

242 
Table VII.7 Equipment Class 2 - 150 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 808.79 2679.99 3488.78 -- -- -- --

1 1 817.32 2644.09 3461.41 27.37 3 97 4.5

2, 3 2 829.51 2628.57 3458.08 30.70 3 97 8.1

4 3 855.33 2581.21 3436.54 52.23 34 66 7.5

5 4 873.73 2578.45 3452.18 36.60 38 62 10.3

Table VII.8 Equipment Class 3 - 250 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 541.02 2122.17 2663.19 -- -- -- --

1, 2 1 564.55 2094.13 2658.68 4.51 40 60 14.2

3 2 581.65 2082.60 2664.26 -1.07 63 37 17.9

4 3 611.53 2111.32 2722.85 -59.67 82 18 113.2

5 4 604.31 2099.21 2703.52 -40.33 71 29 38.4

243 
Table VII.9 Equipment Class 3 - 250 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 1009.36 3153.36 4162.72 -- -- -- --

1, 2 1 1031.89 3124.09 4155.98 6.74 33 67 17.4

3 2 1048.27 3112.97 4161.24 1.48 55 45 22.8

4 3 1109.39 3172.98 4282.37 -119.65 76 24 326.7

5 4 1102.47 3158.11 4260.58 -97.86 71 29 135.1

Table VII.10 Equipment Class 4 - 400 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 628.46 3120.84 3749.31 -- -- -- --

1 1 669.22 3077.26 3746.48 2.83 53 47 16.2

2, 3 2 686.23 3055.12 3741.36 7.95 46 54 15.0

4 3 756.96 3100.09 3857.05 -107.74 92 8 369.2

5 4 798.21 3081.70 3879.91 -130.60 94 6 137.2

244 
Table VII.11 Equipment Class 4 - 400 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 1077.56 4040.60 5118.16 -- -- -- --

1 1 1116.59 3995.41 5112.00 6.16 45 55 19.9

2, 3 2 1132.88 3972.13 5105.01 13.15 38 62 18.4

4 3 1229.74 4053.72 5283.46 -165.30 81 19 Never

5 4 1269.24 4036.62 5305.85 -187.69 84 16 Never

Table VII.12 Equipment Class 5 -- 1000 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 760.77 7861.06 8621.83 -- -- -- --

Base+DS* 0.00 0.00 0.00 0.00 0 0 0.0

Base+DS** 810.04 8025.13 8835.17 -213.34 100 0 N/A

1 816.70 7795.42 8612.12 9.71 45 55 15.2

1 + DS* 801.73 6617.67 7419.40 1202.43 0 100 0.5

1 + DS** 865.97 7959.48 8825.46 -203.63 100 0 Never

2 837.75 7770.63 8608.38 13.45 45 55 15.2

1, 2, 3, 4, 5 2 + DS* 830.98 6569.31 7400.29 1221.54 0 100 0.8

2 + DS** 887.02 7934.70 8821.72 -199.89 100 0 Never

* DS = Design Standard prohibits fixtures from containing a probe-start ballast. A percentage of customers 

in this equipment class will migrate to these fixtures, which are reduced-wattage 875 W systems.

** Design Standard 1000 W pulse-start fixtures. Customers who do not migrate to 875 W systems will 

choose these 1000 W systems.

245 
Table VII.13 Equipment Class 5 -- 1000 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Baseline 1184.62 9152.48 10,337.10 -- -- -- --

Base+DS* 0.00 0.00 0.00 0.00 0 0 0.0

Base+DS** 1239.95 9435.92 10,675.88 -338.78 100 0 N/A

1 1238.18 9081.54 10,319.72 17.37 30 70 17.0

1 + DS* 1231.48 7497.64 8729.12 1607.97 0 100 0.5

1 + DS** 1293.52 9364.98 10,658.50 -321.40 100 0 Never

2 1258.34 9054.76 10,313.10 24.00 30 70 17.0

1, 2, 3, 4, 5 2 + DS* 1259.49 7445.67 8705.16 1631.94 2 98 0.8

2 + DS** 1313.68 9338.20 10,651.88 -314.78 100 0 Never

* DS = Design Standard prohibits fixtures from containing a probe-start ballast. A percentage of customers 

in this equipment class will migrate to these fixtures, which are reduced-wattage 875 W systems.

** Design Standard 1000 W pulse-start fixtures. Customers who do not migrate to 875 W systems will 

choose these 1000 W systems.

Table VII.14 Equipment Class 6 -- 1500 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3 Baseline 908.54 914.31 1822.86 0.00 -- -- --

4 1 980.76 909.25 1890.01 -67.15 100 0 209.4

5 2 1010.83 905.09 1915.92 -93.06 100 0 162.7

246 
Table VII.15 Equipment Class 6 -- 1500 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

1, 2, 3 Baseline 1276.71 1203.04 2479.75 0.00 -- -- --

4 1 1345.86 1197.60 2543.46 -63.71 100 0 244.5

5 2 1374.66 1193.11 2567.78 -88.03 100 0 190.0

b. Customer Subgroup Analysis

Using the LCC spreadsheet model, DOE determined the effect of the trial 

standard levels on the following customer subgroups: utilities, owners of transportation 

facilities, warehouse owners, owners of transient-prone outdoor lighting, and owners of 

transient-prone indoor lighting in heavy industrial facilities. DOE adjusted particular 

inputs to the LCC model to reflect conditions faced by the identified subgroups. For 

utilities, DOE assumed that maintenance costs would be higher than average maintenance 

costs because utilities have to maintain more equipment than the other subgroups do, and 

that operating costs are lower than average because utilities pay wholesale rates for 

electricity instead of retail rates. DOE assumed that owners of transportation facilities 

face higher annual operating hours than the average used in the main LCC analysis. For 

warehouse owners, DOE assumed lower annual operating hours than average used in the 

main LCC analysis. DOE assumed that owners of transient-prone outdoor lighting face 

more frequent surge protection and ballast replacements because of lightning than the 

average used in the main LCC analysis. Finally, for owners of heavy industrial facilities, 

DOE assumed that indoor lighting equipment (250 W and 400 W equipment classes only) 

247 
faced more frequent surge protection and ballast replacements because of voltage 

transients than the average used in the main LCC analysis.

Table VII.16 through Table VII.27 show the LCC effects and PBPs for identified 

subgroups that purchase metal halide lamp fixtures. In general, the average LCC savings 

for the identified subgroups at the considered efficiency levels are significantly different 

from the average for all customers.

248 
Table VII.16 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Indoor, 

Magnetic Baseline): LCC Subgroup Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 442.76 444.35 887.11 -- -- -- --

1 1 445.70 444.92 890.62 -3.50 100.0 0.0 Never

2, 3 2 454.09 446.85 900.94 -13.82 100.0 0.0 Never

4 3 459.40 477.98 937.38 -50.26 93.7 6.3 Never

5 4 472.80 483.06 955.86 -68.75 98.0 2.0 Never

Subgroup: Transportation Facility Owners

Baseline 442.76 979.64 1,422.40 -- -- -- --

1 1 445.70 948.60 1,394.30 28.10 0.0 100.0 1.4

2, 3 2 454.09 939.88 1,393.97 28.43 0.0 100.0 4.3

4 3 459.40 923.95 1,383.35 39.05 17.4 82.6 3.8

5 4 472.80 915.84 1,388.64 33.76 20.9 79.1 6.3

Subgroup: Warehouse Owners

Baseline 442.76 936.53 1,379.29 -- -- -- --

1 1 445.70 906.98 1,352.68 26.61 0.0 100.0 1.5

2, 3 2 454.09 898.53 1,352.62 26.67 0.1 99.9 4.6

4 3 459.40 878.47 1,337.87 41.42 17.4 82.6 3.5

5 4 472.80 870.24 1,343.05 36.25 19.9 80.1 5.9

249 
Table VII.17 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Indoor, 

Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

1, 2, 3, 4 Baseline / 3 459.40 477.98 937.38 -- -- -- --

5 4 472.80 483.06 955.86 -18.49 100.0 0.0 Never

Subgroup: Transportation Facility Owners

1, 2, 3, 4 Baseline / 3 459.40 923.95 1,383.35 -- -- -- --

5 4 472.80 915.84 1,388.64 -5.29 88.8 11.2 31.9

Subgroup: Warehouse Owners

1, 2, 3, 4 Baseline / 3 459.40 878.47 1,337.87 -- -- -- --

5 4 472.80 870.24 1,343.05 -5.17 89.5 10.5 30.5

250 
Table VII.18 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Outdoor, 

Magnetic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 793.71 1,536.88 2,330.59 -- -- -- --

1 1 796.52 1,538.23 2,334.75 -4.16 100.0 0.0 Never

2, 3 2 804.56 1,542.56 2,347.12 -16.52 100.0 0.0 Never

4 3 835.01 1,620.58 2,455.59 -125.00 87.2 12.8 Never

5 4 847.86 1,630.51 2,478.36 -147.77 89.9 10.1 Never

Subgroup: Transportation Facility Owners

Baseline 793.69 2,195.72 2,989.41 -- -- -- --

1 1 796.50 2,158.67 2,955.17 34.24 1.6 98.4 1.4

2, 3 2 804.53 2,149.99 2,954.53 34.88 2.9 97.1 4.5

4 3 834.98 2,159.40 2,994.38 -4.98 49.0 51.0 12.0

5 4 847.83 2,152.73 3,000.55 -11.15 51.3 48.7 14.7

Subgroup: Warehouse Owners

Baseline 793.69 2,195.72 2,989.41 -- -- -- --

1 1 796.50 2,158.67 2,955.17 34.24 1.6 98.4 1.4

2, 3 2 804.53 2,149.99 2,954.53 34.88 2.9 97.1 4.5

4 3 834.98 2,159.40 2,994.38 -4.98 49.0 51.0 12.0

5 4 847.83 2,152.73 3,000.55 -11.15 51.3 48.7 14.7

Subgroup: Owners of Transient-Prone Outdoor Lighting

Baseline 793.71 2,179.70 2,973.41 -- -- -- --

1 1 796.52 2,142.44 2,938.97 34.44 1.8 98.2 1.4

2, 3 2 804.56 2,133.66 2,938.22 35.20 2.9 97.1 4.5

4 3 835.01 2,167.47 3,002.48 -29.07 59.2 40.8 31.3

5 4 847.86 2,163.21 3,011.07 -37.66 62.2 37.8 41.0

251 
Table VII.19 Equipment Class 1 - 70 Watt Metal Halide Lamp Fixtures (Outdoor, 

Electronic Baseline): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

1, 2, 3, 4 Baseline / 3 835.01 1,620.58 2,455.59 -- -- -- --

5 4 847.86 1,630.51 2,478.36 -22.77 100.0 0.0 Never

Subgroup: Transportation Facility Owners

1, 2, 3, 4 Baseline / 3 834.98 2,159.40 2,994.38 -- -- -- --

5 4 847.83 2,152.73 3,000.55 -6.17 87.8 12.2 55.8

Subgroup: Warehouse Owners

1, 2, 3, 4 Baseline / 3 834.98 2,159.40 2,994.38 -- -- -- --

5 4 847.83 2,152.73 3,000.55 -6.17 87.8 12.2 55.8

Subgroup: Owners of Transient-Prone Outdoor Lighting

1, 2, 3, 4 Baseline / 3 835.01 2,167.47 3,002.48 -- -- -- --

5 4 847.86 2,163.21 3,011.07 -8.59 94.9 5.1 161.5

252 
Table VII.20 Equipment Class 2 - 150 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 483.05 466.08 949.13 -- -- -- --

1 1 491.95 468.47 960.43 -11.29 100.0 0.0 Never

2, 3 2 504.68 472.02 976.71 -27.57 100.0 0.0 Never

4 3 503.23 513.09 1,016.31 -67.18 97.0 3.0 Never

5 4 522.45 521.74 1,044.18 -95.05 99.6 0.4 Never

Subgroup: Transportation Facility Owners

Baseline 483.05 1,636.83 2,119.88 -- -- -- --

1 1 491.95 1,603.44 2,095.39 24.49 0.0 100.0 4.1

2, 3 2 504.68 1,587.84 2,092.53 27.35 0.7 99.3 7.0

4 3 503.23 1,521.09 2,024.32 95.56 7.2 92.8 2.4

5 4 522.45 1,515.71 2,038.15 81.73 11.1 88.9 4.6

Subgroup: Warehouse Owners

Baseline 483.05 1,494.69 1,977.73 -- -- -- --

1 1 491.95 1,463.62 1,955.58 22.16 0.0 100.0 4.4

2, 3 2 504.68 1,448.78 1,953.46 24.27 0.8 99.2 7.5

4 3 503.23 1,382.65 1,885.88 91.86 5.5 94.5 2.4

5 4 522.45 1,376.64 1,899.08 78.65 11.2 88.8 4.5

253 
Table VII.21 Equipment Class 2 - 150 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 808.82 1,406.87 2,215.69 -- -- -- --

1 1 817.35 1,411.33 2,228.68 -12.99 100.0 0.0 Never

2, 3 2 829.54 1,417.89 2,247.43 -31.74 100.0 0.0 Never

4 3 855.36 1,499.15 2,354.52 -138.83 87.1 12.9 Never

5 4 873.77 1,513.42 2,387.18 -171.49 90.7 9.3 Never

Subgroup: Transportation Facility Owners

Baseline 808.79 2,679.99 3,488.78 -- -- -- --

1 1 817.32 2,644.09 3,461.41 27.37 2.9 97.1 4.5

2, 3 2 829.51 2,628.57 3,458.08 30.70 3.3 96.7 8.1

4 3 855.33 2,581.21 3,436.54 52.23 33.8 66.2 7.5

5 4 873.73 2,578.45 3,452.18 36.60 38.2 61.8 10.3

Subgroup: Warehouse Owners

Baseline 808.79 2,679.99 3,488.78 -- -- -- --

1 1 817.32 2,644.09 3,461.41 27.37 2.9 97.1 4.5

2, 3 2 829.51 2,628.57 3,458.08 30.70 3.3 96.7 8.1

4 3 855.33 2,581.21 3,436.54 52.23 33.8 66.2 7.5

5 4 873.73 2,578.45 3,452.18 36.60 38.2 61.8 10.3

Subgroup: Owners of Transient-Prone Outdoor Lighting

Baseline 808.82 2,671.89 3,480.71 -- -- -- --

1 1 817.35 2,635.75 3,453.09 27.62 2.9 97.1 4.5

2, 3 2 829.54 2,620.05 3,449.58 31.13 3.2 96.8 8.1

4 3 855.36 2,608.06 3,463.42 17.29 47.8 52.2 11.8

5 4 873.77 2,608.78 3,482.55 -1.84 52.3 47.7 17.4

254 
Table VII.22 Equipment Class 3 - 250 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 541.05 490.86 1,031.91 -- -- -- --

1, 2 1 564.58 498.98 1,063.56 -31.66 100.0 0.0 Never

3 2 581.69 504.93 1,086.62 -54.71 100.0 0.0 Never

4 3 611.57 572.99 1,184.56 -152.65 100.0 0.0 Never

5 4 604.35 569.07 1,173.42 -141.51 99.9 0.1 Never

Subgroup: Transportation Facility Owners

Baseline 541.05 2,361.30 2,902.35 -- -- -- --

1, 2 1 564.58 2,330.88 2,895.46 6.89 30.2 69.8 13.0

3 2 581.69 2,318.58 2,900.26 2.08 56.2 43.8 16.6

4 3 611.57 2,354.22 2,965.79 -63.44 81.4 18.6 147.2

5 4 604.35 2,340.54 2,944.89 -42.54 70.6 29.4 39.2

Subgroup: Warehouse Owners

Baseline 541.05 2,096.87 2,637.92 -- -- -- --

1, 2 1 564.58 2,068.76 2,633.35 4.57 39.4 60.6 14.2

3 2 581.69 2,057.12 2,638.80 -0.89 62.7 37.3 17.9

4 3 611.57 2,086.19 2,697.76 -59.84 82.0 18.0 133.3

5 4 604.35 2,074.29 2,678.63 -40.72 72.1 27.9 40.0

Subgroup: Owners of Transient-Prone Indoor Lighting

Baseline 541.05 2,125.94 2,666.98 -- -- -- --

1, 2 1 564.58 2,097.72 2,662.30 4.68 39.7 60.3 14.1

3 2 581.69 2,086.10 2,667.79 -0.80 63.0 37.0 17.7

4 3 633.04 2,202.92 2,835.96 -168.97 99.5 0.5 Never

5 4 625.82 2,189.03 2,814.85 -147.86 99.0 1.0 Never

Table VII.23 Equipment Class 3 - 250 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings MedianPayback 

255 
Level

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Period

years

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 1,009.40 1,274.00 2,283.40 -- -- -- --

1, 2 1 1,031.93 1,286.12 2,318.06 -34.66 100.0 0.0 Never

3 2 1,048.32 1,294.99 2,343.30 -59.91 100.0 0.0 Never

4 3 1,109.44 1,402.28 2,511.72 -228.33 94.7 5.3 Never

5 4 1,102.53 1,396.84 2,499.37 -215.97 93.4 6.6 Never

Subgroup: Transportation Facility Owners

Baseline 1,009.36 3,153.36 4,162.72 -- -- -- --

1, 2 1 1,031.89 3,124.09 4,155.98 6.74 32.6 67.4 17.4

3 2 1,048.27 3,112.97 4,161.24 1.48 55.2 44.8 22.8

4 3 1,109.39 3,172.98 4,282.37 -119.65 76.4 23.6 326.7

5 4 1,102.47 3,158.11 4,260.58 -97.86 71.2 28.8 135.1

Subgroup: Warehouse Owners

Baseline 1,009.36 3,153.36 4,162.72 -- -- -- --

1, 2 1 1,031.89 3,124.09 4,155.98 6.74 32.6 67.4 17.4

3 2 1,048.27 3,112.97 4,161.24 1.48 55.2 44.8 22.8

4 3 1,109.39 3,172.98 4,282.37 -119.65 76.4 23.6 326.7

5 4 1,102.47 3,158.11 4,260.58 -97.86 71.2 28.8 135.1

Subgroup: Owners of Transient-Prone Outdoor Lighting

Baseline 1,009.40 3,152.36 4,161.76 -- -- -- --

1, 2 1 1,031.93 3,122.75 4,154.68 7.08 32.0 68.0 17.3

3 2 1,048.32 3,111.43 4,159.74 2.02 54.7 45.3 22.7

4 3 1,109.44 3,240.29 4,349.73 -187.97 90.0 10.0 Never

5 4 1,102.53 3,224.03 4,326.55 -164.79 86.7 13.3 Never

256 
Table VII.24 Equipment Class 4 - 400 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 628.50 448.11 1,076.61 -- -- -- --

1 1 669.26 463.69 1,132.95 -56.34 100.0 0.0 Never

2, 3 2 686.28 470.18 1,156.45 -79.84 100.0 0.0 Never

4 3 757.01 568.72 1,325.74 -249.13 100.0 0.0 Never

5 4 798.27 592.98 1,391.25 -314.64 100.0 0.0 Never

Subgroup: Transportation Facility Owners

Baseline 628.50 3,542.88 4,171.38 -- -- -- --

1 1 669.26 3,496.08 4,165.34 6.04 46.9 53.1 15.2

2, 3 2 686.28 3,472.11 4,158.39 13.00 38.9 61.1 14.1

4 3 757.01 3,527.12 4,284.13 -112.75 89.5 10.5 Never

5 4 798.27 3,508.32 4,306.59 -135.20 91.9 8.1 166.6

Subgroup: Warehouse Owners

Baseline 628.50 3,097.26 3,725.76 -- -- -- --

1 1 669.26 3,053.68 3,722.95 2.82 54.0 46.0 16.1

2, 3 2 686.28 3,031.58 3,717.85 7.91 46.7 53.3 15.0

4 3 757.01 3,077.37 3,834.39 -108.63 92.0 8.0 905.6

5 4 798.27 3,058.66 3,856.92 -131.16 93.8 6.2 151.6

Subgroup: Owners of Transient-Prone Indoor Lighting

Baseline 628.50 3,125.34 3,753.84 -- -- -- --

1 1 669.26 3,081.43 3,750.69 3.15 53.2 46.8 16.0

2, 3 2 686.28 3,059.14 3,745.42 8.42 45.9 54.1 15.0

4 3 778.48 3,212.60 3,991.09 -237.25 99.6 0.4 Never

5 4 819.73 3,204.61 4,024.35 -270.51 99.7 0.3 Never

257 
Table VII.25 Equipment Class 4 - 400 Watt Metal Halide Lamp Fixtures (Outdoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

-- Baseline 1,077.60 1,039.14 2,116.75 -- -- -- --

1 1 1,116.64 1,060.17 2,176.81 -60.06 100.0 0.0 Never

2, 3 2 1,132.93 1,068.93 2,201.86 -85.11 100.0 0.0 Never

4 3 1,229.80 1,210.75 2,440.55 -323.80 98.7 1.3 Never

5 4 1,269.31 1,241.30 2,510.61 -393.86 99.6 0.4 Never

Subgroup: Transportation Facility Owners

-- Baseline 1,077.56 4,040.60 5,118.16 -- -- -- --

1 1 1,116.59 3,995.41 5,112.00 6.16 44.6 55.4 19.9

2, 3 2 1,132.88 3,972.13 5,105.01 13.15 38.1 61.9 18.4

4 3 1,229.74 4,053.72 5,283.46 -165.30 80.7 19.3 Never

5 4 1,269.24 4,036.62 5,305.85 -187.69 83.9 16.1 Never

Subgroup: Warehouse Owners

-- Baseline 1,077.56 4,040.60 5,118.16 -- -- -- --

1 1 1,116.59 3,995.41 5,112.00 6.16 44.6 55.4 19.9

2, 3 2 1,132.88 3,972.13 5,105.01 13.15 38.1 61.9 18.4

4 3 1,229.74 4,053.72 5,283.46 -165.30 80.7 19.3 Never

5 4 1,269.24 4,036.62 5,305.85 -187.69 83.9 16.1 Never

Subgroup: Owners of Transient-Prone Outdoor Lighting

-- Baseline 1,077.60 4,044.53 5,122.13 -- -- -- --

1 1 1,116.64 3,998.77 5,115.41 6.72 44.2 55.8 19.9

2, 3 2 1,132.93 3,975.23 5,108.17 13.97 37.6 62.4 18.3

4 3 1,229.80 4,159.95 5,389.75 -267.62 96.3 3.7 Never

5 4 1,269.31 4,150.29 5,419.60 -297.47 97.3 2.7 Never

258 
Table VII.26 Equipment Class 5 - 1000 Watt Metal Halide Lamp Fixtures (Indoor): 

LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 760.82 1,091.41 1,852.22 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 810.09 1,258.76 2,068.85 -216.63 100.0 0.0 N/A

EL1 816.76 1,119.70 1,936.46 -84.23 100.0 0.0 Never

EL1+DS* 801.78 720.57 1,522.35 329.87 4.0 96.0 1.5

EL1+DS** 866.04 1,287.05 2,153.09 -300.86 100.0 0.0 Never

EL2 837.81 1,130.34 1,968.16 -115.93 100.0 0.0 Never

1,2,3,4,5 EL2+DS* 831.04 735.29 1,566.33 285.90 4.1 95.9 2.7

1,2,3,4,5 EL2+DS** 887.09 1,297.70 2,184.79 -332.57 100.0 0.0 Never

Subgroup: Transportation Facility Owners

Baseline 760.82 9,226.73 9,987.55 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 810.09 9,426.57 10,236.67 -249.12 100.0 0.0 N/A

EL1 816.76 9,153.37 9,970.13 17.41 34.0 66.0 13.7

EL1+DS* 801.78 7,781.69 8,583.47 1,404.08 0.0 100.0 0.4

EL1+DS** 866.04 9,353.22 10,219.25 -231.71 99.7 0.3 Never

EL2 837.81 9,125.67 9,963.48 24.06 33.9 66.1 13.6

1,2,3,4,5 EL2+DS* 831.04 7,726.91 8,557.95 1,429.60 0.0 100.0 0.7

1,2,3,4,5 EL2+DS** 887.09 9,325.51 10,212.60 -225.06 99.6 0.4 Never

Subgroup: Warehouse Owners

Baseline 760.82 7,821.14 8,581.96 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 810.09 7,990.69 8,800.78 -218.83 100.0 0.0 N/A

EL1 816.76 7,755.53 8,572.29 9.66 45.6 54.4 15.4

EL1+DS* 801.78 6,584.62 7,386.40 1,195.55 0.0 100.0 0.5

EL1+DS** 866.04 7,925.08 8,791.12 -209.16 99.7 0.3 Never

EL2 837.81 7,730.76 8,568.58 13.38 45.5 54.5 15.4

1,2,3,4,5 EL2+DS* 831.04 6,536.33 7,367.37 1,214.59 0.0 100.0 0.8

259 
1,2,3,4,5 EL2+DS** 887.09 7,900.31 8,787.40 -205.45 99.6 0.4 Never

* DS = Design Standard prohibits fixtures from containing a probe-start ballast. A percentage of customers 

in this equipment class will migrate to these fixtures, which are reduced-wattage 875 W systems.

** Design Standard 1000 W pulse-start fixtures. Customers who do not migrate to 875 W systems will 

choose these 1000 W systems.

260 
Table VII.27 Equipment Class 5 - 1000 Watt Metal Halide Lamp Fixtures 

(Outdoor): LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percent of 

Customers that 

Experience

Net

Cost

Net 

Benefit

Subgroup: Utilities

Baseline 1,184.66 1,966.58 3,151.25 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 1,240.01 2,251.71 3,491.72 -340.47 100.0 0.0 N/A

EL1 1,238.24 1,995.40 3,233.63 -82.38 100.0 0.0 Never

EL1+DS* 1,231.53 1,229.54 2,461.07 690.17 4.3 95.7 1.2

EL1+DS** 1,293.58 2,280.52 3,574.10 -422.86 100.0 0.0 Never

EL2 1,258.40 2,006.24 3,264.64 -113.39 100.0 0.0 Never

1,2,3,4,5 EL2+DS* 1,259.55 1,244.54 2,504.08 647.16 5.4 94.6 2.1

1,2,3,4,5 EL2+DS** 1,313.74 2,291.37 3,605.11 -453.86 100.0 0.0 Never

Subgroup: Transportation Facility Owners

Baseline 1,184.62 9,152.48 10,337.10 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 1,239.95 9,435.92 10,675.88 -338.78 100.0 0.0 N/A

EL1 1,238.18 9,081.54 10,319.72 17.37 30.4 69.6 17.0

EL1+DS* 1,231.48 7,497.64 8,729.12 1,607.97 0.1 99.9 0.5

EL1+DS** 1,293.52 9,364.98 10,658.50 -321.40 99.7 0.3 Never

EL2 1,258.34 9,054.76 10,313.10 24.00 30.3 69.7 17.0

1,2,3,4,5 EL2+DS* 1,259.49 7,445.67 8,705.16 1,631.94 1.6 98.4 0.8

1,2,3,4,5 EL2+DS** 1,313.68 9,338.20 10,651.88 -314.78 99.7 0.3 Never

Subgroup: Warehouse Owners

Baseline 1,184.62 9,152.48 10,337.10 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 1,239.95 9,435.92 10,675.88 -338.78 100.0 0.0 N/A

EL1 1,238.18 9,081.54 10,319.72 17.37 30.4 69.6 17.0

EL1+DS* 1,231.48 7,497.64 8,729.12 1,607.97 0.1 99.9 0.5

EL1+DS** 1,293.52 9,364.98 10,658.50 -321.40 99.7 0.3 Never

EL2 1,258.34 9,054.76 10,313.10 24.00 30.3 69.7 17.0

1,2,3,4,5 EL2+DS* 1,259.49 7,445.67 8,705.16 1,631.94 1.6 98.4 0.8

261 
1,2,3,4,5 EL2+DS** 1,313.68 9,338.20 10,651.88 -314.78 99.7 0.3 Never

Subgroup: Owners of Transient-Prone Outdoor Lighting

Baseline 1,184.66 9,169.03 10,353.69 -- -- -- --

Baseline+DS* -- -- -- -- -- -- --

Baseline+DS** 1,240.01 9,454.15 10,694.16 -340.47 100.0 0.0 N/A

EL1 1,238.24 9,097.27 10,335.50 18.19 29.8 70.2 16.9

EL1+DS* 1,231.53 7,511.15 8,742.68 1,611.01 0.1 99.9 0.5

EL1+DS** 1,293.58 9,382.40 10,675.98 -322.29 99.7 0.3 Never

EL2 1,258.40 9,070.18 10,328.57 25.12 29.7 70.3 16.8

1,2,3,4,5 EL2+DS* 1,259.55 7,458.67 8,718.22 1,635.47 1.8 98.2 0.8

1,2,3,4,5 EL2+DS** 1,313.74 9,355.30 10,669.04 -315.35 99.7 0.3 Never

* DS = Design Standard prohibits fixtures from containing a probe-start ballast. A percentage of customers 

in this equipment class will migrate to these fixtures, which are reduced-wattage 875 W systems.

** Design Standard 1000 W pulse-start fixtures. Customers who do not migrate to 875 W systems will 

choose these 1000 W systems.

c. Rebuttable Presumption Payback

As discussed in section IV.D.2, EPCA establishes a rebuttable presumption that, 

in essence, an energy conservation standard is economically justified if the increased 

purchase cost for a product that meets the standard is less than three times the value of 

the first-year energy savings resulting from the standard. (42 U.S.C. 6295(o)(2)(B)(iii)) 

DOE calculated a rebuttable presumption payback period for each TSL to determine 

whether DOE could presume that a standard at that level is economically justified. Table 

VII.28 shows the rebuttable-presumption payback periods for the fixture TSLs. Because 

only a single, average value is necessary for establishing the rebuttable-presumption 

payback period, rather than using distributions for input values, DOE used discrete 

values. As required by EPCA, DOE based the calculation on the assumptions in the DOE 

test procedures for microwave ovens. (42 U.S.C. 6295(o)(2)(B)(iii)) As a result, DOE 

calculated a single rebuttable presumption payback value, and not a distribution of 

payback periods, for each TSL.

262 
Table VII.28 Fixture Efficiency Levels with a Rebuttable Payback Period of Less 

Than Three Years 

Equipment Class Efficiency

Level

Mean Payback 

Period

years

70 W (indoor, magnetic baseline) 1 1.3

70 W (outdoor, magnetic baseline) 1 1.4

1000 W (indoor) 1 + DS* 0.4

2 + DS* 0.7

1000 W (outdoor) 1 + DS* 0.6

2 + DS* 1.0

* DS = Design standard requiring that all fixtures shall not contain a probe-start 

ballast

All the fixture efficiency levels in the LCC and PBP results tables have 

rebuttable-presumption payback periods of less than 3 years. DOE believes that the 

rebuttable-presumption payback period criterion (i.e., a limited payback period) is not 

sufficient for determining economic justification. Therefore, DOE has considered a full 

range of impacts, including those to consumers, manufacturers, the Nation, and the 

environment. Section IV of this rulemaking provides a complete discussion of how DOE 

considered the range of impacts to select the standards in today’s final rule.

2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate the impact of new and amended energy 

conservation standards on manufacturers of MHLFs and ballasts. The section below 

describes the expected impacts on manufacturers at each TSL. Chapter 13 of this final 

rule TSD explains the analysis in further detail.

263 
a. Industry Cash-Flow Analysis Results

The tables below depict the financial impacts (represented by changes in INPV) 

of new and amended energy conservation standards on manufacturers as well as the 

conversion costs that DOE estimates manufacturers would incur at each TSL. DOE 

reports the impacts on manufacturers of MHLFs and ballasts separately. Within each 

industry, DOE presents the results for all equipment classes in one group because most 

equipment classes are generally made by the same manufacturers. To evaluate the range 

of cash-flow impacts on the MHLF and ballast industries, DOE modeled four different 

scenarios using different assumptions for markups and shipments that correspond to the 

range of anticipated market responses to new and amended standards. Each scenario 

results in a unique set of cash flows and corresponding INPV at each TSL.

DOE presents two of these shipment and markup scenario combinations in the 

following section. These scenarios represent the upper and lower bounds of market 

responses that DOE anticipates could occur in the standards case. The INPV results 

presented refer to the difference in industry value between the base case and the standards 

case that result from the sum of discounted cash flows from the base year (2014) through 

the end of the analysis period. The cash-flow results presented refer to the difference in 

cash flow between the base case and the standards case in 2016, the year before 

compliance is required. This figure represents the size of the required conversion costs 

relative to the cash flow generated by the industry in the absence of new and amended 

energy conservation standards.

Cash-Flow Analysis Results by TSL for Metal Halide Ballasts

264 
To assess the upper (less severe) end of the range of potential impacts on MH

ballast manufacturers, DOE modeled a flat markup scenario. The flat markup scenario 

assumes that in the standards case, manufacturers would be able to pass along all the 

higher production costs required for more efficient equipment to their customers. 

Specifically, the industry would be able to maintain its average base case gross margin, as 

a percentage of revenue, despite the higher production costs in the standards case. In 

general, the larger the equipment price increases, the less likely manufacturers are to 

achieve the cash flow from operations calculated in this scenario because it is less likely 

that manufacturers would be able to fully markup these larger cost increases.

DOE also used the high-shipment scenario to assess the upper bound of impacts. 

Under the high-shipment scenario, base case shipments of MHLFs decrease at a slower 

rate over the analysis period compared to the low-shipment scenario. The combination of 

the flat markup and high-shipment scenario provides the best conditions for cash flow 

generation than any other combination analyzed by DOE in the MIA. In this scenario, 

manufacturers experience higher annual shipment volumes and have the ability to 

preserve their base case gross margins. Thus, this combination of scenarios yields the 

greatest modeled industry profitability.

To assess the lower (more severe) end of the range of potential impacts on the 

MH ballast industry, DOE modeled the preservation of operating profit markup scenario. 

This scenario represents the lower end of the range of potential impacts on manufacturers 

because no additional operating profit is earned on the higher production costs, eroding 

profit margins as a percentage of total revenue.

265 
DOE also used the low-shipment scenario to assess the lower bound of impacts. 

Under the low-shipment scenario, MHLF shipments decrease at a faster rate over the 

analysis period compared to the high-shipment scenario. The combination of the 

preservation of operating profit markup and low-shipment scenario most restricts 

manufacturers’ ability to pass on costs to customers and assumes the lowest level of 

shipments. Thus, this combination of scenarios estimates the largest manufacturer 

impacts.

Table VII.29 Manufacturer Impact Analysis for Metal Halide Ballasts — Flat 

Markup and High-Shipment Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2012$ millions) 74 71 74 75 83 89 

Change in INPV (2012$ millions) - (3.1) (0.4) 0.6 9.6 15.0 

(%) - -4.2 -0.5 0.8 12.9 20.3

Product 

Conversion Costs (2012$ millions) - 11 12 12 16 20 

Capital 

Conversion Costs (2012$ millions) - 9 10 11 4 5 

Total Conversion 

Costs (2012$ millions) - 21 22 23 21 24 

Table VII.30 Manufacturer Impact Analysis for Metal Halide Ballasts — 

Preservation of Operating Profit Markup and Low-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5

INPV (2012$ millions) 67 50 49 48 51 48 

Change in INPV (2012$ millions) - (16.5) (17.9) (19.0) (16.2) (19.0)

(%) - -24.6 -26.7 -28.3 -24.1 -28.3

Product 

Conversion Costs (2012$ millions) - 11 12 12 16 20 

Capital Conversion 

Costs (2012$ millions) - 9 10 11 4 5 

Total Conversion

Costs (2012$ millions) - 21 22 23 21 24 

266 
TSL 1 is baseline for two of the 12 equipment classes (1500 W indoor and 

outdoor), EL1 for eight of the 12 equipment classes (70 W indoor and outdoor, 150 W 

indoor and outdoor, 250 W indoor and outdoor, and 400 W indoor and outdoor), and EL2 

for the remaining two equipment classes (1000 W indoor and outdoor). At TSL 1, DOE 

estimates impacts on INPV range from -$3.1 million to -$16.5 million, or a change in 

INPV of -4.2 percent to -24.6 percent. At TSL 1, industry free cash flow (operating cash 

flow minus capital expenditures) is estimated to decrease by approximately 105 percent 

to -$0.4 million, compared to the base case value of $7.2 million in 2016.

Impacts on INPV range from slightly negative to moderately negative at TSL 1. 

TSL 1 requires the use of more efficient magnetic ballasts for the 70 W indoor and 

outdoor, 150 W indoor and outdoor, 250 W indoor and outdoor, 400 W indoor and 

outdoor, and 1000 W indoor and outdoor equipment classes. DOE projects that in 2017, 

92 percent of 70 W indoor shipments, 13 percent of 150 W indoor shipments, 16 percent 

of 250 W indoor shipments, seven percent of 400 W indoor shipments, one percent of 

1000 W indoor shipments, 100 percent of 1500 W indoor shipments, 40 percent of 70 W 

outdoor shipments, two percent of 150 W outdoor shipments, 10 percent of 250 W 

outdoor shipments, one percent of 1000 W outdoor shipments, and 100 percent of 1500 

W outdoor shipments would meet TSL 1 or higher in the base case. No shipments from 

the 400 W outdoor equipment class would meet TSL 1 or higher in the base case in 2017.

Conversion costs are expected to be moderate at TSL 1. DOE expects ballast 

manufacturers to incur $11 million in product conversion costs for model redesigns and 

267 
testing and $9 million in capital conversion costs for equipment such as stamping dies to 

process more efficient steel cores.

At TSL 1, the shipment-weighted average MPC increases by 29 percent relative 

to the base case MPC. Under the flat markup scenario, manufacturers are able to fully 

pass on this cost increase to customers under this scenario. Additionally, under the highshipment scenario, shipments are 130 percent higher than shipments under the lowshipment scenario in the last year of the analysis period. Thus, manufacturers generate 

the most revenue under this combination (flat markup and high-shipment) of scenarios. 

The fairly large $21 million in conversion costs estimated at TSL 1 outweigh the 

moderate MPC increase even when applied to the larger quantity of shipments of the 

high-shipment scenario, resulting in slightly negative INPV impacts at TSL 1 under the 

flat markup and high-shipment scenarios.

Under the preservation of operating profit markup scenario, manufacturers earn 

the same operating profit as they would in the base case in 2018, however, manufacturers 

do not earn additional profit from their investments. In this scenario, the 29 percent MPC 

increase is outweighed by a lower average markup of 1.43 (compared to the flat markup 

scenario markup of 1.47) and $21 million in conversion costs, resulting in greater 

negative impacts at TSL 1. The low-shipment scenario exacerbates these impacts because 

the base case INPV (the figure against which the absolute change in INPV is compared) 

is 10 percent lower than the base case INPV in the high-shipment scenario.

268 
TSL 2 is baseline for two of the 12 equipment classes (1500 W indoor and 

outdoor), EL1 for two of the 12 equipment classes (250 W indoor and outdoor), and EL2 

for the remaining eight equipment classes (70 W indoor and outdoor, 150 W indoor and 

outdoor, 400 W indoor and outdoor, and 1000 W indoor and outdoor). At TSL 2, DOE 

estimates impacts on INPV to range from -$0.4 million to -$17.9 million, or a change in 

INPV of -0.5 percent to -26.7 percent. At this level, industry free cash flow is estimated 

to decrease by approximately 114 percent to -$1.0 million, compared to the base case 

value of $7.2 million in 2016. 

For several equipment classes TSL 2 is the highest efficiency level the 

engineering analysis assumes manufacturers can meet with magnetic ballasts. DOE 

projects that in 2017, 89 percent of 70 W indoor shipments, ten percent of 150 W indoor 

shipments, 16 percent of 250 W indoor shipments, seven percent of 400 W indoor

shipments, one percent of 1000 W indoor shipments, 100 percent of 1500 W indoor 

shipments, 10 percent of 250 W outdoor shipments, one percent of 1000 W outdoor 

shipments, and 100 percent of 1500 W outdoor shipments would meet TSL 2 or higher in 

the base case. No shipments from the 70 W outdoor, 150 W outdoor, or 400 W outdoor 

equipment classes would meet TSL 2 or higher in the base case in 2017. At TSL 2, 

product conversion costs slightly rise to $12 million and capital conversion costs slightly

rise to $10 million as manufacturers need to purchase additional equipment and tooling to 

upgrade magnetic production lines.

At TSL 2, the shipment-weighted average MPC increases 38 percent over the 

base case MPC. In flat markup scenario, INPV impacts are slightly negative because the 

269 
$22 million in conversion costs outweigh the manufacturers’ ability to pass on the higher 

equipment costs to customers. Under the preservation of operating profit markup 

scenario, the 38 percent MPC increase is outweighed by a lower average markup of 1.42 

and $22 million in conversion costs, resulting in negative INPV impacts at TSL 2.

TSL 3 is baseline for two of the 12 equipment classes (1500 W indoor and 

outdoor) and EL2 for the remaining ten equipment classes (70 W indoor and outdoor, 150 

W indoor and outdoor, 250 W indoor and outdoor, 400 W indoor and outdoor, and 1000 

W indoor and outdoor). At TSL 3, DOE estimates impacts on INPV to range from $0.6 

million to -$19.0 million, or a change in INPV of 0.8 percent to -28.3 percent. At this 

level, industry free cash flow is estimated to decrease by approximately 120 percent to -

$1.5 million, compared to the base case value of $7.2 million in 2016.

TSL 3 is the highest efficiency level the engineering analysis assumes 

manufacturers can meet with magnetic ballasts for all equipment classes. DOE projects 

that in 2017, 89 percent of 70 W indoor shipments, ten percent of 150 W indoor 

shipments, 12 percent of 250 W indoor shipments, seven percent of 400 W indoor 

shipments, one percent of 1000 W indoor shipments, 100 percent of 1500 W indoor 

shipments, one percent of 1000 W outdoor shipments, and 100 percent of 1500 W 

outdoor shipments would meet TSL 3 or higher in the base case. No shipments from the 

70 W outdoor, 150 W outdoor, 250 W outdoor, or 400 W outdoor equipment classes 

would meet TSL 3 or higher in 2016 in the base case in 2017. DOE expects product 

conversion costs to remain constant at $12 million and capital conversion costs to 

increase slightly to $11 million.

270 
At TSL 3 the shipment-weighted average MPC increases 42 percent over the base 

case MPC. In the flat markup scenario, the additional revenues earned from passing on 

these higher MPC costs outweigh the $23 million in conversion costs and higher working 

capital requirements, resulting in slightly positive INPV impacts. Under the preservation 

of operating profit markup scenario, the 42 percent MPC increase is outweighed by a 

lower average markup of 1.41 and $23 million in conversion costs, resulting in INPV 

results remaining negative at TSL 3.

TSL 4 is EL1 for two equipment classes (1500 W indoor and outdoor), EL2 for 

two equipment classes (1000 W indoor and outdoor), and EL3 for the remaining eight 

equipment classes (70 W indoor and outdoor, 150 W indoor and outdoor, 250 W indoor 

and outdoor, and 400 W indoor and outdoor). At TSL 4, DOE estimates impacts on INPV 

to range from $9.6 million to -$16.2 million, or a change in INPV of 12.9 percent to -24.1 

percent. At this level, industry free cash flow is estimated to decrease by approximately 

94 percent to $0.5 million, compared to the base case value of $7.2 million in 2016.

The technology changes from TSL 3 to TSL 4 are that manufacturers must now 

use now electronic ballasts for the 70 W indoor and outdoor, 150 W indoor and outdoor, 

250 W indoor and outdoor, and 400 W indoor and outdoor equipment classes at TSL 4. 

DOE projects that in 2017, 89 percent of 70 W indoor shipments, 10 percent of 150 W 

indoor shipments, 12 percent of 250 W indoor shipments, seven percent of 400 W indoor 

shipments, one percent of 1000 W indoor shipments, six percent of 1500 W indoor 

shipments, one percent of 1000 W outdoor shipments, and four percent of 1500 W 

271 
outdoor shipments would meet TSL 4 or higher in the base case. No shipments of the 70 

W outdoor, 150 W outdoor, 250 W outdoor, or 400 W outdoor equipment classes would 

meet TSL 4 or higher in the base case in 2017. Total conversion costs decrease from $23 

million at TSL 3 to $21 million at TSL 4, because of the flexibility of electronic ballast 

production within the lighting manufacturing industry.

At TSL 4, the shipment-weighted average MPC increases 63 percent over the 

base case MPC. In the flat markup scenario, the additional revenues earned from passing 

on these higher MPC costs outweigh the $21 million in conversion costs, resulting in 

moderately positive impacts on INPV. Under the preservation of operating profit markup 

scenario, the MPC increase is outweighed by a lower average markup of 1.40 and $21 

million in conversion costs, resulting in INPV results remaining negative at TSL 4.

TSL 5 is EL2 for four of the 12 equipment classes (1000 W indoor and outdoor 

and 1500 W indoor and outdoor) and EL4 for the remaining eight equipment classes (70 

W indoor and outdoor, 150 W indoor and outdoor, 250 W indoor and outdoor, and 400 W 

indoor and outdoor). At TSL 5, DOE estimates impacts on INPV to range from $15.0 

million to -$19.0 million, or a change in INPV of 20.3 percent to -28.3 percent. At this 

level, industry free cash flow is estimated to decrease by approximately 109 percent to -

$0.6 million, compared to the base case value of $7.2 million in 2016.

TSL 5 is max tech for all equipment classes. DOE projects that in 2017, one 

percent of 70 W indoor shipments, one percent of 1000 W indoor shipments, and one 

percent of 1000 W outdoor shipments will meet TSL 5 in the base case. No shipments of 

272 
any of the other equipment classes will meet TSL 5 in the base case in 2017. As a result, 

product conversion costs increase to $24 million because of the need to redesign and test 

additional models. However, capital conversion costs remain fairly low at $5 million due 

to the flexibility of electronic ballast production.

At TSL 5, the shipment-weighted average MPC increases 82 percent over the 

base case MPC. In the flat markup scenario the additional revenues earned from passing 

on these higher MPC costs outweigh the increased conversion costs of $24 million, 

resulting in a moderately positive impact on INPV. Under the preservation of operating 

profit markup scenario, the MPC increase is outweighed by a lower average markup of 

1.39 and $24 million in conversion costs, resulting in INPV results remaining negative at 

TSL 5.

Cash Flow Analysis Results by TSL for Metal Halide Lamp Fixtures

DOE incorporated the same scenarios to represent the upper and lower bounds of 

industry impacts for MHLFs as for MH ballasts: the flat markup scenario with the highshipment scenario and the preservation of operating profit markup scenario with the lowshipment scenario. Note that the TSLs below represent the same sets of efficiency levels 

as discussed in the previous section in the description of impacts on MH ballast 

manufacturers.

273 
Table VII.31 Manufacturer Impact Analysis for Metal Halide Lamp Fixtures — 

Flat Markup and High-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5

INPV (2012$ millions) 379 408 418 423 418 408 

Change in INPV (2012$ millions) - 28.4 38.3 43.4 38.6 29.1 

(%) - 7.5 10.1 11.4 10.2 7.7

Product 

Conversion Costs (2012$ millions) - 3 3 3 45 62 

Capital 

Conversion Costs (2012$ millions) - 0 0 0 32 50 

Total Conversion 

Costs (2012$ millions) - 3 3 3 77 112 

Table VII.32 Manufacturer Impact Analysis for Metal Halide Lamp Fixtures — 

Preservation of Operating Profit Markup and Low-Shipment Scenario

Units Base Case

Trial Standard Level

1 2 3 4 5

INPV (2012$ millions) 346 342 342 342 285 257 

Change in INPV (2012$ millions) (3.6) (3.6) (3.6) (60.4) (88.6)

(%) -1.0 -1.0 -1.1 -17.5 -25.6

Product 

Conversion Costs (2012$ millions) 3 3 3 45 62 

Capital 

Conversion Costs (2012$ millions) 0 0 0 32 50 

Total Conversion 

Costs (2012$ millions) 3 3 3 77 112 

At TSL 1, DOE estimates impacts on INPV to range from $28.4 million to -$3.6 

million, or a change in INPV of 7.5 percent to -1.0 percent. At TSL 1, industry free cash 

flow is estimated to decrease by approximately 3 percent to $38.3 million, compared to 

the base case value of $39.3 million in 2016.

DOE expects minimal conversion costs for fixture manufacturers at TSL 1. 

Fixture manufacturers would incur $3 million in product conversion costs for the testing 

of redesigned ballasts. Because the stack height of magnetic ballasts is not expected to 

274 
change in response to the standards, fixture manufacturers would not incur any capital 

conversion costs at efficiency levels that can be met with magnetic ballast such as TSL 1.

At TSL 1, the shipment-weighted average MPC increases by 11 percent from the 

base case MPC. In the flat markup scenario manufacturers maximize revenue since they 

are able to fully pass on this cost increase to customers. The slight price increase applied 

to a large quantity of shipments outweighs the impact of the $3 million in conversion 

costs for TSL 1, resulting in positive impacts at TSL 1 under the flat markup and highshipment scenarios.

Under the preservation of operating profit markup scenario a lower average 

markup of 1.54 (compared to the flat manufacturer markup of 1.58) and $3 million in 

conversion cost results in a slightly negative impacts at TSL 1. The low-shipment 

scenario exacerbates these impacts because the base case INPV (the figure against which 

the absolute change in INPV is compared) is 10 percent lower than the base case INPV in 

the high-shipment scenario.

At TSL 2, DOE estimates impacts on INPV to range from $38.3 million to -$3.6 

million, or a change in INPV of 10.1 percent to -1.0 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 3 percent to $38.3 million, compared 

to the base case value of $39.3 million in 2016.

At TSL 2, the shipment-weighted average MPC increases 15 percent over the 

base case MPC. In the flat markup scenario the additional revenues earned from passing 

275 
on these higher MPC costs outweigh the fairly low conversion costs of $3 million, 

resulting in a positive impact on INPV. Under the preservation of operating profit markup 

scenario, the MPC increase is outweighed by a lower average markup of 1.53 and $3 

million in conversion costs, resulting in slightly negative INPV results at TSL 2.

At TSL 3, DOE estimates impacts on INPV to range from $43.4 million to -$3.6 

million, or a change in INPV of 11.4 percent to -1.1 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 3 percent to $38.3 million, compared 

to the base case value of $39.3 million in 2016. At TSL 3, the shipment-weighted average 

MPC increases 16 percent over the base case MPC. In the flat markup scenario the 

additional revenues earned from passing on these higher MPC costs outweigh the fairly 

low conversion costs of $3 million, resulting in a positive impact on INPV. Under the 

preservation of operating profit markup scenario, the MPC increase is outweighed by a 

lower average markup of 1.53 and $3 million in conversion costs, resulting in slightly 

negative INPV results at TSL 3.

At TSL 4, DOE estimates impacts on INPV to range from $38.6 million to -$60.4 

million, or a change in INPV of 10.2 percent to -17.5 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 72 percent to $10.9 million, 

compared to the base case value of $39.3 million in 2016.

The technology changes from TSL 3 to TSL 4 are that manufacturers must use 

electronic ballasts to meet the required efficiencies for the 70 W indoor and outdoor, 150 

W indoor and outdoor, 250 W indoor and outdoor, and 400 W indoor and outdoor 

276 
equipment classes at TSL 4. This increases the product conversion costs from $3 million 

at TSL 3 to $45 million at TSL 4 and increases the capital conversion costs from zero at 

TSL 3 to $32 million at TSL 4.

At TSL 4, the shipment-weighted average MPC increases 44 percent over the 

base case MPC. In the flat markup scenario the additional revenue earned from passing 

on these higher MPC costs outweigh the increased conversion costs of $77 million, 

resulting in a positive impact on INPV at TSL 4. Under the preservation of operating 

profit markup scenario the MPC increase is outweighed by a lower average markup of 

1.48 and $77 million in conversion costs, resulting in moderately negative INPV impacts 

at TSL 4.

At TSL 5, DOE estimates impacts on INPV to range from $29.1 million to -$88.6 

million, or a change in INPV of 7.7 percent to -25.6 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 107 percent to -$2.8 million, 

compared to the base case value of $39.3 million in 2016.

At TSL 5, product conversion costs again significantly increase to $62 million as 

manufacturers must redesign all equipment classes to accommodate the most efficient 

electronic ballasts. Capital conversion costs also significantly increase to $50 million 

because of the need for additional equipment and tooling, such as new castings to 

incorporate thermal protection in the 70 W indoor and outdoor, 150 W indoor and 

outdoor, 250 W indoor and outdoor, and 400 W indoor and outdoor equipment classes.

277 
At TSL 5, the shipment-weighted average MPC increases 51 percent over the 

base case MPC. In the flat markup scenario the additional revenues earned from passing 

on these higher MPC costs outweigh the much larger conversion costs of $112 million, 

resulting in a positive impact on INPV. Under the preservation of operating profit markup 

scenario, the MPC increase is outweighed by a lower average markup of 1.47 and $112 

million in conversion costs, resulting in significantly negative INPV impacts at TSL 5.

b. Impacts on Employment

DOE quantitatively assessed the impacts of potential new and amended energy 

conservation standards on direct employment. DOE used the GRIM to estimate the 

domestic labor expenditures and number of domestic production workers in the base case 

and at each TSL from 2014 to 2046. DOE used statistical data from the U.S. Census 

Bureau’s 2009 Annual Survey of Manufacturers (ASM), the results of the engineering 

analysis, and interviews with manufacturers to determine the inputs necessary to calculate 

industry-wide labor expenditures and domestic employment levels. Labor expenditures 

involved with the manufacture of the equipment is a function of the labor intensity of the 

equipment, the sales volume, and an assumption that wages remain fixed in real terms 

over time.

In the GRIM, DOE used the labor content of the equipment and the 

manufacturing production costs to estimate the annual labor expenditures in the industry. 

DOE used Census data and interviews with manufacturers to estimate the portion of the 

total labor expenditures that is attributable to domestic labor.

278 
The production worker estimates in this section cover only workers up to the linesupervisor level who are directly involved in fabricating and assembling equipment 

within an OEM facility. Workers performing services that are closely associated with 

production operations, such as material handing with a forklift, are also included as 

production labor. DOE’s estimates account for only production workers who manufacture 

the specific equipment covered by this rulemaking. For example, a worker on a 

fluorescent lamp ballast line would not be included with the estimate of the number of 

MHLF or MH ballast workers.

The employment impacts shown in the tables below represent the potential 

production employment that could result following new and amended energy 

conservation standards. The upper bound of the results estimates the maximum change in 

the number of production workers that could occur after compliance with new and 

amended energy conservation standards when assuming that manufacturers continue to 

produce the same scope of covered equipment in the same production facilities. It also 

assumes that domestic production does not shift to lower labor-cost countries. Because 

there is a real risk of manufacturers evaluating sourcing decisions in response to new and 

amended energy conservation standards, the lower bound of the employment results 

includes the estimated total number of U.S. production workers in the industry who could 

lose their jobs if all existing production were moved outside of the United States. While 

the results present a range of employment impacts following 2017, the sections below 

also include qualitative discussions of the likelihood of negative employment impacts at 

the various TSLs. Finally, the employment impacts shown are independent of the 

279 
employment impacts from the broader U.S. economy, which are documented in chapter 

14 of this final rule TSD.

Employment Impacts for Metal Halide Ballasts

Based on 2009 ASM data and interviews with manufacturers, DOE estimates that 

less than 30 domestic production workers would be involved in manufacturing MH 

ballasts in 2017, as the vast majority of MH ballasts are manufactured abroad. DOE’s 

view is that manufacturers could face moderate positive impacts on domestic 

employment levels because increasing equipment costs at each TSL would result in 

higher labor expenditures per unit, causing manufacturers to hire more workers to meet 

demand for MH ballasts, assuming that production remains in domestic facilities. Many 

manufacturers, however, do not expect a significant change in total employment at their 

facilities. Although manufacturers are concerned that higher prices for MH ballasts will 

drive customers to alternate technologies, most manufacturers offer these alternate 

technologies and can shift their employees from MH ballast production to production of 

other technologies in their facilities. Most manufacturers believe that domestic 

employment will only be significantly adversely affected if customers shift to foreign 

imports, causing the total lighting market share of the major domestic manufacturers to 

decrease.

Employment Impacts for Metal Halide Lamp Fixtures

Using 2009 ASM data and interviews with manufacturers, DOE estimates that 

approximately 60 percent of the MHLFs sold in the United States are manufactured 

domestically. With this assumption, DOE estimates that in the absence of new and 

280 
amended energy conservation standards, there would be approximately 340 domestic 

production workers involved in manufacturing MHLFs in 2017. Table VII.33 and Table 

VII.34 show the range of the impacts of potential new and amended energy conservation 

standards on U.S. production workers in the MHLF industry.

Table VII.33 Potential Changes in the Total Number of Domestic Metal Halide 

Lamp Fixture Production Workers in 2017 (Flat Markup and High-Shipment 

Scenario)

Base 

Case Trial Standard Level

1 2 3 4 5

Total Number of Domestic 

Production Workers in 2017

(without changes in 

production locations)

345 393 408 415 419 440

Potential Changes in 

Domestic Production 

Workers in 2017*

- 48 – (345) 63 – (345) 70 – (345) 74 – (345) 95 – (345)

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers

Table VII.34 Potential Changes in the Total Number of Domestic Metal Halide 

Lamp Fixture Production Workers in 2017 (Preservation of Operating Profit 

Markup and Low-Shipment Scenario) 

Base 

Case Trial Standard Level

1 2 3 4 5

Total Number of Domestic 

Production Workers in 2017

(without changes in 

production locations)

339 386 401 408 412 432

Potential Changes in 

Domestic Production 

Workers in 2017*

- 47 – (339) 62 – (339) 69 – (339) 73 – (339) 93 – (339)

At the upper end of the range, all examined TSLs show moderate positive impacts 

on domestic employment levels. The increasing equipment cost at each higher TSL 

would result in higher labor expenditures per unit, causing manufacturers to hire more 

workers to meet demand levels of MHLFs, assuming that production remains in domestic 

281 
facilities. Many manufacturers, however, do not expect a significant change in total 

employment at their facilities. Although manufacturers are concerned that higher prices 

for MHLFs will drive customers to alternate technologies, most manufacturers offer these 

alternate technologies and can shift their employees from MHLF production to 

production of other technologies in their facilities. As with MH ballast manufacturers, 

most MHLF manufacturers believe that domestic employment will only be significantly 

adversely affected if customers shift to foreign imports, causing the total lighting market 

share of the major domestic manufacturers to decrease. Because of the potentially high 

cost of shipping MHLFs from overseas, many manufacturers believe that this shift is 

unlikely to occur, especially for the higher wattage MHLFs. This is particularly true for 

the significant portion of the market served by small manufacturers, for whom the perunit shipping costs of sourcing products would be even greater because of the lower 

volumes that they sell.

Based on the above, DOE does not expect the adopted energy conservation 

standards for MHLFs, at TSL 2, to have a significant negative impact on direct domestic 

employment levels. DOE notes that domestic employment levels could be negatively 

affected in the event that small fixture businesses choose to exit the market due to 

standards. However, discussions with small manufacturers indicated that most small 

businesses will be able to adapt to new and amended regulations at the adopted standards. 

The impacts on small businesses are discussed in section VIII.B. 

282 
c. Impacts on Manufacturing Capacity

Both MHLF and ballast manufacturers stated that they do not anticipate any 

capacity constraints at efficiency levels that can be met with magnetic ballasts, which are 

the efficiency levels adopted for all equipment classes in today’s final rule. If the 

production of higher-efficiency magnetic ballasts decreases the throughput on production 

lines, manufacturers stated that they would be able to add shifts on existing lines and 

maintain capacity. 

At efficiency levels that require electronic ballasts, however, manufacturers are 

concerned about the current worldwide shortage of electrical components. The 

components most affected by this shortage are high-efficiency parts, for which demand 

would increase even further following new and amended energy conservation standards. 

The increased demand could exacerbate the component shortage, thereby impacting 

manufacturing capacity in the near term, according to manufacturers. However, there are 

no equipment classes requiring electronic ballasts in today’s final rule. Therefore, DOE 

does not anticipate a significant increase in demand for electric components due to 

today’s energy conservation standards. While DOE recognizes that the premium 

component shortage is currently a significant issue for manufacturers, DOE views it as a 

relatively short-term phenomenon to which component suppliers will ultimately adjust. 

According to several manufacturers, suppliers have the ability to ramp up production to 

meet MH ballast component demand by the compliance date of new and amended 

standards, but those suppliers have hesitated to invest in additional capacity due to 

economic uncertainty and skepticism about the sustainability of demand. The state of the 

macroeconomic environment through 2017 will likely affect the duration of the premium 

283 
component shortage. Mandatory standards, however, could create more certainty for 

suppliers about the eventual demand for these components. Additionally, the premium 

components at issue are not new technologies; rather, they have simply not historically 

been demanded in large quantities by MH ballast manufacturers.

d. Impacts on Subgroups of Manufacturers

Using average cost assumptions to develop an industry cash-flow estimate may 

not be adequate for assessing differential impacts among manufacturer subgroups. Small 

manufacturers, niche equipment manufacturers, and manufacturers exhibiting cost 

structures substantially different from the industry average could be affected 

disproportionately. DOE analyzed the impacts to small businesses in section VIII.B and 

did not identify any other adversely impacted subgroups for MHLFs or ballasts for this 

rulemaking based on the results of the industry characterization.

e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of recent or impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 

manufacturer can strain profits and lead companies to abandon product lines or markets 

with lower expected future returns than competing products. For these reasons, DOE 

284 
conducts an analysis of cumulative regulatory burden as part of its rulemakings 

pertaining to appliance efficiency.

During previous stages of this rulemaking, DOE identified a number of 

requirements, in addition to new and amended energy conservation standards for MHLFs, 

that manufacturers will face for products and equipment they manufacture approximately

three years prior to and three years after the compliance date of the new and amended 

standards. The following section briefly addresses comments DOE received with respect 

to cumulative regulatory burden and summarizes other key related concerns that 

manufacturers raised during interviews and submitted comments.

Several manufacturers expressed concern about the overall volume of DOE 

energy conservation standards with which they must comply. Most MHLF manufacturers 

also make a full range of lighting products and share engineering and other resources 

with these other internal manufacturing divisions for different products, including 

certification testing for regulatory compliance.

DOE discusses these and other requirements in chapter 13 of this final rule TSD. 

DOE takes into account the cost of compliance with other published Federal energy 

conservation standards in weighing the benefits and burdens of today’s rulemaking. DOE 

does not describe the quantitative impacts of standards that have not yet been finalized 

because any impacts would be speculative. DOE also notes that certain standards, such as 

ENERGY STAR, are optional for manufacturers.

285 
3. National Impact Analysis

a. Significance of Energy Savings

For each TSL, DOE projected energy savings for metal halide lamp fixtures 

purchased in the 30-year period that begins in the year 2017, ending in the year 2046. The 

savings are measured over the entire lifetime of equipment purchased in the 30-year 

period. DOE quantified the energy savings attributable to each TSL as the difference in 

energy consumption between each standards case and the base case. Table VII.35

presents the estimated primary energy savings for each TSL for the low- and highshipments scenarios, which represent the minimum and maximum energy savings 

resulting from all the scenarios analyzed. Table VII.36 presents the estimated FFC energy 

savings for each considered TSL. Chapter 11 of the final rule TSD describes these 

estimates in more detail.

286 
Table VII.35 Cumulative National Primary Energy Savings for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2017–2046 

Trial 

Standard 

Level

Equipment Class

National Primary Energy Savings

quads

Low-Shipments 

Scenario

High-Shipments 

Scenario

1 

70 W 0.01 0.01

150 W 0.02 0.02

250 W 0.02 0.02

400 W 0.10 0.13

1000 W 0.16 0.20

1500 W 0.00 0.00

Total 0.30 0.38

2 

70 W 0.02 0.02

150 W 0.04 0.05

250 W 0.02 0.02

400 W 0.15 0.19

1000 W 0.16 0.20

1500 W 0.00 0.00

Total 0.38 0.48

3 

70 W 0.02 0.02

150 W 0.04 0.05

250 W 0.03 0.03

400 W 0.15 0.19

1000 W 0.16 0.20

1500 W 0.00 0.00

Total 0.39 0.49

4 

70 W 0.07 0.09

150 W 0.10 0.12

250 W 0.11 0.14

400 W 0.25 0.31

1000 W 0.16 0.20

1500 W 0.00 0.00

Total 0.69 0.86

5 

70 W 0.09 0.11

150 W 0.11 0.14

250 W 0.13 0.16

400 W 0.33 0.41

1000 W 0.16 0.20

1500 W 0.00 0.00

Total 0.81 1.02

287 
Table VII.36 Cumulative National Full-Fuel-Cycle Energy Savings for Metal Halide 

Lamp Fixture Trial Standard Levels for Units Sold in 2017–2046 

Trial 

Standard 

Level

Equipment Class

National FFC Energy Savings

quads

Low-Shipments 

Scenario

High-Shipments 

Scenario

1 

70 W 0.01 0.01

150 W 0.02 0.02

250 W 0.02 0.02

400 W 0.11 0.13

1000 W 0.16 0.21

1500 W 0.00 0.00

Total 0.31 0.39

2 

70 W 0.02 0.02

150 W 0.04 0.05

250 W 0.02 0.02

400 W 0.16 0.20

1000 W 0.16 0.21

1500 W 0.00 0.00

Total 0.39 0.49

3 

70 W 0.02 0.02

150 W 0.04 0.05

250 W 0.03 0.03

400 W 0.16 0.20

1000 W 0.16 0.21

1500 W 0.00 0.00

Total 0.40 0.50

4 

70 W 0.08 0.09

150 W 0.10 0.13

250 W 0.12 0.14

400 W 0.25 0.32

1000 W 0.16 0.21

1500 W 0.00 0.00

Total 0.71 0.88

5 

70 W 0.09 0.11

150 W 0.11 0.14

250 W 0.13 0.16

400 W 0.33 0.42

1000 W 0.16 0.21

1500 W 0.00 0.00

Total 0.83 1.03

Circular A-4 requires agencies to present analytical results, including separate 

schedules of the monetized benefits and costs that show the type and timing of benefits 

and costs. Circular A-4 also directs agencies to consider the variability of key elements 

underlying the estimates of benefits and costs. For this rulemaking, DOE undertook a 

sensitivity analysis using nine rather than 30 years of fixture shipments. The choice of a 

288 
9-year period is a proxy for the timeline in EPCA for the review of certain energy 

conservation standards and potential revision of and compliance with such revised 

standards.66 DOE notes that the review time frame established in EPCA generally does 

not overlap with the equipment lifetime, equipment manufacturing cycles or other factors 

specific to metal halide lamp fixtures. Thus, this information is presented for 

informational purposes only and is not indicative of any change in DOE’s analytical 

methodology. The NES results based on a 9-year analytical period are presented in Table 

VII.37. The impacts are counted over the lifetime of fixtures purchased in 2017–2025. 

66 EPCA requires DOE to review its standards at least once every 6 years, and requires, for certain 

products, a 3-year period after any new standard is promulgated before compliance is required, except that 

in no case may any new standards be required within 6 years of the compliance date of the previous 

standards. While adding a 6-year review to the 3-year compliance period adds up to 9 years, DOE notes 

that it may undertake reviews at any time within the 6-year period and that the 3-year compliance date may 

yield to the 6-year backstop. 

289 

 
Table VII.37 Cumulative National Primary Energy Savings for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2017–2025 

Trial 

Standard 

Level

Equipment Class National Primary Energy Savings

quads

Low-Shipments 

Scenario

High-Shipments 

Scenario

1 

70 W 0.01 0.01

150 W 0.01 0.01

250 W 0.01 0.01

400 W 0.05 0.05

1000 W 0.08 0.08

1500 W 0.00 0.00

Total 0.15 0.16

2 

70 W 0.01 0.01

150 W 0.02 0.02

250 W 0.01 0.01

400 W 0.07 0.07

1000 W 0.08 0.08

1500 W 0.00 0.00

Total 0.19 0.20

3 

70 W 0.01 0.01

150 W 0.02 0.02

250 W 0.01 0.01

400 W 0.07 0.07

1000 W 0.08 0.08

1500 W 0.00 0.00

Total 0.19 0.20

4 

70 W 0.04 0.05

150 W 0.05 0.05

250 W 0.06 0.06

400 W 0.11 0.12

1000 W 0.08 0.08

1500 W 0.00 0.00

Total 0.34 0.36

5 

70 W 0.05 0.06

150 W 0.05 0.06

250 W 0.06 0.07

400 W 0.15 0.16

1000 W 0.08 0.08

1500 W 0.00 0.00

Total 0.39 0.42

b. Net Present Value of Customer Costs and Benefits

DOE estimated the cumulative NPV of the total costs and savings for customers 

that would result from the TSLs considered for metal halide lamp fixtures. In accordance 

290 
with OMB’s guidelines on regulatory analysis,67 DOE calculated the NPV using both a 7-

percent and a 3-percent real discount rate. The 7-percent rate is an estimate of the average 

before-tax rate of return on private capital in the U.S. economy, and reflects the returns 

on real estate and small business capital as well as corporate capital. This discount rate 

approximates the opportunity cost of capital in the private sector (OMB analysis has 

found the average rate of return on capital to be near this rate). The 3-percent rate reflects 

the potential effects of standards on private consumption (e.g., through higher prices for 

products and reduced purchases of energy). This rate represents the rate at which society 

discounts future consumption flows to their present value. It can be approximated by the 

real rate of return on long-term government debt (i.e., yield on United States Treasury 

notes), which has averaged about 3 percent for the past 30 years.

Table VII.38 shows the customer NPV results for each TSL DOE considered for 

metal halide lamp fixtures, using both 7-percent and 3-percent discount rates. In each 

case, the impacts cover the lifetime of equipment purchased in 2017–2046. See chapter 

11 of the final rule TSD for more detailed NPV results.

67 OMB Circular A-4, section E (Sept. 17, 2003). Available at: 

www.whitehouse.gov/omb/circulars_a004_a-4. 

291 

 
Table VII.38 Net Present Value of Customer Benefits for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2017–2046 

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 2012$

Low-Shipments Scenario High-Shipments Scenario

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1 

70 W 0.018 0.033 0.019 0.035

150 W 0.031 0.074 0.035 0.089

250 W 0.007 0.045 0.009 0.053

400 W 0.004 0.102 0.008 0.134

1000 W 0.198 0.528 0.234 0.656

1500 W 0.000 0.000 0.000 0.000

Total 0.257 0.783 0.304 0.968

2 

70 W 0.016 0.041 0.017 0.044

150 W 0.046 0.119 0.054 0.144

250 W 0.007 0.045 0.009 0.053

400 W 0.022 0.183 0.030 0.236

1000 W 0.198 0.528 0.234 0.656

1500 W 0.000 0.000 0.000 0.000

Total 0.289 0.915 0.343 1.134

3 

70 W 0.016 0.041 0.017 0.044

150 W 0.046 0.119 0.054 0.144

250 W -0.014 0.026 -0.015 0.033

400 W 0.022 0.183 0.030 0.236

1000 W 0.198 0.528 0.234 0.656

1500 W 0.000 0.000 0.000 0.000

Total 0.267 0.896 0.319 1.114

4 

70 W -0.091 -0.118 -0.102 -0.135

150 W 0.074 0.218 0.087 0.269

250 W -0.352 -0.606 -0.401 -0.721

400 W -0.636 -1.057 -0.722 -1.244

1000 W 0.198 0.528 0.234 0.656

1500 W -0.005 -0.007 -0.005 -0.008

Total -0.812 -1.042 -0.910 -1.183

5 

70 W -0.114 -0.146 -0.128 -0.166

150 W 0.049 0.177 0.059 0.221

250 W -0.283 -0.460 -0.321 -0.543

400 W -0.741 -1.201 -0.839 -1.409

1000 W 0.198 0.528 0.234 0.656

1500 W -0.007 -0.010 -0.008 -0.012

Total -0.898 -1.111 -1.004 -1.252

The NPV results based on the aforementioned 9-year analytical period are 

presented in Table VII.39. The impacts are counted over the lifetime of fixtures 

purchased in 2017–2025. As mentioned previously, this information is presented for 

292 
informational purposes only and is not indicative of any change in DOE’s analytical 

methodology or decision criteria.

Table VII.39 Net Present Value of Customer Benefits for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2017–2025 

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 2012$

Low-Shipments Scenario High-Shipments Scenario

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1 

70 W 0.018 0.033 0.019 0.035

150 W 0.021 0.043 0.022 0.046

250 W 0.003 0.025 0.004 0.026

400 W -0.004 0.038 -0.004 0.041

1000 W 0.122 0.269 0.131 0.289

1500 W 0.000 0.000 0.000 0.000

Total 0.160 0.408 0.171 0.436

2 

70 W 0.016 0.037 0.017 0.039

150 W 0.030 0.065 0.032 0.070

250 W 0.003 0.025 0.004 0.026

400 W 0.005 0.074 0.005 0.079

1000 W 0.122 0.269 0.131 0.289

1500 W 0.000 0.000 0.000 0.000

Total 0.177 0.470 0.189 0.502

3 

70 W 0.016 0.037 0.017 0.039

150 W 0.030 0.065 0.032 0.070

250 W -0.013 0.009 -0.013 0.010

400 W 0.005 0.074 0.005 0.079

1000 W 0.122 0.269 0.131 0.289

1500 W 0.000 0.000 0.000 0.000

Total 0.161 0.455 0.172 0.486

4 

70 W -0.064 -0.072 -0.068 -0.077

150 W 0.046 0.112 0.049 0.120

250 W -0.241 -0.353 -0.253 -0.373

400 W -0.440 -0.635 -0.462 -0.669

1000 W 0.122 0.269 0.131 0.289

1500 W -0.003 -0.004 -0.003 -0.004

Total -0.580 -0.683 -0.607 -0.714

5 

70 W -0.081 -0.092 -0.087 -0.099

150 W 0.029 0.088 0.031 0.094

250 W -0.196 -0.274 -0.206 -0.289

400 W -0.514 -0.729 -0.540 -0.768

1000 W 0.122 0.269 0.131 0.289

1500 W -0.005 -0.006 -0.005 -0.006

Total -0.645 -0.744 -0.676 -0.779

293 
Finally, DOE evaluated the NPV results for both indoor and outdoor fixtures for 

each equipment class. Table VII.40 gives the NPV associated with each equipment class 

broken down into indoor and outdoor fixture environments.

Table VII.40 Net Present Value of Customer Benefits for Metal Halide Lamp 

Fixture Trial Standard Levels for Units Sold in 2017–2046 (Low Shipments, by 

Fixture Environment) 

Trial 

Standard 

Level

Equipment 

Class

Net Present Value

billion 2012$

Indoor Fixtures Outdoor Fixtures

7-Percent

Discount Rate

3-Percent

Discount Rate

7-Percent

Discount Rate

3-Percent

Discount Rate

1 

70 W 0.001 0.001 0.017 0.033

150 W 0.008 0.019 0.023 0.056

250 W 0.003 0.014 0.004 0.031

400 W 0.002 0.028 0.001 0.075

1000 W 0.054 0.136 0.143 0.393

1500 W 0.000 0.000 0.000 0.000

Total 0.068 0.197 0.189 0.586

2 

70 W 0.000 0.001 0.016 0.040

150 W 0.022 0.051 0.024 0.068

250 W 0.003 0.014 0.004 0.031

400 W 0.008 0.049 0.014 0.134

1000 W 0.054 0.136 0.143 0.393

1500 W 0.000 0.000 0.000 0.000

Total 0.087 0.251 0.201 0.664

3 

70 W 0.000 0.001 0.016 0.040

150 W 0.022 0.051 0.024 0.068

250 W -0.002 0.010 -0.012 0.016

400 W 0.008 0.049 0.014 0.134

1000 W 0.054 0.136 0.143 0.393

1500 W 0.000 0.000 0.000 0.000

Total 0.082 0.247 0.185 0.650

4 

70 W 0.001 0.002 -0.092 -0.119

150 W 0.036 0.080 0.038 0.137

250 W -0.050 -0.082 -0.302 -0.524

400 W -0.121 -0.192 -0.515 -0.865

1000 W 0.054 0.136 0.143 0.393

1500 W -0.001 -0.002 -0.003 -0.005

Total -0.081 -0.059 -0.731 -0.983

5 

70 W -0.004 -0.003 -0.110 -0.142

150 W 0.029 0.069 0.020 0.108

250 W -0.030 -0.041 -0.253 -0.419

400 W -0.151 -0.234 -0.589 -0.967

1000 W 0.054 0.136 0.143 0.393

1500 W -0.002 -0.002 -0.005 -0.007

Total -0.103 -0.075 -0.794 -1.035

294 
c. Impacts on Employment

DOE estimated the indirect employment impacts of potential standards on the 

economy in general, assuming that energy conservation standards for metal halide lamp 

fixtures will reduce energy bills for fixture users and that the resulting net savings will be 

redirected to other forms of economic activity. DOE used an input/output model of the 

U.S. economy to estimate these effects, including the demand for labor as described in 

section V.J. 

The input/output model results suggest that today’s adopted standards are likely to 

increase the net labor demand. The gains, however, would most likely be small relative to 

total national employment, and neither the BLS data nor the input/output model DOE 

uses includes the quality or wage level of the jobs. As shown in Table VII.41, DOE 

estimates that net indirect employment impacts from adopted fixture standards are small 

relative to the national economy.

Table VII.41 Net Change in Jobs from Indirect Employment Effects Under Fixture 

TSLs

Analysis 

Period 

Year

Trial 

Standard 

Level

Net National Change in Jobs

Low Shipments 

Scenario, Roll-up

High Shipments 

Scenario, Roll-up

2018

1 -60 150

2 -85 260

3 -105 405

4 -405 820

5 -470 705

2022

1 135 650

2 170 945

3 155 1,300

4 65 2,755

5 80 2,655

295 
4. Impact on Utility or Performance of Equipment

As presented in section V.B of this notice, DOE concluded that none of the TSLs 

that were analyzed would reduce the utility or performance of the MHLFs under 

consideration in this rulemaking. Furthermore, manufacturers currently offer ballasts that 

meet or exceed the adopted standards in all equipment classes. (42 U.S.C. 

6295(o)(2)(B)(i)(IV))

5. Impact of Any Lessening of Competition

EPCA directs DOE to consider any lessening of competition that is likely to result 

from standards. It also directs the Attorney General of the United States (Attorney 

General) to determine the impact, if any, of any lessening of competition likely to result 

from a proposed standard and to transmit such determination to the Secretary within 60 

days of the publication of a proposed rule, together with an analysis of the nature and 

extent of the impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)). To assist the Attorney 

General in making a determination for MHLF standards, DOE provided the Department 

of Justice (DOJ) with copies of the NOPR and the TSD for review. DOE received 

comments from DOJ stating the proposed energy conservation standards for MHLFs are 

unlikely to have a significant adverse impact on competition.

6. Need of the Nation to Conserve Energy

An improvement in the energy efficiency of the products subject to today’s rule is 

likely to improve the security of the nation’s energy system by reducing overall demand 

for energy. Reduced electricity demand may also improve the reliability of the electricity 

296 
system. Reductions in national electric generating capacity estimated for each considered 

TSL are reported in chapter 14 of the final rule TSD.

Energy savings from new and amended energy conservation standards for fixtures 

could produce environmental benefits in the form of reduced emissions of air pollutants 

and GHGs associated with electricity production. Table VII.42 and Table VII.43 provide 

DOE’s estimate of cumulative emissions reductions projected to result from the TSLs 

considered in this rulemaking, for the low and high shipment scenarios, respectively. The 

tables include both power sector emissions and upstream emissions. The upstream 

emissions were calculated using the multipliers discussed in section V.L. DOE reports 

annual emissions reductions for each TSL in the emissions analysis in chapter 16 the final 

rule TSD.

297 
Table VII.42 Cumulative Emissions Reduction for Potential Standards for Metal 

Halide Lamp Fixtures (Low Shipments Scenario)

Trial Standard Level

1 2 3 4 5

Power Sector Emissions

 CO2 (million metric tons) 16.80 21.24 21.80 38.30 44.93

 NOX (thousand tons) 8.85 11.18 11.48 20.16 23.64

 Hg (tons) 0.04 0.05 0.05 0.08 0.10

 N2O (thousand tons) 0.36 0.45 0.46 0.81 0.95

 CH4 (thousand tons) 2.04 2.59 2.65 4.66 5.47

 SO2 (thousand tons) 29.48 37.29 38.26 67.25 78.95

Upstream Emissions

 CO2 (million metric tons) 0.98 1.24 1.27 2.23 2.62

 NOX (thousand tons) 13.45 17.01 17.45 30.68 36.00

 Hg (tons) 0.001 0.001 0.001 0.001 0.001

 N2O (thousand tons) 0.01 0.01 0.01 0.02 0.03

 CH4 (thousand tons) 81.69 103.31 106.01 186.34 218.69

 SO2 (thousand tons) 0.21 0.27 0.27 0.48 0.56

Total Emissions

 CO2 (million metric tons) 17.78 22.48 23.07 40.53 47.54

 NOX (thousand tons) 22.29 28.19 28.93 50.84 59.64

 Hg (tons) 0.04 0.05 0.05 0.08 0.10

 N2O (thousand tons) 0.37 0.46 0.47 0.83 0.98

 CH4 (thousand tons) 83.74 105.90 108.66 191.01 224.16

 SO2 (thousand tons) 29.69 37.55 38.53 67.73 79.51

298 
Table VII.43 Cumulative Emissions Reduction for Potential Standards for Metal 

Halide Lamp Fixtures (High Shipments Scenario) 

Trial Standard Level

1 2 3 4 5

Power Sector Emissions

 CO2 (million metric tons) 20.78 26.26 26.95 47.13 55.37

 NOX (thousand tons) 10.89 13.76 14.12 24.69 29.00

 Hg (tons) 0.05 0.06 0.06 0.10 0.12

 N2O (thousand tons) 0.46 0.58 0.60 1.04 1.23

 CH4 (thousand tons) 2.57 3.25 3.33 5.83 6.85

 SO2 (thousand tons) 37.14 46.92 48.15 84.20 99.02

Upstream Emissions

 CO2 (million metric tons) 1.22 1.54 1.59 2.77 3.26

 NOX (thousand tons) 16.83 21.26 21.81 38.16 44.85

 Hg (tons) 0.001 0.001 0.001 0.001 0.002

 N2O (thousand tons) 0.01 0.02 0.02 0.03 0.03

 CH4 (thousand tons) 102.23 129.15 132.54 231.83 272.53

 SO2 (thousand tons) 0.26 0.33 0.34 0.59 0.70

Total Emissions

 CO2 (million metric tons) 22.01 27.80 28.53 49.90 58.63

 NOX (thousand tons) 27.72 35.02 35.93 62.85 73.86

 Hg (tons) 0.05 0.06 0.06 0.10 0.12

 N2O (thousand tons) 0.47 0.60 0.61 1.07 1.26

 CH4 (thousand tons) 104.80 132.40 135.87 237.66 279.39

 SO2 (thousand tons) 37.40 47.25 48.49 84.80 99.72

As discussed in section V.L, DOE did not report SO2 emissions reductions from 

power plants because there is uncertainty about the effect of energy conservation 

standards on the overall level of SO2 emissions in the United States due to new emissions 

standards for power plants under the MATS rule. DOE also did not include NOx

emissions reductions from power plants in states subject to CAIR because an energy 

conservation standard would not affect the overall level of NOx emissions in those states 

due to the emissions caps.

As part the analysis for this final rule, DOE estimated monetary benefits likely to 

result from the reduced emissions of CO2 and NOx that DOE estimated for each of the 

TSLs considered. As discussed in section V.M.1, DOE used values for the SCC 

299 
developed by an interagency process. The interagency group selected four sets of SCC 

values for use in regulatory analyses. Three sets are based on the average SCC from three 

integrated assessment models, at discount rates of 2.5 percent, 3 percent, and 5 percent. 

The fourth set, which represents the 95th-percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from 

temperature change further out in the tails of the SCC distribution. The four SCC values 

for CO2 emissions reductions in 2015, expressed in 2012$, are $11.8/ton, $39.7/ton, 

$61.2/ton, and $117.0/ton. These values for later years are higher due to increasing 

emissions-related costs as the magnitude of projected climate change increases. 

Table VII.44 and Table VII.45 present the global value of CO2 emissions 

reductions at each TSL for the low and high shipment scenarios, respectively. DOE 

calculated domestic values as a range from 7 percent to 23 percent of the global values, 

and these results are presented in chapter 17 of the final rule TSD.

300 
Table VII.44 Global Present Value of CO2 Emissions Reduction for Potential 

Standards for Metal Halide Lamp Fixtures (Low Shipments Scenario) 

TSL

SCC Scenario*

5% discount 

rate, average

3% discount rate, 

average

2.5% discount 

rate, average

3% discount rate, 

95th percentile

million 2012$

Power Sector Emissions

1 109.3 509.9 813.4 1,574.7

2 138.2 644.8 1,028.7 1,991.6

3 141.8 661.8 1,055.7 2,043.9

4 249.2 1,162.7 1,854.8 3,591.3

5 291.9 1,362.9 2,174.5 4,209.8

Upstream Emissions

1 6.2 29.3 46.8 90.6

2 7.9 37.1 59.2 114.6

3 8.1 38.0 60.8 117.6

4 14.2 66.9 106.9 206.8

5 16.6 78.4 125.3 242.5

Total Emissions

1 115 539.2 860.2 1,665.3

2 146 681.9 1,087.9 2,106.2

3 150 699.8 1,116.5 2,161.5

4 263 1,229.6 1,961.7 3,798.1

5 309 1,441.3 2,299.8 4,452.3

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, 

$39.7, $61.2 and $117.0 per metric ton (2012$).

301 
Table VII.45 Global Present Value of CO2 Emissions Reduction for Potential 

Standards for Metal Halide Lamp Fixtures (High Shipments Scenario) 

TSL

SCC Scenario*

5% discount 

rate, average

3% discount rate, 

average

2.5% discount 

rate, average

3% discount rate, 

95th percentile

million 2012$

Power Sector Emissions

1 130.4 617.9 988.6 1,909.5

2 164.8 780.8 1,249.3 2,413.0

3 169.1 801.4 1,282.2 2,476.6

4 296.0 1,402.5 2,243.7 4,334.3

5 347.3 1,646.3 2,634.1 5,088.0

Upstream Emissions

1 7.5 35.9 57.6 111.1

2 9.5 45.4 72.7 140.4

3 9.7 46.6 74.7 144.1

4 17.0 81.5 130.7 252.2

5 20.0 95.7 153.5 296.2

Total Emissions

1 137.9 653.8 1,046.2 2,020.6

2 174.2 826.2 1,322.0 2,553.4

3 178.8 848.0 1,356.8 2,620.7

4 313.1 1,484.0 2,374.3 4,586.5

5 367.2 1,742.1 2,787.6 5,384.2

* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, 

$39.7, $61.2 and $117.0 per metric ton (2012$).

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the potential 

resulting damages to the world economy continues to evolve rapidly. Thus, any value 

placed in this rulemaking on reducing CO2 emissions is subject to change. DOE, together 

with other Federal agencies, will continue to review various methodologies for estimating 

the monetary value of reductions in CO2 and other GHG emissions. This ongoing review 

will consider the comments on this subject that are part of the public record for this and 

other rulemakings, as well as other methodological assumptions and issues. However, 

consistent with DOE’s legal obligations, and taking into account the uncertainty involved 

with this particular issue, DOE has included in this NOPR the most recent values and 

analyses resulting from the ongoing interagency review process.

302 
DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOx and Hg emissions reductions anticipated to result from 

amended metal halide lamp fixture standards. Estimated monetary benefits for CO2 and 

NOx emission reductions are detailed in chapter 17 of the final rule TSD. 

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the customer savings calculated for each TSL 

considered in this rulemaking. The dollar-per-ton values that DOE used are discussed in 

section V.M. Table VII.46 presents the present value of cumulative NOX emissions 

reductions for each TSL calculated using the average dollar-per-ton values and 7-percent 

and 3-percent discount rates.

303 
Table VII.46 Present Value of NOX Emissions Reduction for Potential Standards for 

Metal Halide Lamp Fixtures

TSL

Low Shipments Scenario High Shipments Scenario

3% Discount Rate 7% Discount Rate 3% Discount Rate 7% Discount Rate

million 2012$

Power Sector Emissions

1 12.0 5.8 14.1 6.6

2 15.2 7.4 17.9 8.3

3 15.6 7.6 18.3 8.5

4 27.4 13.3 32.1 14.9

5 32.0 15.5 37.6 17.5

Upstream Emissions

1 17.4 7.9 20.8 9.1

2 22.0 10.0 26.3 11.4

3 22.6 10.2 27.0 11.7

4 39.7 18.0 47.3 20.6

5 46.5 21.0 55.5 24.1

Total Emissions

1 29.4 13.7 35.0 15.6

2 37.2 17.3 44.2 19.8

3 38.2 17.8 45.4 20.3

4 67.0 31.2 79.4 35.5

5 78.5 36.5 93.1 41.6

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the customer savings calculated for each TSL 

considered in this rulemaking. Table VII.47 and Table VII.48 present the NPV values 

that result from adding the estimates of the potential economic benefits resulting from 

reduced CO2 and NOX emissions in each of four valuation scenarios to the NPV of 

customer savings calculated for each TSL considered in this rulemaking, at both a 7-

percent and a 3-percent discount rate, and for the low and high shipment scenarios, 

respectively. The CO2 values used in the columns of each table correspond to the four 

scenarios for the valuation of CO2 emission reductions discussed above.

304 
Table VII.47 Metal Halide Lamp Fixture TSLs: Net Present Value of Customer 

Savings Combined with Net Present Value of Monetized Benefits from CO2 and 

NOX Emissions Reductions (Low Shipments Scenario)

TSL

Customer NPV at 3% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium 

Value for NOX

**

billion 2012$

1 0.928 1.352 1.673 2.478

2 1.099 1.634 2.040 3.059

3 1.084 1.634 2.051 3.096

4 -0.712 0.255 0.987 2.823

5 -0.724 0.409 1.268 3.420

TSL

Customer NPV at 7% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium 

Value for NOX

**

billion 2012$

1 0.386 0.810 1.131 1.936

2 0.452 0.988 1.394 2.412

3 0.435 0.985 1.402 2.447

4 -0.518 0.449 1.181 3.017

5 -0.553 0.580 1.439 3.591 * These label values represent the global SCC in 2015, in 2012$. The present values have been calculated 

with scenario-consistent discount rates. ** Medium Value corresponds to $2,639 per ton of NOX emissions. 

305 
Table VII.48 Metal Halide Lamp Fixture TSLs: Net Present Value of Customer 

Savings Combined with Net Present Value of Monetized Benefits from CO2 and 

NOX Emissions Reductions (High Shipments Scenario)

TSL

Customer NPV at 3% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium 

Value for NOX

**

billion 2012$

1 1.141 1.657 2.049 3.024

2 1.353 2.005 2.501 3.732

3 1.338 2.008 2.516 3.780

4 -0.790 0.380 1.271 3.483

5 -0.792 0.583 1.628 4.225

TSL

Customer NPV at 7% Discount Rate added with:

SCC Value of 

$11.8/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$39.7/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$61.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Value of 

$117.0/metric ton 

CO2

* and Medium 

Value for NOX

**

billion 2012$

1 0.458 0.974 1.366 2.340

2 0.537 1.189 1.685 2.916

3 0.518 1.188 1.696 2.960

4 -0.561 0.610 1.500 3.712

5 -0.595 0.780 1.825 4.422 * These label values represent the global SCC in 2015, in 2012$. The present values have been calculated 

with scenario-consistent discount rates. ** Medium Value corresponds to $2,639 per ton of NOX emissions. 

Although adding the value of customer savings to the values of emission 

reductions provides a valuable perspective, the following should be considered: (1) the 

national customer savings are domestic U.S. customer monetary savings found in market 

transactions, while the values of emissions reductions are based on estimates of marginal 

social costs, which, in the case of CO2, are based on a global value; and (2) the 

assessments of customer savings and emissions-related benefits are performed with 

different computer models, leading to different time frames for analysis. For fixtures, the 

present value of national customer savings is measured for the period in which units 

shipped in 2017–2046 continue to operate. The SCC values, on the other hand, reflect the 

306 
present value of future climate-related impacts resulting from the emission of one metric 

ton of CO2 in each year. These impacts continue well beyond 2100.

C. Conclusions

DOE is subject to the EPCA requirement that any new or amended energy 

conservation standard for any type (or class) of covered equipment be designed to 

achieve the maximum improvement in energy efficiency that the Secretary determines is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In 

determining whether a standard is economically justified, the Secretary must determine 

whether the benefits of the standard exceed its burdens to the greatest extent practicable, 

in light of the seven statutory factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) 

The new or amended standard must also result in a significant conservation of energy. 

(42 U.S.C. 6295(o)(3)(B)) 

DOE considered the impacts of MHLF standards at each trial standard level, 

beginning with the max-tech level, to determine whether that level met the evaluation 

criteria. If the max-tech level was not justified, DOE then considered the next most 

efficient level and undertook the same evaluation until it reached the highest efficiency 

level that is both technologically feasible and economically justified and saves a 

significant amount of energy. 

DOE discusses the benefits and/or burdens of each trial standard level in the 

following sections based on the quantitative analytical results for each trial standard level 

(presented in section VII.A) such as national energy savings, net present value 

307 
(discounted at 7 and 3 percent), emissions reductions, industry net present value, lifecycle cost, and customers’ installed price increases. Beyond the quantitative results, DOE 

also considers other burdens and benefits that affect economic justification, including 

how technological feasibility, manufacturer costs, and impacts on competition may affect 

the economic results presented.

To aid the reader as DOE discusses the benefits and burdens of each trial standard 

level, DOE has included the following tables (Table VII.49 and Table VII.50) that 

summarize DOE’s quantitative analysis for each TSL. In addition to the quantitative 

results presented in the tables, DOE also considers other burdens and benefits that affect 

economic justification. Section VII.B.1 presents the estimated impacts of each TSL for 

the LCC subgroup analysis. 

Table VII.49 Summary of Results for Metal Halide Lamp Fixtures (Low-Shipments 

Scenario) 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

National Energy Savings (quads) 0.31 0.39 0.40 0.71 0.83

NPV of Customer Benefits (2012$ billion)

3% discount rate 0.78 0.92 0.90 (1.04) (1.11)

7% discount rate 0.26 0.29 0.27 (0.81) (0.90)

Industry Impacts*

Ballast + Fixture Industry NPV 

(2012$million)

(Base Case Industry NPV of $413 million) 393 391 390 336 305 

Ballast + Fixture Industry NPV 

(change in 2012$million) (20.1) (21.5) (22.6) (76.6) (107.5)

Ballast + Fixture Industry NPV (% change) -4.9% -5.2% -5.5% -18.6% -26.1%

Cumulative Emissions Reduction

CO2 (Mt) 17.78 22.48 23.07 40.53 47.54

SO2 (kt) 29.69 37.55 38.53 67.73 79.51

NOx (kt) 22.29 28.19 28.93 50.84 59.64

Hg (t) 0.04 0.05 0.05 0.08 0.10

CH4 (kt) 83.74 105.90 108.66 191.01 224.16

N2O (kt) 0.37 0.46 0.47 0.83 0.98

Value of Cumulative Emissions Reduction

CO2 (2012$ billion)** 0.1 to 1.7 0.1 to 2.1 0.1 to 2.2 0.3 to 3.8 0.3 to 4.5

308 
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

NOx – 3% discount rate (2012$ million)** 29.4 37.2 38.2 67.0 78.5

NOx – 7% discount rate (2012$ million)** 13.7 17.3 17.8 31.2 36.5

Mean LCC Savings (and Percent Customers Experiencing Net Benefit)*** (2012$)

50to100W_Ind_OtherV****†

(magnetic baseline)

26.97

(100)

27.00

(100)

27.00

(100)

42.50

(82)

37.25

(79)

50to100W_Outd_OtherV

(magnetic baseline)

34.24

(98)

34.88

(97)

34.88

(97)

-4.98

(51)

-11.15

(49)

50to100W_Ind_OtherV

(electronic baseline) --- --- --- --- -5.25(10)

50to100W_Outd_OtherV

(electronic baseline) --- --- --- --- -6.17(12)

101to150W_Ind_OtherV‡ 22.43

(100)

24.63

(99)

24.63

(99)

89.67

(94)

76.11

(89)

101to150W_Outd_OtherV 27.37

(97)

30.70

(97)

30.70

(97)

52.23

(66)

36.60

(62)

151to250W_Ind_OtherV‡ 4.51

(60)

4.51

(60)

-1.07

(37)

-59.67

(18)

-40.33

(29)

151to250W_Outd_OtherV 6.74

(67)

6.74

(67)

1.48

(45)

-119.65

(24)

-97.86

(29)

251to500W_Ind_OtherV 2.83

(47)

7.95

(54)

7.95

(54)

-107.74

(8)

130.60

(6)

251to500W_Outd_OtherV 6.16

(55)

13.15

(62)

13.15

(62)

-165.30

(19)

-187.69

(16)

501to1000W_Ind_OtherV 1221.54

(100)

1221.54

(100)

1221.54

(100)

1221.54

(100)

1221.54

(100)

501to1000W_Outd_OtherV 1631.94

(98)

1631.94

(98)

1631.94

(98)

1631.94

(98)

1631.94

(98)

1001to2000W_Ind_OtherV --- --- --- -67.15

(0)

-93.06

(0)

1001to2000W_Outd_OtherV --- --- --- -63.71

(0)

-88.03

(0)

Median PBP (years)

50to100W_Ind_OtherV

(magnetic baseline) 1.4 4.5 4.5 3.7 6.0

50to100W_Outd_OtherV

(magnetic baseline) 1.4 4.5 4.5 12.0 14.7

50to100W_Ind_OtherV

(electronic baseline) --- --- --- --- 31.5

50to100W_Outd_OtherV

(electronic baseline) --- --- --- --- 55.8

101to150W_Ind_OtherV‡ 4.3 7.3 7.3 2.5 4.8

101to150W_Outd_OtherV 4.5 8.1 8.1 7.5 10.3

151to250W_Ind_OtherV‡ 14.2 14.2 17.9 113.2 38.4

151to250W_Outd_OtherV 17.4 17.4 22.8 326.7 135.1

251to500W_Ind_OtherV 16.2 15.0 15.0 369.2 137.2

251to500W_Outd_OtherV 19.9 18.4 18.4 Never Never

501to1000W_Ind_OtherV 0.8 0.8 0.8 0.8 0.8

501to1000W_Outd_OtherV 0.8 0.8 0.8 0.8 0.8

1001to2000W_Ind_OtherV --- --- --- 209.4 162.7

1001to2000W_Outd_OtherV --- --- --- 244.5 190.0

Employment Impacts

Direct Employment Impacts 47 –

(339)

62 –

(339)

69 –

(339)

73 –

(339)

93 –

(339)

309 
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Indirect Domestic Jobs|| 135 170 155 65 80

* INPV results are shown under the preservation of operating profit markup scenario.

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2

emissions. Economic value of NOX reductions is based on estimates at $2639/ton. 

*** For LCCs, a negative value means an increase in LCC by the amount indicated.

**** “Indoor” and “outdoor” as defined in section V.A.2. 

† Equipment class abbreviations in the form of 50 to100W_Ind_OtherV refers to the equipment class of fixtures with 

(1) a rated lamp wattage of 50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 

480 V. See section V.A.2 for more detail on equipment class distinctions.

‡ The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures 

rated only for 150 watt lamps that are also rated for use in wet locations, as specified by the NFPA 70-2002, section 

410.4(A) and contain a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 

1029–2007. The ≥150 W and ≤250 W equipment classes contain all other covered fixtures that are rated only for 150 

watt lamps.

|| Changes in 2022.

Table VII.50 Summary of Results for Metal Halide Lamp Fixtures (High-Shipments 

Scenario)

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

National Energy Savings (quads) 0.39 0.49 0.50 0.88 1.03

NPV of Customer Benefits (2012$ billion)

3% discount rate 0.97 1.13 1.11 (1.18) (1.25)

7% discount rate 0.30 0.34 0.32 (0.91) (1.00)

Industry Impacts*

Ballast + Fixture Industry NPV 

(2012$million)

(Base Case Industry NPV of $453 million) 478 491 497 501 497 

Ballast + Fixture Industry NPV 

(change in 2012$million) 25.3 38.0 44.0 48.1 44.2

Ballast + Fixture Industry NPV (% change) 5.6% 8.4% 9.7% 10.6% 9.7%

Cumulative Emissions Reduction

CO2 (Mt) 22.01 27.80 28.53 49.90 58.63

SO2 (kt) 37.40 47.25 48.49 84.80 99.72

NOx (kt) 27.72 35.02 35.93 62.85 73.86

Hg (t) 0.05 0.06 0.06 0.10 0.12

CH4 (kt) 104.80 132.40 135.87 237.66 279.39

N2O (kt) 0.47 0.60 0.61 1.07 1.26

Value of Cumulative Emissions Reduction

CO2 (2012$ billion)** 0.1 to 2.0 0.2 to 2.6 0.2 to 2.6 0.3 to 4.6 0.4 to 5.4

NOx – 3% discount rate (2012$ million)** 35.0 44.2 45.4 79.4 93.1

NOx – 7% discount rate (2012$ million)** 15.6 19.8 20.3 35.5 41.6

Mean LCC Savings (and Percent Customers Experiencing Net Benefit)*** (2012$)

50to100W_Ind_OtherV****†

(magnetic baseline)

26.97

(100)

27.00

(100)

27.00

(100)

42.50

(82)

37.25

(79)

50to100W_Outd_OtherV

(magnetic baseline)

34.24

(98)

34.88

(97)

34.88

(97)

-4.98

(51)

-11.15

(49)

50to100W_Ind_OtherV

(electronic baseline) --- --- --- --- -5.25(10)

50to100W_Outd_OtherV

(electronic baseline) --- --- --- --- -6.17(12)

100to149W_Ind_OtherV‡ 22.43

(100)

24.63

(99)

24.63

(99)

89.67

(94)

76.11

(89)

100to149W_Outd_OtherV 27.37 30.70 30.70 52.23 36.60

310 
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

(97) (97) (97) (66) (62)

150to250W_Ind_OtherV‡ 4.51

(60)

4.51

(60)

-1.07

(37)

-59.67

(18)

-40.33

(29)

150to250W_Outd_OtherV 6.74

(67)

6.74

(67)

1.48

(45)

-119.65

(24)

-97.86

(29)

251to500W_Ind_OtherV 2.83

(47)

7.95

(54)

7.95

(54)

-107.74

(8)

130.60

(6)

251to500W_Outd_OtherV 6.16

(55)

13.15

(62)

13.15

(62)

-165.30

(19)

-187.69

(16)

501to1000W_Ind_OtherV 1221.54

(100)

1221.54

(100)

1221.54

(100)

1221.54

(100)

1221.54

(100)

501to1000W_Outd_OtherV 1631.94

(98)

1631.94

(98)

1631.94

(98)

1631.94

(98)

1631.94

(98)

1001to2000W_Ind_OtherV --- --- --- -67.15

(0)

-93.06

(0)

1001to2000W_Outd_OtherV --- --- --- -63.71

(0)

-88.03

(0)

Median PBP (years)

50to100W_Ind_OtherV

(magnetic baseline) 1.4 4.5 4.5 3.7 6.0

50to100W_Outd_OtherV

(magnetic baseline) 1.4 4.5 4.5 12.0 14.7

50to100W_Ind_OtherV

(electronic baseline) --- --- --- --- 31.5

50to100W_Outd_OtherV

(electronic baseline) --- --- --- --- 55.8

100to149W_Ind_OtherV‡ 4.3 7.3 7.3 2.5 4.8

100to149W_Outd_OtherV 4.5 8.1 8.1 7.5 10.3

150to25W0_Ind_OtherV‡ 14.2 14.2 17.9 113.2 38.4

150to250W_Outd_OtherV 17.4 17.4 22.8 326.7 135.1

251to500W_Ind_OtherV 16.2 15.0 15.0 369.2 137.2

251to500W_Outd_OtherV 19.9 18.4 18.4 Never Never

501to1000W_Ind_OtherV 0.8 0.8 0.8 0.8 0.8

501to1000W_Outd_OtherV 0.8 0.8 0.8 0.8 0.8

1001to2000W_Ind_OtherV --- --- --- 209.4 162.7

1001to2000W_Outd_OtherV --- --- --- 244.5 190.0

Employment Impacts

Direct Employment Impacts 48 –

(345)

63 –

(345)

70 –

(345)

74 –

(345)

95 –

(345)

Indirect Domestic Jobs|| 650 945 1300 2755 2655

* INPV results are shown under the -flat markup scenario.

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2

emissions. Economic value of NOX reductions is based on estimates at $2,639/ton.

*** For LCCs, a negative value means an increase in LCC by the amount indicated.

**** “Indoor” and “outdoor” as defined in section V.A.2. 

† Equipment class abbreviations in the form of 50 to100W_Ind_OtherV refers to the equipment class of fixtures with 

(1) a rated lamp wattage of 50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 

480 V. See section V.A.2 for more detail on equipment class distinctions.

‡ The >100 W and ≤150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures 

rated only for 150 watt lamps that are also rated for use in wet locations, as specified by the NFPA 70-2002, section 

410.4(A) and contain a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 

1029–2007. The ≥150 W and ≤250 W equipment classes contain all other covered fixtures that are rated only for 150 

watt lamps.

|| Changes in 2022.

311 
1. Trial Standard Level 5

DOE first considered the most efficient level, TSL 5, which would save an 

estimated total of 0.83 to 1.03 quads of energy for fixtures shipped in 2017 through 2046, 

a significant amount of energy. For the nation as a whole, TSL 5 would have net costs 

ranging from a decrease of $0.90 billion to a decrease of $1.0 billion at a 7-percent 

discount rate, and a decrease of $1.1 billion to a decrease of $1.3 billion at a 3-percent 

discount rate. The emissions reductions at TSL 5 are estimated to be 48 to 59 million 

metric tons (Mt) of CO2, 80 to 100 kt of SO2, 60 to 74 kt of NOx, and 0.10 to 0.12 tons of 

Hg. As seen in section VII.B.1, customers have available designs that result in positive 

mean LCC savings for a majority of customers for only five out of twelve of the 

representative equipment classes, ranging from $37 to $1632, at TSL 5. The equipment 

classes with positive mean LCC savings for a majority of customers at TSL 5 are indoor 

fixtures at 70 W (compared to the magnetic 70 W baseline), 150 W, and 1000 W; and 

outdoor fixtures at 150 W and 1000 W. Additionally, DOE’s NPV analysis indicates (see 

Table VII.49) that most equipment classes experience a negative NPV at TSL 5. The 

equipment classes that have negative NPV at TSL 5 are indoor and outdoor 70 W, 250 

W, 400 W, and 1500 W fixtures. The equipment classes with positive NPV at TSL 5 are 

indoor and outdoor 150 W and 1000 W fixtures. The projected change in industry value 

for MH ballast manufacturers would range from an increase of $15.0 million to a 

decrease of $19.0 million, or a net gain of 20.3 percent to a net loss of 28.3 percent in 

INPV. The projected change in industry value for MHLF manufacturers would range 

from an increase of $29.1 million to a decrease of $88.6 million, or a net gain of 7.7 

percent to a net loss of 25.6 percent in INPV.

312 
DOE based TSL 5 on the most efficient commercially available equipment for 

each representative equipment class analyzed. This TSL corresponds to a commercially 

available low-frequency electronic ballast for indoor and outdoor 70 W, 150 W, 250 W, 

400 W fixtures, and a modeled magnetic ballast in 1000 W and 1500 W. TSL 5 also 

prohibits the use of probe-start ballasts in new 1000 W fixtures. 

Although TSL 5 for 150 W MHLFs shows positive LCC savings and NPVs, DOE 

believes uncertainty remains regarding the cost effectiveness of electronic ballasts for 

these customers, especially in outdoor applications. There has been virtually no market 

penetration of electronic ballasts in outdoor applications according to DOE’s shipment 

analysis. Further, DOE received comments from manufacturers and utilities that 

electronic ballasts are not suitable for outdoor applications due to their lower operating 

temperature limits, different sizes compared to magnetic ballasts, and susceptibility to 

transient voltage fluctuations. DOE has conducted significant research to address each 

one of these issues (see section V.C.8.b), but remains concerned that requiring electronic 

ballasts for 150 W MHLFs could cause disproportionate financial hardship for these 

customers. Therefore, DOE is not adopting an efficiency level that requires electronic 

ballasts in this final rule. DOE will continue to monitor the market share of electronic 

ballasts, particularly in outdoor applications, and may revisit this decision in future 

rulemakings.

After considering the analysis, the comments that DOE received on the NOPR, 

and the benefits and burdens of TSL 5, the Secretary has reached the following 

conclusion: the benefits of energy savings, emissions reductions (both in physical 

313 
reductions and the monetized value of those reductions), and positive net economic 

savings to the nation for some equipment classes are outweighed by the negative NPV 

experienced in some equipment classes at both a 3-percent and 7-percent discount rate, 

the negative mean LCC savings experienced in most equipment classes, the negative 

mean LCC savings experienced by some customer subgroups, the potential decrease in 

INPV for manufacturers, and the uncertainty regarding electronic ballasts. Consequently, 

the Secretary has concluded that TSL 5 is not economically justified. 

2. Trial Standard Level 4

DOE then considered TSL 4, which would save an estimated total of 0.71 to 0.88 

quads of energy for fixtures shipped in 2017 through 2046, a significant amount of 

energy. For the nation as a whole, TSL 4 would have net costs ranging from a decrease of 

$0.81 billion to a decrease of $0.91 billion at a 7-percent discount rate, and a decrease of 

$1.0 billion to a decrease of $1.2 billion at a 3-percent discount rate. The emissions 

reduction at TSL 4 are estimated to be 41 to 50 Mt of CO2, 68 to 85 kt of SO2, 51 to 63 kt 

of NOx, and 0.08 to 0.10 tons of Hg. As seen in section VII.B.1, for less than half of the 

representative equipment classes, customers have available designs that result in positive 

mean LCC savings for a majority of customers, ranging from $43 to $1632, at TSL 4. 

Additionally, DOE’s NPV analysis indicates (see Table VI.34) that less than half of the 

representative classes have a positive NPV at TSL 4. The projected change in industry 

value for MH ballast manufacturers would range from an increase of $9.6 million to a 

decrease of $16.2 million, or a net gain of 12.9 percent to a net loss of 24.1 percent in 

INPV. The projected change in industry value for MHLF manufacturers would range 

314 
from an increase of $38.6 million to a decrease of $60.4 million, or a net gain of 10.2 

percent to a net loss of 17.5 percent in INPV.

TSL 4 represents the next highest EL for all equipment classes not justified at 

TSL 5. This TSL corresponds to a commercially available low-frequency electronic 

ballast in indoor and outdoor 70 W, 150 W, 250 W, and 400 W fixtures; a commercially 

available magnetic ballast in indoor and outdoor 1500 W fixtures; and a modeled 

magnetic ballast in indoor and outdoor 1000 W fixtures. TSL 4 also prohibits the use of 

probe-start ballasts in new 1000 W fixtures.

Although TSL 4 for 150 W MHLFs shows positive LCC savings and NPVs, DOE 

believes uncertainty remains regarding the cost effectiveness of electronic ballasts for 

these customers, especially in outdoor applications. There has been virtually no market 

penetration of electronic ballasts in outdoor applications according to DOE’s shipment 

analysis. Further, DOE received comments from manufacturers and utilities that 

electronic ballasts are not suitable for outdoor applications due to their lower operating 

temperature limits, different sizes compared to magnetic ballasts, and susceptibility to 

transient voltage fluctuations. DOE has conducted significant research to address each 

one of these issues (see section V.C.8.b), but remains concerned that requiring electronic 

ballasts for 150 W MHLFs could cause disproportionate financial hardship for these 

customers. Therefore, DOE is not adopting an efficiency level that requires electronic 

ballasts in this final rule. DOE will continue to monitor the market share of electronic 

ballasts, particularly in outdoor applications, and may revisit this decision in future 

rulemakings. 

315 
After considering the analysis, the comments that DOE received on the NOPR, 

and the benefits and burdens of TSL 4, the Secretary has reached the following 

conclusion: at TSL 4, the benefits of energy savings, emissions reductions (both in 

physical reductions and the monetized value of those reductions), and positive net 

economic savings to the nation are outweighed by negative NPV experienced in some 

equipment classes at both 3-percent and 7-percent discount rate, the negative mean LCC 

savings experienced in some equipment classes, the negative mean LCC savings for the 

utility customer subgroup, the potential decrease in INPV for manufacturers, and the 

uncertainty regarding electronic ballasts. Consequently, the Secretary has concluded that 

TSL 4 is not economically justified.

3. Trial Standard Level 3

DOE then considered TSL 3, which would save an estimated total of 0.40 to 0.50 

quads of energy for fixtures shipped in 2017 through 2046, a significant amount of 

energy. For the nation as a whole, TSL 3 would have positive net savings of $0.27 billion

to $0.32 billion at a 7-percent discount rate and $0.90 billion to $1.1 billion at a 3-percent 

discount rate. The emissions reductions at TSL 3 are estimated to be 23 to 29 Mt of CO2, 

39 to 48 kt of SO2, 29 to 36 kt of NOx, and 0.05 to 0.06 tons of Hg. As seen in section

VII.B.1, for most representative equipment classes, customers have available designs that 

result in positive mean LCC savings, ranging from $8 to $1632, at TSL 3. DOE’s NPV 

analysis indicates (see Table VI.34) that most equipment classes have a positive NPV at 

TSL 3, though indoor and outdoor 250 W customers experience negative NPV. The 

projected change in industry value for MH ballast manufacturers would range from an 

316 
increase of $0.6 million to a decrease of $19.0 million, or a net gain of 0.8 percent to a 

net loss of 28.3 percent in INPV. The projected change in industry value for MHLF 

manufacturers would range from an increase of $43.4 million to a decrease of $3.6 

million, or a net gain of 11.4 percent to a net loss of 1.1 percent in INPV.

TSL 3 represents the next highest EL for all equipment classes not justified at 

TSL 4, requiring that indoor and outdoor fixtures are set at the same ELs. This TSL 

corresponds to a modeled magnetic ballast in indoor and outdoor fixtures at 70 W, 150 

W, 250 W, 400 W, and 1000 W. Indoor and outdoor fixtures at 1500 W would remain at 

baseline, with no new standards established. TSL 3 also prohibits the use of probe-start 

ballasts in new 1000 W fixtures.

After considering the analysis, the comments that DOE received on the 

preliminary analysis, and the benefits and burdens of TSL 3, the Secretary has reached 

the following conclusion: at TSL 3, the benefits of energy savings, emissions reductions 

(both in physical reductions and monetized value of those reductions), and positive net 

economic savings to the nation would be outweighed by the negative NPV experienced in 

the 250 W indoor and outdoor equipment classes at 7-percent discount rate and the 

potential decrease in INPV for manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

4. Trial Standard Level 2

DOE then considered TSL 2, which would save an estimated total of 0.39 to 0.49 

quads of energy for fixtures shipped in 2017 through 2046, a significant amount of 

317 
energy. For the nation as a whole, TSL 2 would have a positive net savings of $0.29 

billion to $0.34 billion at a 7-percent discount rate, and $0.92 billion to $1.1 billion at a 

3-percent discount rate. The emissions reductions at TSL 3 are estimated to be 23 to 28 

Mt of CO2, approximately 38 to 47 kt of SO2, 28 to 35 kt of NOx, and 0.05 to 0.06 tons of 

Hg. As seen in section VII.B.1, for all representative equipment classes, customers have 

available designs that result in positive mean LCC savings, ranging from $5 to $1632, at 

TSL 2. DOE’s NPV analysis indicates (see Table VI.34) that each equipment class has a 

positive NPV at TSL 2. The projected change in industry value for MH ballast 

manufacturers would range from a decrease of $0.4 million to a decrease of $17.9 

million, or a net loss from 0.5 percent to 26.7 percent in INPV. The projected change in 

industry value for MHLF manufacturers would range from an increase of $38.3 million to 

a decrease of $3.6 million, or a net gain of 10.1 percent to net loss of 1.0 percent in 

INPV.

TSL 2 represents the highest magnetic ELs with a positive NPV, where the same 

ELs are required for indoor and outdoor fixtures. This TSL corresponds to a modeled 

magnetic ballast in 70 W, 150 W, 400 W, and 1000 W; and a commercially available 

magnetic ballast in 250 W. Indoor and outdoor fixtures at 1500 W would remain at 

baseline, with no new standards set. TSL 2 also prohibits the use of probe-start ballasts in 

new 1000 W fixtures.

After considering the analysis, the comments that DOE received on the NOPR, 

and the benefits and burdens of TSL 2, the Secretary has reached the following 

conclusion: TSL 2 offers the maximum improvement in efficiency that is technologically 

318 
feasible and economically justified, and will result in significant conservation of energy. 

The benefits of energy savings, emissions reductions (both in physical reductions and the 

monetized value of those reductions), positive net economic savings (NPV) at discount 

rates of 3-percent and 7-percent at each representative equipment class would outweigh 

the potential reduction in INPV for manufacturers. Therefore, DOE today adopts energy 

conservation standards for metal halide lamp fixtures at TSL 2.

D. Final Standard Equations 

As detailed in section VII.C of this notice, DOE is adopting TSL 2. TSL 2 sets an 

EL2 standard for indoor and outdoor metal halide fixtures for 50 W – 150 W and 251 W 

– 1000 W, and an EL1 standard for indoor and outdoor metal halide fixtures for 151 W – 

250 W. This creates a discontinuous combination of equations both above and below the

151 W – 250 W equipment class. The discontinuity at 150 W occurs because fixtures 

below 150 W do not have to comply with EISA 2007, while those at 150 W and above 

are required to meet the 88 percent standard of EISA 2007. However, the discontinuity at 

250 W occurs because TSL 2 represents EL1 from 151 W – 250 W, but EL2 from 251 W 

– 500 W. To maintain continuity, DOE developed new equations from 151 W – 500 W. 

First, from 151 W – 200 W, DOE maintained a flat 88 percent requirement. Then, from 

201 W – 500 W, DOE used one continuous power-law equation. Based on written 

comments from NEMA, lamps in this wattage range follow the same trend between lamp 

current squared (an indicator of ballast losses) and lamp wattage. (NEMA, No. 56 at p. 

15) This implies that one equation can be used to represent the efficiency of all ballasts in 

this wattage range. The equation was created by connecting the 200 W ballasts with 

0.880 efficiency with the 500 W EL2 efficiency (0.910) to ensure continuity with the EL 

319 
equations for adjacent wattage ranges. The 250 W EL1 and 400 W EL2 representative 

units comply with the new equation. The resulting TSL 2 equations are shown in Table 

VII.51 below. 

Table VII.51 TSL Equation

Wattage Range Efficiency Level EL Equation TSL Equation

≥50 W and ≤100 W EL2 1/(1+1.24*×P^(-0.351)) † 1/(1+1.24*×P^(-0.351)) 

>100 W and <150 W* EL2 1/(1+1.24*×P^(-0.351)) 1/(1+1.24*×P^(-0.351))

≥150 W** and ≤250 W EL1

≥150 W and ≤200 W: 0.88 

>200 W and ≤250 W: 

0.000400*×P + 0.800

≥150 W and ≤200 W: 0.88 

>200 W and ≤250 W: 

1/(1+0.876*×P^(-0.351)) 

>250 W and ≤500 W EL2 0.910 1/(1+0.876*×P^(-0.351)) 

>500 W and ≤1000 W EL2

>500 W and ≤750 W: 0.910

>750 W and ≤1000 W:

0.000104*×P + 0.832

>500 W and ≤750 W: 0.910

>750 W and ≤1000 W:

0.000104*×P + 0.832

*Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use 

in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for 

use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.

†P is defined as the rated wattage of the lamp the MHLF is designed to operate.

DOE also created a continuous TSL equation for the non-representative 

equipment classes. As discussed in section V.C.11, the scaling factor to equipment 

classes tested at 480 V from equipment classes tested at all other voltages is 0.020 from 

50 W – 150 W and 0.010 from 151 W – 1000 W. DOE applied these scaling factors to 

develop equations for non-representative equipment classes, with the exception of the 

151 W – 250 W and 251 W – 500 W equipment classes. For wattages from 201 W – 264 

W, the scaled equation would be below 0.880. As detailed in section VII.E, DOE cannot 

adopt a standard below 0.880 for fixtures covered by EISA 2007. Thus the scaled TSL 

equation was adjusted to be 0.880 from 201 – 264 W, and the scaled equation is 

Comment [AGA17]: Change requested by 

OIRA.

320 
calculated as described previously at 265 W and above. The scaled TSL equation is 

shown in Table VII.52 below.

Table VII.52 TSL Equation

Wattage Range Efficiency Level TSL Equation†

≥50 W and ≤100 W EL2 (1/(1+1.24*×P^(-0.351)) – 0.0200)

>100 W and <150 W* EL2 (1/(1+1.24*×P^(-0.351)) – 0.0200)

≥150 W** and ≤250 W EL1 0.880

>250 W and ≤500 W EL2 >250 W and <265 W: 0.880

≥265 W and ≤500 W: (1/(1+0.876*×P^(-0.351)) – 0.0100

>500 W and ≤1000 W EL2 >500 W and ≤750 W: 0.900

>750 W and ≤1000 W: 0.000104*×P + 0.822

*Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007. 

**Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated 

for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that 

is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.

†P is defined as the rated wattage of the lamp the MHLF is designed to operate.

 

E. Backsliding

As discussed in section II.A of this notice, EPCA contains what is commonly 

known as an “anti-backsliding” provision, which mandates that the Secretary not 

prescribe any amended standard that either increases the maximum allowable energy use 

or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 

6295(o)(1)) DOE evaluated amended standards in terms of ballast efficiency, which is the 

same metric that is currently used in energy conservation standards. Therefore, DOE 

compared the existing standards directly to the amended standards to confirm that they do 

not constitute backsliding.

The existing standards for ballast efficiency for MHLFs, established by EISA 

2007, mandated that ballasts rated at wattages 150 W – 500 W operate at a minimum of 

Comment [AGA18]: Change requested by 

OIRA.

321 
88 percent efficiency if pulse-start, 94 percent if probe-start magnetic, 90 percent if nonpulse-start electronic 150 W – 250 W, and 92 percent if non-pulse-start electronic 251 W 

– 500 W. These standards excluded fixtures with regulated-lag ballasts, fixtures that use 

480 V electronic ballasts, and fixtures that (1) are only rated for use with 150 W lamps; 

(2) are rated for use in wet locations; and (3) contain a ballast that is rated to operate 

above 50 °C. This rulemaking adopts standards for fixtures with ballasts rated at 50 W – 

1000 W, retains the exemptions for fixtures with regulated-lag ballasts or 480 V 

electronic ballasts, and removes the exemption for 150 W fixtures used in wet locations 

with ballasts rated that operate above 50 °C.

The Northwest Power and Conservation Council (NPCC) commented that 

because certain 150 W fixtures were exempt from EISA 2007, backsliding should not be 

a concern in this category. (NPCC, Public Meeting Transcript, No. 48 at pp. 112-114) 

DOE agrees with NPCC’s assertion that backsliding is not an issue for 150 W fixtures

rated for use with 150 W lamps, rated for wet locations, and rated to operate at 

temperatures greater than 50 °C. These exempted fixtures, along with fixtures that fall 

within wattage ranges that do not have existing federal energy conservation standards, 

cannot violate the backsliding provision as no standard currently exists.

As presented in the following table, DOE’s adopted efficiency standards do not 

qualify as backsliding. In the 50 W – 150 W68 range, there are no existing federal 

68 This wattage range contains those fixtures that are rated only for 150 W lamps that are also rated for use 

in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and contain a ballast that is rated to 

operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.

322 

 
efficiency standards. Thus, the standards set by DOE in this rulemaking for this wattage 

range are not backsliding, as they are prescribing a standard where there previously was 

not one. As stated previously, the 150 W ballasts currently exempted by EISA 2007 

(those only rated for use with 150 W lamps, rated for wet locations, and rated to operate 

at temperatures greater than 50 °C) are not covered by any existing federal energy 

conservation standards, so the standards set for such ballasts are likewise not subject to 

backsliding. Similarly, in the 500 W – 1000 W range, there are no existing federal energy 

conservation standards, so standards adopted in this rulemaking for that wattage range do 

not backslide. Finally, for the 150 W69 – 500 W range (not including the exempt 150 W 

fixtures), EISA 2007 prescribes the current standards. DOE is amending the standards for 

fixtures in this wattage range. The adopted standard changes with wattage, but always 

requires ballasts in new fixtures to be at least 88 percent efficient (88 percent efficiency 

for pulse-start ballasts is the least stringent of the various EISA 2007 requirements). If 

DOE’s plotted efficiency level was lower than the standard prescribed by EISA 2007 for 

any ballast types or wattages (e.g., 94 percent efficiency requirement for probe-start 

ballasts), then the EISA 2007 standard was given precedence and has been incorporated 

into today’s rule without amendment, thus preventing any potential backsliding.

On the basis of this section, the standards adopted in this final rule are either 

higher than the existing standards, primarily because they set standards for previously 

unregulated fixtures, or match existing standards because if the EISA 2007 standards 

69 This wattage range contains all covered fixtures that are rated only for 150 W lamps that are not also 

rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and do not also contain 

a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.

323 

 
were higher than the efficiency levels calculated by DOE, then the EISA 2007 standard is 

retained. As such, the adopted standards do not decrease the minimum required energy 

efficiency of the covered equipment and, therefore, do not violate the anti-backsliding 

provision in EPCA.

Table VII.53 Existing Federal Efficiency Standards and Efficiency Standards 

Adopted in this Final Rule

Designed to be 

Operated with 

Lamps of the 

Following Rated 

Lamp Wattage

Indoor/ 

Outdoor***

Test 

Input 

Voltage‡

Existing Standards 

(Efficiency)

Adopted Efficiency 

Standards/Equations†

% 

≥50 W and ≤100 

W Indoor 480 V N/A (1/(1+1.24*×P^(-0.351))) – 0.020

≥50 W and ≤100 

W Indoor All others N/A 1/(1+1.24*×P^(-0.351))

≥50 W and ≤100 

W Outdoor 480 V N/A (1/(1+1.24*×P^(-0.351))) – 0.020

≥50 W and ≤100 

W Outdoor All others N/A 1/(1+1.24*×P^(-0.351))

>100 W and 

<150 W* Indoor 480 V N/A (1/(1+1.24*×P^(-0.351))) – 0.020

>100 W and 

<150 W* Indoor All others N/A 1/(1+1.24*×P^(-0.351))

>100 W and 

<150 W* Outdoor 480 V N/A (1/(1+1.24*×P^(-0.351))) – 0.020

>100 W and 

<150 W* Outdoor All others N/A 1/(1+1.24*×P^(-0.351))

≥150 W** and 

≤250 W Indoor 480 V

Varies from 88% to 

94% depending on 

ballast type

0.880

≥150 W** and 

≤250 W Indoor All others

Varies from 88% to 

94% depending on 

ballast type

For ≥150 W and ≤200 W: 0.880

For >200 W and ≤250 W:

1/(1+0.876*×P^(-0.351))

≥150 W** and 

≤250 W Outdoor 480 V

Varies from 88% to 

94% depending on 

ballast type

0.880

≥150 W** and 

≤250 W Outdoor All others

Varies from 88% to 

94% depending on 

ballast type

For ≥150 W and ≤200 W: 0.880

For >200 W and ≤250 W:

1/(1+0.876*×P^(-0.351))

>250 W and 

≤500 W Indoor 480 V

Varies from 88% to 

94% depending on 

ballast type

For >250 W and <265 W: 0.880

For ≥265 W and ≤500 W;: 

(1/(1+0.876*×P^(-0.351)) – 0.010

>250 W and 

≤500 W Indoor All others

Varies from 88% to 

94% depending on 

ballast type

1/(1+0.876*×P^(-0.351)) 

>250 W and 

≤500 W Outdoor 480 V Varies from 88% to 94% depending on 

For >250 W and <265 W: 0.880

For ≥265 W and ≤500 W;: 

324 
Designed to be 

Operated with 

Lamps of the 

Following Rated 

Lamp Wattage

Indoor/ 

Outdoor***

Test 

Input 

Voltage‡

Existing Standards 

(Efficiency)

Adopted Efficiency 

Standards/Equations†

% 

ballast type (1/(1+0.876*×P^(-0.351)) – 0.010

>250 W and 

≤500 W Outdoor All others

Varies from 88% to 

94% depending on 

ballast type

1/(1+0.876*×P^(-0.351)) 

>500 W and 

≤1000 W Indoor 480 V N/A

For >500 W and ≤750 W: 0.900

For >750 W and ≤1000 W: 

0.000104*×P+0.822 

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and 

≤1000 W Indoor All others N/A

For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 

0.000104*×P+0.832

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and 

≤1000 W Outdoor 480 V N/A

For >500 W and ≤750 W: 0.900

For >750 W and ≤1000 W: 

0.000104*×P+0.822 

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

>500 W and 

≤1000 W Outdoor All others N/A

For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 

0.000104*×P+0.832

For >500 W and ≤1000 W: may not 

utilize a probe-start ballast

*Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 W lamps; rated for use 

in wet locations, as specified by the National Electrical Code NFPA 70-2002, section 410.4(A); and containing a 

ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–20012007. 

**Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 W lamps; rated for 

use in wet locations, as specified by the National Electrical Code NFPA 70-2002, section 410.4(A); and 

containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–

20012007. 

*** DOE’s definitions for “indoor” and “outdoor” MHLFs are described in section V.A.2.

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

‡Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 

W would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not 

designed to operate at either of these voltages would be tested at the highest voltage the ballast is designed to 

operate.

VIII. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563 

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

325 
address, including, where applicable, the failures of private markets or public institutions 

that warrant new agency action, as well as to assess the significance of that problem. The 

problems that today’s standards address are as follows:

There are external benefits resulting from improved energy efficiency of MHLFs that 

are not captured by the users of such equipment. These benefits include externalities 

related to environmental protection and energy security that are not reflected in 

energy prices, such as emissions of greenhouse gases. DOE attempts to quantify some 

of the external benefits through use of SCC values.

In addition, DOE has determined that today’s regulatory action is an 

“economically significant regulatory action” under section 3(f)(1) of Executive Order 

12866. Accordingly, section 6(a)(3) of the Executive Order requires that DOE prepare a 

regulatory impact analysis (RIA) on today’s rule and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office of Management and Budget review this rule. 

DOE presented to OIRA for review the draft rule and other documents prepared for this 

rulemaking, including the RIA, and has included these documents in the rulemaking 

record. The assessments prepared pursuant to Executive Order 12866 can be found in the 

technical support document for this rulemaking.

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563 is supplemental to and 

explicitly reaffirms the principles, structures, and definitions governing regulatory review 

established in Executive Order 12866. To the extent permitted by law, agencies are 

326 
required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public.

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, OIRA has emphasized that such techniques may 

include identifying changing future compliance costs that might result from technological 

innovation or anticipated behavioral changes. For the reasons stated in the preamble, 

DOE believes that today’s final rule is consistent with these principles, including the 

requirement that, to the extent permitted by law, benefits justify costs and that net 

benefits are maximized.

327 
B. Review Under the Regulatory Flexibility Act

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, and a final regulatory flexibility analysis (FRFA) for any such rule that 

an agency adopts as a final rule, unless the agency certifies that the rule, if promulgated, 

will not have a significant economic impact on a substantial number of small entities. As 

required by E. O. 13272, “Proper Consideration of Small Entities in Agency 

Rulemaking,” 67 FR 53461 (Aug. 16, 2002), DOE published procedures and policies on 

February 19, 2003, to ensure that the potential impacts of its rules on small entities are 

properly considered during the rulemaking process. 68 FR 7990. DOE has made its 

procedures and policies available on the Office of the General Counsel’s website 

(http://energy.gov/gc/office-general-counsel). DOE reviewed the August 2013 NOPR and 

today’s final rule under the provisions of the Regulatory Flexibility Act and the 

procedures and policies published on February 19, 2003.

As a result of this review, DOE has prepared a FRFA for MHLFs and ballasts, a 

copy of which DOE will transmit to the Chief Counsel for Advocacy of the SBA for 

review under 5 U.S.C 605(b). As presented and discussed below, the FRFA describes 

impacts on small MHLF and ballast manufacturers and discusses alternatives that could 

minimize these impacts.

A statement of the reasons for establishing the standards in today’s final rule, and 

the objectives of and legal basis for these standards, are set forth elsewhere in the 

preamble and not repeated here.

328 
This FRFA incorporates the IRFA and public comments DOE received on the 

IRFA and the economic impacts of the rule. DOE provides responses to these comments 

in the discussion below on the compliance impacts of the standards and elsewhere in the 

preamble. DOE modified the standards adopted in today’s final rule in response to 

comments received as described in the preamble.

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

For manufacturers of MHLFs and ballasts, the SBA has set a size threshold which 

defines those entities classified as “small businesses” for the purposes of the statute. DOE 

used the SBA’s small business size standards to determine whether any small entities 

would be subject to the requirements of the rule. 65 FR 30836, 30850 (May 15, 2000), as 

amended at 65 FR 53533, 53545 (Sept. 5, 2000) and codified at 13 CFR part 121. The 

size standards are listed by North American Industry Classification System (NAICS) 

code and industry description and are available at 

http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. MH ballast

manufacturing is classified under NAICS 335311, “Power, Distribution and Specialty 

Transformer Manufacturing.” The SBA sets a threshold of 750 employees or less for an 

entity to be considered as a small business for this category. MHLF manufacturing is 

classified under NAICS 335122, “Commercial, Industrial, and Institutional Electric 

Lighting Fixture Manufacturing.” The SBA sets a threshold of 500 employees or less for 

an entity to be considered as a small business for this category.

329 
In the NOPR, DOE identified five small businesses that produce MH ballasts sold 

in the United States and can be considered small business manufacturers. For MHLFs, 

DOE identified approximately 54 small businesses that produce MHLFs sold in the 

United States and can be considered small business manufacturers. DOE did not receive 

any comments to suggest these estimates should be altered for the FRFA.

b. Manufacturer Participation

As stated in the August 2013 NOPR, DOE attempted to contact the small business 

manufacturers of MHLFs and ballasts it had identified. One small MH ballast 

manufacturer and two small MHLF manufacturers consented to being interviewed. DOE 

also obtained information about small business impacts while interviewing large 

manufacturers.

c. Metal Halide Ballast and Fixture Industry Structure

Ballasts. Five major MH ballast manufacturers with limited domestic production 

supply the vast majority of the MH ballast market. None of the five major manufacturers 

is a small business. The remaining market share is held by a few smaller domestic 

companies, only one of which has significant market share. Nearly all MH ballast 

production occurs abroad.

Fixtures. The majority of the MHLF market is supplied by six major 

manufacturers with sizeable domestic production. None of these major manufacturers is a 

small business. The remaining market share is held by several smaller domestic and 

foreign manufacturers. Most of the small domestic manufacturers produce MHLFs in the 

330 
United States. Although none of the small businesses holds a significant market share 

individually, collectively these small businesses account for approximately a third of the 

market. See chapter 3 of this final rule TSD for further details on the MHLF and ballast 

markets.

d. Comparison Between Large and Small Entities

Ballasts. The five large MH ballast manufacturers typically offer a much wider 

range of designs of MH ballasts than small manufacturers do. MH ballasts can vary by 

start method, input voltage, wattage, and design. Often large MH ballast manufacturers 

will offer several different ballast options for each lamp wattage. Small manufacturers 

generally specialize in manufacturing only a handful of different ballast types and do not 

have the volume to support as wide a range of products as large manufacturers do. Three 

of the five small MH ballast manufacturers specialize in high-efficiency electronic 

ballasts and do not offer any magnetic ballasts. Some small MH ballast manufacturers 

offer a wide variety of lighting products, but others focus exclusively on MH ballasts.

Fixtures. The six large MHLF manufacturers typically serve large-scale 

commercial lighting markets, while small MHLF manufacturers tend to operate in niche 

lighting markets such as architectural and designer lighting. Small MHLF manufacturers 

also frequently fill custom orders that are much smaller in volume than large MHLF 

manufacturers’ typical orders are. Because small MHLF manufacturers typically offer 

specialized products and cater to individual customers’ needs, they can command higher 

markups than most large MHLF manufacturers. Like large MH ballast manufacturers, 

large MHLF manufacturers offer a wider range of MHLFs than small MHLF 

331 
manufacturers. A small MHLF manufacturer may offer fewer than 50 models, while a 

large MHLF manufacturer may typically offer several hundred models. Almost all small 

MHLF manufacturers offer a variety of lighting products in addition to those covered by 

this rulemaking, such as fluorescent, incandescent, and LED fixtures.

2. Description and Estimate of Compliance Requirements

Ballasts. Because three of the five small MH ballast manufacturers offer only 

electronic ballasts that already meet the standards at TSL 2, the level established in 

today’s final rule, DOE does not expect any product or capital conversion costs for these 

small MH ballast manufacturers. The fourth small MH ballast manufacturer offers a wide 

range of magnetic and electronic ballasts, so DOE does not expect this manufacturer’s 

conversion costs to differ significantly from those of the large manufacturers. The fifth 

small ballast manufacturer currently offers a large variety of lighting products, but only 

two models of MH ballasts. Because it would likely invest in other parts of its business, 

this manufacturer stated to DOE that this rulemaking is unlikely to significantly affect 

them.

Fixtures. As previously stated, DOE identified approximately 54 small MHLF 

businesses affected by this rulemaking. Based on interviews with two of these 

manufacturers and examinations of product offerings on company websites, DOE 

believes that approximately one-fourth of these small businesses will not face any 

conversion costs because they offer very few MHLF models and would, therefore, focus 

on more substantial areas of their business. Of the remaining small businesses DOE 

identified, nearly two-thirds primarily serve the architectural or specialty lighting 

332 
markets. Because these products command higher prices and margins compared to the 

typical products offered by a large manufacturer, DOE believes that these small MHLF 

manufacturers will be able to pass on any necessary conversion costs to their customers 

without significantly impacting their businesses.

Philips commented that they believe small MHLF manufacturers might not be 

able to pass cost increases due to standards, because in the architectural and specialty 

lighting areas, LEDs are becoming extremely cost competitive. (Philips, Public Meeting 

Transcript, No. 48 at p. 289) Based on small business fixture manufacturer interviews, 

DOE believes that many of the architectural and specialty lighting fixtures are custom 

made orders and the conversion costs for these MHLFs would likely be small. While 

DOE does acknowledge that the MH ballasts used in these MHLFs could increase in 

price, which would result in a higher priced MHLF for customers, these small fixture 

manufacturers stated they also manufacture and sell LED fixtures to meet any customer’s 

needs.

The remaining small MHLF manufacturers (roughly 14 in number) could be 

differentially impacted by today’s established standards. These manufacturers operate 

partially in industrial and commoditized markets in which it may be more difficult to pass 

on any disproportionate costs to their customers. The impacts could be relatively greater 

for a typical small MHLF manufacturer because of the far lower production volumes and 

the relatively fixed nature of the R&D and capital resources required per fixture family.

333 
Based on interviews, however, DOE anticipates that small manufacturers would 

take steps to mitigate the costs required to meet new and amended energy conservation 

standards. DOE believes that under the established standards, small MHLF businesses 

would likely selectively upgrade existing product lines to offer equipment that is in high 

demand or offers a strategic advantage for that company. Small manufacturers could then 

spread out further investments over a longer time period by not upgrading all product 

lines prior to the compliance date.

Additionally, DOE does not expect that small MHLF manufacturers would be 

significantly burdened by compliance requirements. As discussed in section IV.A, the 

standards adopted in this final rule provide simplifying amendments to the current testing 

and reporting procedures. DOE is only mandating testing at a single input voltage for 

MHLFs Because DOE selected the least burdensome input voltage option, DOE 

concludes that regulations in this final rule would not have a significantly adverse impact 

on the testing burden of small manufacturers.

The existing test procedures already dictate that testing for certification requires a 

sample of at least four MHLFs for compliance. DOE is not proposing to change this 

minimum sample size, and as such, does not find an increased testing burden on small 

manufacturers.

DOE did not receive any comments suggesting new and amended energy 

conservation standards would significantly impact small MHLF and ballast 

manufacturers.

334 
3. Duplication, Overlap, and Conflict with Other Rules and Regulations

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being established today.

4. Significant Alternatives to the Rule

Section VII.B.2 analyzes impacts on small businesses that would result from 

DOE’s adopted rule. In addition to the other TSLs being considered, the final rule TSD 

includes an RIA. For MHLFs, the RIA discusses the following policy alternatives: (1) no 

new regulatory action; (2) consumer tax incentives; (3) manufacturer tax incentives; (4) 

performance standards; (5) consumer rebates; (6) manufacturer rebates; (7) voluntary 

energy efficiency targets; (8) early replacement; and (9) bulk government purchases. 

While these alternatives may mitigate to some varying extent the economic impacts on 

small entities compared to the standards, DOE determined that the energy savings of 

these alternatives are significantly smaller than those that would be expected to result 

from the adopted standard levels. Accordingly, DOE is declining to adopt any of these 

alternatives and is adopting the standards set forth in this rulemaking. (See chapter 18 of 

the final rule TSD for further detail on the policy alternatives DOE considered.)

As previously stated, DOE did not receive any comments suggesting new and 

amended energy conservation standards would significantly impact small MHLF and 

ballast manufacturers.

335 
C. Review Under the Paperwork Reduction Act

Manufacturers of MHLFs must certify to DOE that their equipment complies with 

any applicable energy conservation standards. In certifying compliance, manufacturers 

must test their equipment according to DOE test procedures for MHLFs, including any 

amendments adopted for those test procedures. DOE has established regulations for the 

certification and recordkeeping requirements for all covered consumer products and 

commercial equipment, including MHLFs. (76 FR 12422 (March 7, 2011). The 

collection-of-information requirement for the certification and recordkeeping is subject to 

review and approval by OMB under the Paperwork Reduction Act (PRA). This 

requirement has been approved by OMB under OMB control number 1910-1400. Public 

reporting burden for the certification is estimated to average 20 hours per response, 

including the time for reviewing instructions, searching existing data sources, gathering 

and maintaining the data needed, and completing and reviewing the collection of 

information.

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB control number.

D. Review Under the National Environmental Policy Act of 1969

Pursuant to the National Environmental Policy Act (NEPA) of 1969, DOE has 

determined that the rule fits within the category of actions included in Categorical 

Exclusion (CX) B5.1 and otherwise meets the requirements for application of a CX. See 

336 
10 CFR Part 1021, App. B, B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The rule fits 

within the category of actions because it is a rulemaking that establishes energy 

conservation standards for consumer products or industrial equipment, and for which 

none of the exceptions identified in CX B5.1(b) apply. Therefore, DOE has made a CX 

determination for this rulemaking, and DOE does not need to prepare an Environmental 

Assessment or Environmental Impact Statement for this rule. DOE’s CX determination 

for this rule is available at http://cxnepa.energy.gov/.

E. Review Under Executive Order 13132

Executive Order 13132, “Federalism.” 64 FR 43255 (Aug. 10, 1999) imposes 

certain requirements on federal agencies formulating and implementing policies or 

regulations that preempt state law or that have Federalism implications. The Executive 

Order requires agencies to examine the constitutional and statutory authority supporting 

any action that would limit the policymaking discretion of the states and to carefully 

assess the necessity for such actions. The Executive Order also requires agencies to have 

an accountable process to ensure meaningful and timely input by state and local officials 

in the development of regulatory policies that have Federalism implications. On March 

14, 2000, DOE published a statement of policy describing the intergovernmental 

consultation process it will follow in the development of such regulations. 65 FR 13735. 

EPCA governs and prescribes federal preemption of state regulations as to energy 

conservation for the equipment that is the subject of today’s final rule. States can petition 

DOE for exemption from such preemption to the extent, and based on criteria, set forth in 

EPCA. (42 U.S.C. 6297) No further action is required by Executive Order 13132. 

337 
F. Review Under Executive Order 12988 

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, “Civil Justice Reform,” imposes on 

federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing federal law or regulation; (3) provides a 

clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this final rule meets the relevant standards of Executive 

Order 12988.

G. Review Under the Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

federal agency to assess the effects of federal regulatory actions on state, local, and Tribal 

governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 1531). 

338 
For a new and amended regulatory action likely to result in a rule that may cause the 

expenditure by state, local, and Tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

202 of UMRA requires a federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 1532(a), 

(b)) The UMRA also requires a federal agency to develop an effective process to permit 

timely input by elected officers of state, local, and Tribal governments on a “significant 

intergovernmental mandate,” and requires an agency plan for giving notice and 

opportunity for timely input to potentially affected small governments before establishing 

any requirements that might significantly or uniquely affect small governments. On 

March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820. DOE’s policy statement is 

also available at http://energy.gov/gc/office-general-counsel. 

DOE has concluded that this final rule would likely require expenditures of $100 

million or more on the private sector. Such expenditures may include: (1) investment in 

research and development and in capital expenditures by MHLFs manufacturers in the 

years between the final rule and the compliance date for the new standards, and (2) 

incremental additional expenditures by customers to purchase higher-efficiency MHLFs, 

starting at the compliance date for the applicable standard.

Section 202 of UMRA authorizes a federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the final rule. 

2 U.S.C. 1532(c). The content requirements of section 202(b) of UMRA relevant to a 

339 
private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of the notice of final rulemaking and 

the “Regulatory Impact Analysis” section of the TSD for this final rule respond to those 

requirements.

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the rule unless DOE publishes an explanation for doing 

otherwise, or the selection of such an alternative is inconsistent with law. As required by 

42 U.S.C. 6295(hh), and (o), 6317(a), today’s final rule would establish energy 

conservation standards for MHLFs that are designed to achieve the maximum 

improvement in energy efficiency that DOE has determined to be both technologically 

feasible and economically justified. A full discussion of the alternatives considered by 

DOE is presented in the “Regulatory Impact Analysis” section of the TSD for today’s 

final rule.

H. Review Under the Treasury and General Government Appropriations Act, 1999

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This rule would not have any impact on 

340 
the autonomy or integrity of the family as an institution. Accordingly, DOE has 

concluded that it is not necessary to prepare a Family Policymaking Assessment.

I. Review Under Executive Order 12630 

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (March 18, 

1988), that this regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

J. Review Under the Treasury and General Government Appropriations Act, 2001

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed today’s final rule under the OMB and DOE guidelines and has concluded that it 

is consistent with applicable policies in those guidelines.

K. Review Under Executive Order 13211

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires 

federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any significant energy action. A “significant energy action” is defined as any action 

by an agency that promulgates or is expected to lead to promulgation of a final rule, and 

341 
that: (1) is a significant regulatory action under Executive Order 12866, or any successor 

order; and (2) is likely to have a significant adverse effect on the supply, distribution, or 

use of energy, or (3) is designated by the Administrator of OIRA as a significant energy 

action. For any significant energy action, the agency must give a detailed statement of 

any adverse effects on energy supply, distribution, or use should the proposal be 

implemented, and of reasonable alternatives to the action and their expected benefits on 

energy supply, distribution, and use.

DOE has concluded that today’s regulatory action, which sets forth energy 

conservation standards for MHLFs, is not a significant energy action because the new and 

amended standards are not likely to have a significant adverse effect on the supply, 

distribution, or use of energy, nor has it been designated as such by the Administrator at 

OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects on the final 

rule.

L. Review Under the Information Quality Bulletin for Peer Review

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the Bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

342 
defines as scientific information the agency reasonably can determine will have, or does 

have, a clear and substantial impact on important public policies or private sector 

decisions. 70 FR 2667. 

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report” dated February 2007 

has been disseminated and is available at the following website: 

www1.eere.energy.gov/buildings/appliance_standards/peer_review.html. 

M. Congressional Notification

As required by 5 U.S.C. 801, DOE will report to Congress on the promulgation of 

this rule prior to its effective date. The report will state that it has been determined that 

the rule is not a “major rule” as defined by 5 U.S.C. 804(2).

343 
IX. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of today’s final rule.

List of Subjects in 10 CFR Part 431 

Administrative practice and procedure, Confidential business information, Energy 

conservation, Household appliances, Imports, Incorporation by reference, 

Intergovernmental relations, Reporting and recordkeeping requirements, and Small 

businesses.

Issued in Washington, DC, on January 27, 2014

________________________________ 

 ________________________________ 

 David T. Danielson

 Assistant Secretary

 Energy Efficiency and Renewable Energy

344 
For the reasons set forth in the preamble, DOE amends part 431 of chapter II, 

subchapter D, of title 10 of the Code of Federal Regulations, to read as set forth below:

PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

1. The authority citation for part 431 continues to read as follows:

Authority: 42 U.S.C. 6291–6317. 

2. Section 431.322 is amended by adding in alphabetical order definitions for “general 

lighting application” “high-frequency electronic metal halide ballast,” and “nonpulsestart electronic ballast,” to read as follows:

§ 431.322 Definitions concerning metal halide ballasts and fixtures.

* * * * * 

General lighting application means lighting that provides an interior or exterior area with 

overall illumination.

High-frequency electronic metal halide ballast means an electronic ballast that operates a 

lamp at an output frequency of 1000 Hz or greater.

* * * * * 

Nonpulse-start electronic ballast means an electronic ballast with a starting method other 

than pulse-start.

* * * * * 

345 
3. Section 431.324 is amended by:

aa. Adding paragraph (b)(1)(iii); and 

b. Revising paragraphs (b)(3) and (c)(1). 

b. Adding paragraph (b)(1)(iii).

The additions and revisions read as follows:

§431.324 Uniform test method for the measurement of energy efficiency and 

standby mode energy consumption of metal halide ballasts.

* * * * * 

(b) * * * 

(1) * * * 

(iii) Input Voltage for Tests. For ballasts designed to operate lamps rated less than 150 W 

that have 120 V as an available input voltage, testing shall be performed at 120 V. For 

ballasts designed to operate lamps rated less than 150 W that do not have 120 V as an 

available voltage, testing shall be performed at the highest available input voltage. For 

ballasts designed to operate lamps rated greater than or equal to 150 W that have 277 V 

as an available input voltage, testing shall be conducted at 277 V. For ballasts designed to 

operate lamps rated greater than or equal to 150 W that do not have 277 V as an available 

input voltage, testing shall be conducted at the highest available input voltage.

* * * * * 

(3) Efficiency Calculation. The measured lamp output power shall be divided by the 

measured ballast input power to determine the percent efficiency of the ballast under test 

to three significant figures. 

346 
(i) A fractional number at or above the midpoint between two consecutive decimal places 

shall be rounded up to the higher of the two decimal places; or

(ii) A fractional number below the midpoint between two consecutive decimal places 

shall be rounded down to the lower of the two decimal places.

(c) * * * 

(1) Test Conditions. (i) The power supply and ballast test conditions with the exception 

of input voltage shall all conform to the requirements specified in section 4.0, “General 

Conditions for Electrical Performance Tests,” of the ANSI C82.6 (incorporated by 

reference; see §431.323). Ambient temperatures for the testing period shall be maintained 

at 25 °C ± 5 °C. Send a signal to the ballast instructing it to have zero light output using 

the appropriate ballast communication protocol or system for the ballast being tested.

(ii) Input Voltage for Tests. For ballasts designed to operate lamps rated less than 150 W 

that have 120 V as an available input voltage, ballasts are to be tested at 120 V. For 

ballasts designed to operate lamps rated less than 150 W that do not have 120 V as an 

available voltage, ballasts are to be tested at the highest available input voltage. For 

ballasts designed to operate lamps rated greater than or equal to 150 W that have 277 V 

as an available input voltage, ballasts are to be tested at 277 V. For ballasts designed to 

operate lamps rated greater than or equal to 150 W that do not have 277 V as an available 

input voltage, ballasts are to be tested at the highest available input voltage.

347 
* * * * * 

4. Section 431.326 is amended by adding paragraphs (c), (d), and (e) to read as follows:

§ 431.326 Energy conservation standards and their effective dates.

 * * * * * 

(c) Except when the requirements of paragraph (a) of this section are more stringent (i.e., 

require a larger minimum efficiency value) or as provided by paragraph (e) of this 

section, each metal halide lamp fixture manufactured on or after [INSERT DATE 3 

YEARS AFTER DATE OF PUBLICATION OF THIS FINAL RULE] shallIN THE 

FEDERAL REGISTER] must contain a metal halide ballast with an efficiency not less 

than the value determined from the appropriate equation in the following table:

348 
Designed to be Operated with 

Lamps of the Following Rated 

Lamp Wattage

Tested Input 

Voltage‡‡

Minimum Standard Equation††

% 

≥50 W and ≤100 W Tested at 480 V (1/(1+1.24*×P^(-0.351))) – 0.020††

≥50 W and ≤100 W All others 1/(1+1.24*×P^(-0.351))

>100 W and <150† W Tested at 480 V (1/(1+1.24*×P^(-0.351))) – 0.020

>100 W and <150† W All others 1/(1+1.24*×P^(-0.351))

≥150‡ W and ≤250 W Tested at 480 V 0.880

≥150‡ W and ≤250 W All others

For ≥150 W and ≤200 W: 0.880

For >200 W and ≤250 W:

1/(1+0.876*×P^(-0.351))

>250 W and ≤500 W Tested at 480 V

For >250 and <265 W: 0.880

For ≥265 W and ≤500 W: 

(1/(1+0.876*×P^(-0.351)) – 0.010

>250 W and ≤500 W All others 1/(1+0.876*×P^(-0.351)) 

>500 W and ≤1000 W Tested at 480 V

For >500 W and ≤750 W: 0.900

For >750 W and ≤1000 W: 0.000104*×P+0.822 

For >500 W and ≤1000 W: may not utilize a 

probe-start ballast

>500 W and ≤1000 W All others

For >500 W and ≤750 W: 0.910

For >750 W and ≤1000 W: 0.000104*×P+0.832

For >500 W and ≤1000 W: may not utilize a 

probe-start ballast

†Includes 150 W fixtures specified in paragraph (b)(3) of this section, that are fixtures rated only for 150 W 

lamps; rated for use in wet locations, as specified by the National Electrical Code 2002,NFPA 70 

(incorporated by reference, see § 431.323), section 410.4(A); and containing a ballast that is rated to operate at 

ambient air temperatures above 50 °C, as specified by UL 1029–2001. (incorporated by reference, see § 

431.323).

‡Excludes 150 W fixtures specified in paragraph (b)(3) of this section, that are fixtures rated only for 150 W 

lamps; rated for use in wet locations, as specified by the National Electrical Code 2002NFPA 70, section 

410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified 

by UL 1029–2001. 

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

‡‡Tested input voltage is specified in 10 CFR 431.324.

(d) Except as provided in paragraph (e) of this section, metal halide lamp fixtures 

manufactured on or after [INSERT DATE 3 YEARS AFTER PUBLICATION OF 

THIS FINAL RULE] that operate lamps with rated wattage >500 W to ≤1000 W 

shallmust not contain a probe-start metal halide ballast. 

349 
(e) The standards described in paragraphs (c) and (d) of this section do not apply to— 

(1) Metal halide lamp fixtures with regulated-lag ballasts; 

(2) Metal halide lamp fixtures that use electronic ballasts that operate at 480 

volts; and

(3) Metal halide lamp fixtures that use high-frequency electronic ballasts. 

350