[Federal Register Volume 79, Number 27 (Monday, February 10, 2014)]
[Rules and Regulations]
[Pages 7746-7844]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-02356]
[[Page 7745]]
Vol. 79
Monday,
No. 27
February 10, 2014
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for Metal
Halide Lamp Fixtures; Final Rule
Federal Register / Vol. 79, No. 27 / Monday, February 10, 2014 /
Rules and Regulations
[[Page 7746]]
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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.
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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 more-stringent
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this final rule, DOE
is adopting more-stringent 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.
DATES: The effective date of this rule is April 11, 2014. Compliance
with the new and amended standards established for MHLFs in today's
final rule is required by February 10, 2017.
The incorporation by reference of certain publications listed in
this rule is approved by the Director of the Federal Register on April
11, 2014.
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 Web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16. The regulations.gov Web page 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:
[email protected].
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 SW., Washington,
DC 20585-0121. Telephone: (202) 287-1604. Email: [email protected].
Mr. Ari Altman, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 287-6307. Email: [email protected].
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
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
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
[[Page 7747]]
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
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
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 B \1\ of the Energy Policy and Conservation Act
of 1975 (EPCA or the Act), Public Law 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
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 efficiencies \4\ 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).
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\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), Public Law 112-210 (Dec. 18, 2012).
\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 0 for further discussion.
Table I.1--Energy Conservation Standards for MHLFs
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Designed to be operated with
lamps of the following rated lamp Indoor/outdoor Test input voltage Minimum standard equation [Dagger]
wattage [dagger] %
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>=50 W and <=100 W............... Indoor............. 480 V.............. (1/(1+1.24xP[supcaret](-0.351))) -
0.0200.
>=50 W and <=100 W............... Indoor............. All others......... 1/(1+1.24xP[supcaret](-0.351)).
>=50 W and <=100 W............... Outdoor............ 480 V.............. (1/(1+1.24xP[supcaret](-0.351))) -
0.0200.
>=50 W and <=100 W............... Outdoor............ All others......... 1/(1+1.24xPsup⁁(-0.351)).
>100 W and <150 W *.............. Indoor............. 480 V.............. (1/(1+1.24xP[supcaret](-0.351))) -
0.0200.
>100 W and <150 W *.............. Indoor............. All others......... 1/(1+1.24xP[supcaret](-0.351)).
>100 W and <150 W *.............. Outdoor............ 480 V.............. (1/(1+1.24xP[supcaret](-0.351))) -
0.0200.
>100 W and <150 W *.............. Outdoor............ All others......... 1/(1+1.24xP[supcaret](-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+0.876xP[supcaret](-0.351)).
>=150 W ** and <=250 W........... Outdoor............ 480 V.............. 0.880.
[[Page 7748]]
>=150 W ** and <=250 W........... Outdoor............ All others......... For >=150 W and <=200 W: 0.88.
For >200 W and <=250 W:
1/(1+0.876xP[supcaret](-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+0.876xP[supcaret](-0.351))) -
0.0100.
>250 W and <=500 W............... Indoor............. All others......... 1/(1+0.876xP[supcaret](-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+0.876xP[supcaret](-0.351))) -
0.0100.
>250 W and <=500 W............... Outdoor............ All others......... 1/(1+0.876xP[supcaret](-0.351)).
>500 W and <=1000 W.............. Indoor............. 480 V.............. >500 W and <=750 W: 0.900.
>750 W and <=1000 W:
0.000104xP + 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:
0.000104xP+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:
0.000104xP + 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:
0.000104xP+0.832.
For >500 W and <=1000 W: may not
utilize a probe-start ballast.
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* 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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] Tested input voltage is specified in 10 CFR 431.324.
[Dagger] 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.
Table I.2--Impacts of Today's Standards on Customers of MHLFs *
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Median
Representative equipment class Representative wattage Average LCC payback
savings 2012$ period years
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>=50 W and <=100 W (indoor, magnetic baseline) 70 W............................ 27.00 4.5
>=50 W and <=100 W (outdoor, magnetic 70 W............................ 34.88 4.5
baseline).
>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 [dagger] and <=250 W (indoor)......... 250 W........................... 4.51 14.2
>=150 W [dagger] and <=250 W (outdoor)........ 250 W........................... 6.74 17.4
>250 W and <=500 W (indoor)................... 400 W........................... 7.95 15.0
>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
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* 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 [deg]C, as specified by UL 1029-2001.
[dagger] 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 [deg]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
[[Page 7749]]
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 Benefits \5\
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\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.
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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.
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.
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\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.
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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 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 $44.20 million at a 3-percent
discount rate.\8\
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\7\ Technical Support Document: Technical Update of the Social
Cost of Carbon for Regulatory Impact Analysis Under Executive Order
12866. Interagency Working Group on Social Cost of Carbon, United
States Government. May 2013 (Revised November 2013).
www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
\8\ DOE is currently investigating valuation of avoided Hg and
SO2 emissions.
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Table I.3 summarizes the national economic costs and benefits
expected to result from today's standards for MHLFs.
Table I.3--Summary of National Economic Benefits and Costs of MHLF
Energy Conservation Standards *
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Present value
Category million 2012$ Discount rate (%)
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Benefits
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Operating Cost Savings............ 754 7
1,636 3
CO2 Reduction Monetized Value 146 5
($11.8/t case) **................
CO2 Reduction Monetized Value 682 3
($39.7/t case) **................
CO2 Reduction Monetized Value 1,088 2.5
($61.2/t case) **................
CO2 Reduction Monetized Value 2,106 3
($117/t case) **.................
NOX Reduction Monetized Value (at 17 7
$2639/ton) **....................
37 3
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Total Benefits [dagger]....... 1,453 7
2,355 3
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Costs
------------------------------------------------------------------------
Incremental Installed Costs....... 465 7
721 3
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Net Benefits
------------------------------------------------------------------------
Including CO2 and NOX [dagger] 988 7
Reduction Monetized Value........
1,634 3
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* This table presents the primary (low shipments scenario) estimate of
costs and benefits associated with fixtures shipped in 2017-2046.
These results include benefits to customers which accrue after 2047
from the equipment purchased in 2017-2046. The results account for the
incremental variable and fixed costs incurred by manufacturers due to
the standard, some of which may be incurred in preparation for the
rule.
** The CO2 values represent global monetized values of the SCC, in
2012$, 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.
[dagger] 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
[[Page 7750]]
installation costs, which is another way of representing customer
NPV), plus (2) the annualized monetary value of the benefits of
emission reductions, including CO2 emission
reductions.\9\
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\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.
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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 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 $91 million per year.
Table I.4--Annualized Benefits and Costs of New and Amended Standards for MHLFs
----------------------------------------------------------------------------------------------------------------
Primary (low) net High net benefits
Discount rate benefits estimate * estimate * Million 2012$/
Million 2012$/year year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings...... 7%........................ 74........................ 92
3%........................ 91........................ 119
CO2 Reduction at ($11.8 5%........................ 11........................ 13
case) **.
CO2 Reduction at ($39.7/t 3%........................ 38........................ 46
case) **.
CO2 Reduction at ($61.2/t 2.5%...................... 56........................ 68
case) **.
CO2 Reduction at ($117.0/t 3%........................ 117....................... 142
case) **.
NOX Reduction at ($2639/ton) 7%........................ 1.71...................... 1.95
**.
3%........................ 2.07...................... 2.46
-----------------------------------------------------------------------------------
Total Benefits[dagger].. 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 [dagger].......... 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.
** 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.
[dagger] 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
[[Page 7751]]
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.
A. Authority
Title III, Part B \10\ of the Energy Policy and Conservation Act
of 1975 (EPCA or the Act), Public Law 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.
---------------------------------------------------------------------------
\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), Public Law 112-210 (Dec. 18,
2012).
---------------------------------------------------------------------------
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 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;
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))
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. 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 locations; and (3) contain a ballast that is rated to
operate at ambient air temperatures higher than 50 [deg]C.
[[Page 7752]]
Table II.1--Federal Energy Efficiency Standards for MHLFs *
------------------------------------------------------------------------
Operated lamp rated Minimum ballast
Ballast type wattage range 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 Web site; 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 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 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 Web site 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 analysis (MIA) spreadsheet--all of which are
available on DOE's Web site.\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.
Table II.2--Energy Conservation Standards Proposed in the NOPR
----------------------------------------------------------------------------------------------------------------
Designed to be operated with lamps Indoor/outdoor Test input voltage Minimum standard equation
of the following rated lamp wattage [dagger] [dagger][dagger] [Dagger] %
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W................. Indoor................ 480 V.................. 99.4/(1+2.5xP[supcaret](-
0.55)).[Dagger]
>=50 W and <=100 W................. Indoor................ All others............. 100/(1+2.5xP[supcaret](-
0.55)).
>=50 W and <=100 W................. Outdoor............... 480 V.................. 99.4/(1+2.5xP[supcaret](-
0.55)).
>=50 W and <=100 W................. Outdoor............... All others............. 100/(1+2.5xP[supcaret](-
0.55)).
>100 W and <150 W *................ Indoor................ 480 V.................. 99.4/(1+0.36xP[supcaret](-
0.30)).
>100 W and <150 W *................ Indoor................ All others............. 100/(1+0.36xP[supcaret](-
0.30)).
>100 W and <150 W *................ Outdoor............... 480 V.................. 99.4/(1+0.36xP[supcaret](-
0.30)).
>100 W and <150 W *................ Outdoor............... All others............. 100/(1+0.36xP[supcaret](-
0.30)).
>=150 W ** and <=250 W............. Indoor................ 480 V.................. For >=150 W and <=200 W:
88.0.
For >200 W and <=250 W:
0.06xP + 76.0.
>=150 W ** and <=250 W............. Indoor................ All others............. For >=150 W and <=200 W:
88.0.
For >200 W and <=250 W:
0.07xP + 74.0.
>=150 W ** and <=250 W............. Outdoor............... 480 V.................. For >=150 W and <=200 W:
88.0
For >200 W and <=250 W:
0.06xP + 76.0.
>=150 W ** and <=250 W............. Outdoor............... All others............. For >=150 W and <=200 W:
88.0.
For >200 W and <=250 W:
0.07xP + 74.0.
[[Page 7753]]
>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:
0.994x(0.0032xP + 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:
0.0032xP + 89.9.
For >=1000 W to <=2000 W:
93.1 and may not utilize
a probe-start ballast.
>500 W and <=2000 W................ Outdoor............... 480 V.................. For >500 W to <1000 W:
0.994x(0.0032xP + 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:
0.0032xP + 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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] DOE's proposed definitions for ``indoor'' and ``outdoor'' MHLFs are described in section V.A.2.
[dagger][dagger] 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.
[Dagger] 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 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.
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 [deg]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.
---------------------------------------------------------------------------
\13\ As a point of reference, 50 [deg]C is equivalent to
122[emsp14][deg]F.
---------------------------------------------------------------------------
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. 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.
---------------------------------------------------------------------------
\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, document number
48 in the docket of this rulemaking; and (3) appearing on pages 14-
15 and 67-69 of that transcript.
---------------------------------------------------------------------------
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.
[[Page 7754]]
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. 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.
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 [deg]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; 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 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 [deg]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 [deg]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 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 transitions to more
efficient light-emitting diode (LED) lamps in this
[[Page 7755]]
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.
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 small-market-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 MHLFs \15\
covered by EISA 2007.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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 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 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)
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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.
[[Page 7756]]
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.
---------------------------------------------------------------------------
\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).
---------------------------------------------------------------------------
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. 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).
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 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 cost-
efficiency 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 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
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
[[Page 7757]]
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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 [deg]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.
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.
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.
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.
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)
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
[[Page 7758]]
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 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 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:
[GRAPHIC] [TIFF OMITTED] TR10FE14.000
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 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.
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 EL2 is 0.6 percent, and there is a
testing tolerance
[[Page 7759]]
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 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 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 (M6 \19\). (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.
---------------------------------------------------------------------------
\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.
Table IV.1--Max-Tech Levels
----------------------------------------------------------------------------------------------------------------
Equipment class wattage range Efficiency level * Efficiency-level equation [dagger] %
----------------------------------------------------------------------------------------------------------------
>=50 and <=100................. EL4................ 1/(1+0.360xP[supcaret](-0.297))
>100 and <150 *................ EL4................ 1/(1+0.360xP[supcaret](-0.297))
>=150 ** and <=250............. EL4................ 1/(1+0.360xP[supcaret](-0.297))
>250 and <=500................. EL4................ 1/(1+0.360xP[supcaret](-0.297))
>500 and <=1000................ EL2................ For >500 W and <=750 W: 0.910
For >750 W and <=1000 W: 0.000104xP+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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] 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 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
[[Page 7760]]
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 high-pressure
sodium, based on data given by manufacturers during the 2010 Framework
public meeting. (Philips, Public Meeting Transcript, No. 8 at p. 91)
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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).
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 ApplianceEnergy-
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.
---------------------------------------------------------------------------
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
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.
---------------------------------------------------------------------------
\22\ DOE also presents a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
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 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
[[Page 7761]]
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.
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 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))
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 rebuttable-presumption 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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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.
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
[[Page 7762]]
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.
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 multi-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 multi-tap 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. Medium-
wattage (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.
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 cost-
efficiency relationships. Analyzing certain wattage ranges as separate
equipment classes allows DOE to establish the energy conservation
standards that are cost-effective for every wattage.
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 [deg]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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
[[Page 7763]]
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, (2) increased impedance, and (3) decreased
wire cross[hyphen]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. While
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.
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 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 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
cost-efficiency 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\
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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.
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 (NFPA) 70-2002,\26\ section
410.10(A) or UL 1598
[[Page 7764]]
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.
---------------------------------------------------------------------------
\26\ The NFPA 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.
---------------------------------------------------------------------------
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 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. 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 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 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
[[Page 7765]]
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.
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 Indoor/outdoor Input voltage
lamp wattage [dagger] type[Dagger]
------------------------------------------------------------------------
>=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 [deg]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 [deg]C, as
specified by UL 1029-2007.
[dagger] DOE's proposed definitions for ``indoor'' and ``outdoor'' MHLFs
are described in section V.A.2.c.
[Dagger] 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. 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.
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
[[Page 7766]]
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.
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
resistance and output
capacitance.
Transistors........ Use transistors with
lower drain-to-source
resistance.
Improved Circuit Integrated Circuits Substitute discrete
Design. 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 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 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
[[Page 7767]]
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 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 MSPs \28\ 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.
---------------------------------------------------------------------------
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 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 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\
---------------------------------------------------------------------------
\29\ Descriptions of each of these fixtures types can be found
in chapter 3 of the final rule TSD.
---------------------------------------------------------------------------
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 Representative fixture types
lamps of the following rated lamp Representative -------------------------------------------------------------------------------------------------
wattage wattage 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 [deg]C, as specified by UL 1029-
2007.
[[Page 7768]]
** 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 [deg]C, as specified by UL 1029-
2007.
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.
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)
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 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
[[Page 7769]]
baseline unit is meant to measure changes resulting from potential
amended energy 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.
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
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 higher-efficiency 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 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 test \30\ 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 grain-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)
---------------------------------------------------------------------------
\30\ 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.
---------------------------------------------------------------------------
In this final rule, DOE has revised its approach to modeling the
efficiency of magnetic ballasts. The efficiency of
[[Page 7770]]
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
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-
test-based 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 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 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[hyphen]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
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.
[[Page 7771]]
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 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.
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 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) 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
[[Page 7772]]
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 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 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.
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, 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
[[Page 7773]]
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 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.
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.
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 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 [deg]C internal operating
temperature (or case temperature) limit, while their magnetic
counterparts are in the greater than 180 [deg]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 [deg]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)
In addition, several stakeholders noted that the design of existing
fixtures may create high temperature environments within the fixture
itself,
[[Page 7774]]
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 [deg]C. While
magnetic ballasts themselves are able to handle temperatures as extreme
as 180 [deg]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 [deg]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 temperature rating of about 100 [deg]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 [deg]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.
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 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)
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
[[Page 7775]]
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).
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
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 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 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.
[[Page 7776]]
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.
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[supreg] 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 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 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, 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
[[Page 7777]]
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 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 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.
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 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.
[[Page 7778]]
Table V.4--Efficiency Level Descriptions for the Representative Equipment Classes
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Representative equipment Rep. wattage EL Minimum efficiency equation[dagger] %
class
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W........... 70 W....................... EL1.... 1/(1+1.33xP[supcaret](-0.346))[dagger]
EL2.... 1/(1+1.24xP[supcaret](-0.351))
EL3.... 1/(1+0.600xP[supcaret](-0.340))
EL4.... 1/(1+0.360xP[supcaret](-0.297))
>100 W and <150 W*........... 150 W...................... EL1.... 1/(1+1.33xP[supcaret](-0.346))
EL2.... 1/(1+1.24xP[supcaret](-0.351))
EL3.... 1/(1+0.600xP[supcaret](-0.340))
EL4.... 1/(1+0.360xP[supcaret](-0.297))
--------------------------------------------
>=150 W** and <=250 W........ 250 W...................... EL1.... >=150 W and <=200 W:. >200 W and <=250 W:
0.880................ 0.000400xP + 0.800
--------------------------------------------
EL2.... >=150 W and <=200 W:. >200 W and <=250 W:
0.880................ 0.000600xP + 0.760
--------------------------------------------
EL3.... 1/(1+0.600xP[supcaret](-0.340))
EL4.... 1/(1+0.360xP[supcaret](-0.297))
>250 W and <=500 W........... 400 W...................... EL1.... 0.900
EL2.... 0.910
EL3.... 1/(1+0.600xP[supcaret](-0.340))
EL4.... 1/(1+0.360xP[supcaret](-0.297))
--------------------------------------------
>500 W and <=1000 W.......... 1000 W..................... EL1.... >500 W and <=750 W:.. >750 W and <=1000 W:
0.0000400xP+0.880.... 0.0000840xP + 0.847
--------------------------------------------
EL2.... >500 W and <=750 W:.. >750 W and <=1000 W:
0.910................ 0.000104xP + 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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] 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 probe-start ballasts to be 94 percent efficient,
effectively banning probe-start ballasts between 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 pulse-start 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 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-
[[Page 7779]]
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)
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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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. 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 higher-wattage 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)
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)
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 pulse-start
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
[[Page 7780]]
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 U.S.C. 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 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.
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 remote-start 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.
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 quad-voltage 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)
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
[[Page 7781]]
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 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
------------------------------------------------------------------------
Scaling
Wattage range factor
(percent)
------------------------------------------------------------------------
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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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.
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)
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
[[Page 7782]]
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 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)
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 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
probe- and pulse-start systems.
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
[[Page 7783]]
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. 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.
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.
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 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
population-weighted average of the census division and large state
values. For the NOPR, this approach provided a national average tax
rate of 7.13 percent.
---------------------------------------------------------------------------
\33\ The Sales Tax Clearinghouse. Available at https://thestc.com/STRates.stm. (Last accessed June 24, 2013.)
---------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Electrical Wholesaler (Distributor)..................... 1.23 1.05 (\1\) (\1\) (\1\) (\1\)
Utility................................................. (\1\) (\1\) 1.00 1.00 1.00 1.00
Contractor or Installer................................. 1.13 1.13 1.13 1.13 (\1\) (\1\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sales Tax............................................... 1.07
1.07
1.07
-----------------------------------------------------------------------------------------------
Overall................................................. 1.49 1.27 1.21 1.21 1.07 1.07
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ Not applicable.
[[Page 7784]]
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 Energy Consumption Survey (CBECS),\34\ and the
Manufacturer Energy Consumption Survey (MECS).\35\ 78 FR 51464, 51501
(Aug. 20, 2013).
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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.
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.
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.
[[Page 7785]]
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 No change.
distribution channel markups and sales tax.
Installation Cost............... Calculated costs using estimated labor Calculated costs using estimated
times and applicable labor rates from ``RS labor times and applicable labor
Means Electrical Cost Data'' (2009) and rates from ``RS Means Electrical
U.S. Bureau of Labor Statistics. Cost Data'' (2013); Sweets
Electrical Cost Guide 2013; and
U.S. Bureau of Labor Statistics.
Annual Energy Use............... Determined operating hours separately for No change.
indoor and outdoor fixtures. Used lighting
market data: 2010 LMC (2012).
Energy Prices................... Electricity: Based on EIA's Form 826 data No change.
for 2012.
Variability: Energy prices determined at
state level; incorporated off-peak
electricity prices in the Monte Carlo
analysis.
Energy Price Projections........ Projected using AEO2013.................... No change.
Replacement Costs............... Included labor and material costs for lamp No change.
and ballast replacement through the end of
their lifetimes.
Equipment Lifetime.............. Ballasts: Assumed 50,000 hours for magnetic Ballasts: No change.
ballasts and 40,000 hours for electronic
ballasts.
Fixtures: Assumed 20 years for indoor Fixtures: No change.
fixtures and 25 years for outdoor fixtures.
Variability: Incorporated lamp and ballast Variability: Incorporated lamp,
lifetimes in the Monte Carlo analysis. ballast and fixture lifetimes in
the Monte Carlo analysis.
Discount Rates.................. Commercial/Industrial: Developed a Commercial/Industrial: No change.
distribution of discount rates for each
end-use sector.
Outdoor Stationary: Developed a Outdoor Stationary: No change.
distribution of discount rates for each
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).
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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.
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).
---------------------------------------------------------------------------
\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, DC. 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.
---------------------------------------------------------------------------
DOE received comments that larger ballasts and housings--and larger
poles required for outdoor fixtures--would increase costs and payback
periods for higher-efficiency designs. (Acuity Brands, Public Meeting
Transcript, No. 48 at p. 60; GE, Public Meeting
[[Page 7786]]
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 final rule, DOE also referenced Sweets Electrical
Cost Guide \39\ in developing installation cost estimates for the LCC
and PBP analysis. For further detail, see chapter 8 of the final rule
TSD.
---------------------------------------------------------------------------
\39\ Sweets-McGraw Hill Construction. Sweets Electrical Cost
Guide 2013. 2012. Vista, CA.
---------------------------------------------------------------------------
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.
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.
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.
For outdoor fixtures, DOE examined data on the frequency and
geographic distribution of lightning strikes from the National
Lightning Safety Institute \40\ 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).
---------------------------------------------------------------------------
\40\ National Lightning Safety Institute. See http://lightningsafety.com.
---------------------------------------------------------------------------
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 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
[[Page 7787]]
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.
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).
---------------------------------------------------------------------------
\41\ Weibull distribution is a probability density function; for
more information, see www.itl.nist.gov/div898/handbook/eda/section3/eda3668.htm.
---------------------------------------------------------------------------
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 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 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.
---------------------------------------------------------------------------
\42\ The data are available at pages.stern.nyu.edu/~adamodar.
(Last accessed August 21, 2013.)
---------------------------------------------------------------------------
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 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.
[[Page 7788]]
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.
DOE evaluated the impacts of new and amended standards for metal
halide lamp fixtures by comparing base-case projections with standards-
case projections. The base-case 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 See Table V.9.
shipments model.
Annual Energy Consumption per Unit.... Established in the energy use analysis See section V.E.
(NOPR TSD chapter 7).
Rebound Effect........................ 0%...................................... No change.
Electricity Price Forecast............ AEO2013................................. No change.
Energy Site-to-Source Conversion Used annually variable site kWh to No change.
Factor. source Btu conversion factor.
Discount Rate......................... 3% and 7% real.......................... No change.
Present Year.......................... 2013.................................... No change.
----------------------------------------------------------------------------------------------------------------
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 Revised historical MH fixture
shipments to develop shipments for shipments based on updated NEMA MH
MH fixtures. ballast shipment trends.
Fixture Stock...................... Based projections on the shipments No change.
that survive up to a given date;
assumed Weibull lifetime
distribution.
Growth............................. Adjusted based on fixture market..... No change.
Base Case Scenarios................ Developed ``low'' and ``high'' Revised ``low'' and ``high''
shipments scenarios. shipments scenarios based on
revised historical MH fixture
shipments.
Standards Case Scenarios........... Analyzed Roll-up only................ No change.
----------------------------------------------------------------------------------------------------------------
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).
---------------------------------------------------------------------------
\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/.
---------------------------------------------------------------------------
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
[[Page 7789]]
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. 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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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 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.
---------------------------------------------------------------------------
\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, DC. http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022.
---------------------------------------------------------------------------
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 high-temperature 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
[[Page 7790]]
revised base case 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.
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\
---------------------------------------------------------------------------
\46\ Docket ID: EERE-2010-BT-NOA-0028, comment by Kirk
Lundblade.
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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.
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 prices \47\ 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 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.
---------------------------------------------------------------------------
\47\ See www.eia.gov/electricity/wholesale/ (Last accessed
December 2013).
---------------------------------------------------------------------------
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.
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
[[Page 7791]]
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 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, 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 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 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
[[Page 7792]]
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 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)
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)
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.
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 high-
intensity 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
[[Page 7793]]
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 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, No. 56
at p. 24) Musco Lighting commented that the proposed standard requiring
pulse-start 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 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.
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 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
[[Page 7794]]
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 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 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 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 labor-intensive 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 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
[[Page 7795]]
due to shifts in economic activity resulting from new and amended
standards for metal halide lamp fixtures.
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\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 email to[email protected]. 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 Input-Output Modeling System (RIMS
II), Washington, DC, U.S. Department of Commerce, 1992.
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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 special-purpose 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.
---------------------------------------------------------------------------
\50\ Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1:
Impact of Sector Energy Technologies (PNNL-18412 Pacific Northwest
National Laboratory) (2009). Available at www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf. (Last
accessed October 2013.)
---------------------------------------------------------------------------
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 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 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
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.
---------------------------------------------------------------------------
\51\ See www.epa.gov/climateleadership/guidance/ghg-emissions.html.
\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.
---------------------------------------------------------------------------
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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous states and the
District of Columbia (DC). SO2 emissions from 28 eastern
states and DC 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.
[[Page 7796]]
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 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 non-HAP 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.
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 EGUs \54\ 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 cosignatories \55\ (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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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.
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.
[[Page 7797]]
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 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 Council \57\
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.
---------------------------------------------------------------------------
\57\ National Research Council. Hidden Costs of Energy: Unpriced
Consequences of Energy Production and Use. National Academies Press:
Washington, DC (2009).
---------------------------------------------------------------------------
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 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 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).
---------------------------------------------------------------------------
\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).
---------------------------------------------------------------------------
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing CO2 emissions. 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 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
peer-reviewed 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
[[Page 7798]]
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 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.
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 peer-reviewed 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-for-regulator-impact-analysis.pdf.
Table V.11--Annual SCC Values from 2013 Interagency Update, 2010-2050
[In 2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate %
------------------------------------------------------
5 3 2.5 3
Year ------------------------------------------------------
95th
Average Average Average 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
[[Page 7799]]
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 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.
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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 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)
---------------------------------------------------------------------------
\63\ Available at: http://www.cio.noaa.gov/services_programs/pdfs/OMB_Peer_Review_Bulletin_m05-03.pdf
---------------------------------------------------------------------------
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, 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.
---------------------------------------------------------------------------
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 W-150 W
MHLFs, DOE found that EL4, the max-tech level, was economically
justified. However, for the 150 W-250
[[Page 7800]]
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)
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 high-frequency 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
max-tech 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 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.
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 low-frequency 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 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
[[Page 7801]]
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).
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).
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)
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
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
[[Page 7802]]
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 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 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.
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
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* 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 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.
---------------------------------------------------------------------------
\65\ The 501 W-1000 W equipment class requires modeled 1000 W
ballasts, but 875 W ballasts are commercially available.
---------------------------------------------------------------------------
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
[[Page 7803]]
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 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.
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 mid-grade 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 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7804]]
Table VII.3--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Indoor, Electronic Baseline): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.4--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Outdoor, Magnetic Baseline): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.7--Equipment Class 2--150 Watt Metal Halide Lamp Fixtures (outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
[[Page 7805]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.9--Equipment Class 3--250 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.11--Equipment Class 4--400 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
[[Page 7806]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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.
Table VII.13--Equipment Class 5--1000 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7807]]
Table VII.15--Equipment Class 6--1500 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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) 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.
Table VII.16--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Indoor, Magnetic Baseline): LCC Subgroup Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC Savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7808]]
Table VII.17--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Indoor, Electronic Baseline): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC Savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.18--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Outdoor, Magnetic Baseline): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7809]]
Table VII.19--Equipment Class 1--70 Watt Metal Halide Lamp Fixtures (Outdoor, Electronic Baseline): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.20--Equipment Class 2--150 Watt Metal Halide Lamp Fixtures (Indoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.21--Equipment Class 2--150 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
[[Page 7810]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.22--Equipment Class 3--250 Watt Metal Halide Lamp Fixtures (Indoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
[[Page 7811]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.24--Equipment Class 4--400 Watt Metal Halide Lamp Fixtures (Indoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7812]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.25--Equipment Class 4--400 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7813]]
Table VII.26--Equipment Class 5--1000 Watt Metal Halide Lamp Fixtures (Indoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
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.
Table VII.27--Equipment Class 5--1000 Watt Metal Halide Lamp Fixtures (Outdoor): LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------ Median
Percent of customers payback
Trial standard level Efficiency level Installed Discounted Average that experience period
cost operating LCC savings -------------------------- years
cost 2012$ 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
[[Page 7814]]
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
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.
Table VII.28--Fixture Efficiency Levels With a Rebuttable Payback Period
of Less Than Three Years
------------------------------------------------------------------------
Mean payback
Equipment class Efficiency level period years
------------------------------------------------------------------------
70 W (indoor, magnetic 1.................... 1.3
baseline).
70 W (outdoor, magnetic 1.................... 1.4
baseline).
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,
[[Page 7815]]
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.
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
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.
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------
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
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
INPV......................... (2012$ 67 50 49 48 51 48
millions).
Change in INPV............... (2012$ ......... (16.5) (17.9) (19.0) (16.2) (19.0)
millions).
(%)............ ......... -24.6 -26.7 -28.3 -24.1 -28.3
[[Page 7816]]
Product Conversion Costs..... (2012$ ......... 11 12 12 16 20
millions).
Capital Conversion Costs..... (2012$ ......... 9 10 11 4 5
millions).
----------------------------------------------------------------------------------
Total Conversion Costs... (2012$ ......... 21 22 23 21 24
millions).
----------------------------------------------------------------------------------------------------------------
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 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 high-shipment scenario,
shipments are 130 percent higher than shipments under the low-shipment
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.
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 $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
[[Page 7817]]
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.
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 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 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 $24 million in conversion costs, resulting in INPV
results remaining negative at TSL 5.
Cash Flow Analysis Results by TSL for Metal Halide Lamp Fixtures
DOE incorporated the same scenarios to represent the upper and
lower bounds of industry impacts for MHLFs as for MH ballasts: the flat
markup scenario with the high-shipment scenario and the preservation of
operating profit markup scenario with the low-shipment scenario. Note
that the TSLs below represent the same sets of efficiency levels as
discussed in the previous section in the description of impacts on MH
ballast manufacturers.
Table VII.31--Manufacturer Impact Analysis for Metal Halide Lamp Fixtures--Flat Markup and High-Shipment Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 7818]]
Table VII.32--Manufacturer Impact Analysis for Metal Halide Lamp Fixtures--Preservation of Operating Profit
Markup and Low-Shipment Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
INPV......................... (2012$ 346 342 342 342 285 257
millions).
Change in INPV............... (2012$ (3.6) (3.6) (3.6) (60.4) (88.6)
millions).
(%)............ -1.0 -1.0 -1.1 -17.5 -25.6
Product Conversion Costs..... (2012$ 3 3 3 45 62
millions).
Capital Conversion Costs..... (2012$ 0 0 0 32 50
millions).
----------------------------------------------------------------------------------
Total Conversion Costs... (2012$ 3 3 3 77 112
millions).
----------------------------------------------------------------------------------------------------------------
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 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 high-shipment 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 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 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.
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
[[Page 7819]]
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.
The production worker estimates in this section cover only workers
up to the line-supervisor 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 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 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 345 393 408 415 419 440
(without changes in production locations)..............
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.
[[Page 7820]]
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 339 386 401 408 412 432
(without changes in production locations)..............
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 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 per-unit 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.
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 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 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
[[Page 7821]]
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.
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 high-shipments 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.
Table VII.35--Cumulative National Primary Energy Savings for Metal Halide Lamp Fixture Trial Standard Levels for
Units Sold in 2017-2046
----------------------------------------------------------------------------------------------------------------
National primary energy savings quads
---------------------------------------
Trial standard level Equipment class Low-shipments High-shipments
scenario 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
---------------------------------------------------------------------
[[Page 7822]]
Total.................... 0.81 1.02
----------------------------------------------------------------------------------------------------------------
Table VII.36--Cumulative National Full-Fuel-Cycle Energy Savings for Metal Halide Lamp Fixture Trial Standard
Levels for Units Sold in 2017-2046
----------------------------------------------------------------------------------------------------------------
National FFC energy savings quads
---------------------------------------
Trial standard level Equipment class Low-shipments High-shipments
scenario 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 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
[[Page 7823]]
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.
Table VII.37--Cumulative National Primary Energy Savings for Metal Halide Lamp Fixture Trial Standard Levels for
Units Sold in 2017-2025
----------------------------------------------------------------------------------------------------------------
National primary energy savings quads
---------------------------------------
Trial standard level Equipment class Low-shipments High-shipments
scenario 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 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
[[Page 7824]]
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.
---------------------------------------------------------------------------
\67\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
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.
Table VII.38--Net Present Value of Customer Benefits for Metal Halide Lamp Fixture Trial Standard Levels for Units Sold in 2017-2046
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net present value billion 2012$
-------------------------------------------------------------------------------
Low-shipments scenario High-shipments scenario
Trial standard level Equipment class -------------------------------------------------------------------------------
7-percent discount 3-percent discount 7-percent discount 3-percent discount
rate rate rate 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 informational purposes only and is
not indicative of any change in DOE's analytical methodology or
decision criteria.
[[Page 7825]]
Table VII.39--Net Present Value of Customer Benefits for Metal Halide Lamp Fixture Trial Standard Levels for Units Sold in 2017-2025
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net present value billion 2012$
-------------------------------------------------------------------------------
Low-shipments scenario High-shipments scenario
Trial standard level Equipment class -------------------------------------------------------------------------------
7-percent discount 3-percent discount 7-percent discount 3-percent discount
rate rate rate 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
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]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net present value billion 2012$
-------------------------------------------------------------------------------
Indoor fixtures Outdoor fixtures
Trial standard level Equipment class -------------------------------------------------------------------------------
7-percent discount 3-percent discount 7-percent discount 3-percent discount
rate rate rate rate
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 70 W........................ 0.001 0.001 0.017 0.033
150 W....................... 0.008 0.019 0.023 0.056
[[Page 7826]]
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
----------------------------------------------------------------------------------------------------------------
Net national change in jobs
---------------------------------------
Analysis period year Trial standard level Low shipments High shipments
scenario, roll-up scenario, roll-up
----------------------------------------------------------------------------------------------------------------
2018...................................... 1........................... -60 150
2........................... -85 260
[[Page 7827]]
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
----------------------------------------------------------------------------------------------------------------
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 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.
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
[[Page 7828]]
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
----------------------------------------------------------------------------------------------------------------
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 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 $117.0/ton. These values for later years are higher due
to increasing emissions-related costs as the magnitude of projected
climate change increases.
Table VII.44 and Table VII.45 present the global value of
CO2 emissions reductions at each TSL for the low and high
shipment scenarios, respectively. DOE calculated domestic values as a
range from 7 percent to 23 percent of the global values, and these
results are presented in chapter 17 of the final rule TSD.
[[Page 7829]]
Table VII.44--Global Present Value of CO2 Emissions Reduction for Potential Standards for Metal Halide Lamp
Fixtures
[Low shipments scenario]
----------------------------------------------------------------------------------------------------------------
SCC scenario *
---------------------------------------------------------------
TSL 3% discount
5% discount 3% discount 2.5% discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
million 2012$
----------------------------------------------------------------------------------------------------------------
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
$117.0 per metric ton (2012$).
Table VII.45--Global Present Value of CO2 Emissions Reduction for Potential Standards for Metal Halide Lamp
Fixtures
[High shipments scenario]
----------------------------------------------------------------------------------------------------------------
SCC scenario *
---------------------------------------------------------------
TSL 3% discount
5% discount 3% discount 2.5% discount rate, 95th
rate, average rate, average rate, average 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
$117.0 per metric ton (2012$).
[[Page 7830]]
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.
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.
Table VII.46--Present Value of NOX Emissions Reduction for Potential Standards for Metal Halide Lamp Fixtures
----------------------------------------------------------------------------------------------------------------
Low shipments scenario High shipments scenario
---------------------------------------------------------------
TSL 3% discount 7% discount 3% discount 7% discount
rate rate rate 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.
[[Page 7831]]
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]
----------------------------------------------------------------------------------------------------------------
Customer NPV at 3% discount rate added with:
---------------------------------------------------------------
SCC value of SCC value of SCC value of SCC value of
TSL $11.8/metric $39.7/metric $61.2/metric $117.0/metric
ton CO2* and ton CO2* and ton CO2* and ton CO2* and
medium value medium value medium value medium value
for NOX** for NOX** for NOX** for NOX**
----------------------------------------------------------------------------------------------------------------
billion 2012$
----------------------------------------------------------------------------------------------------------------
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
----------------------------------------------------------------------------------------------------------------
Customer NPV at 7% discount rate added with:
----------------------------------------------------------------------------------------------------------------
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.
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]
----------------------------------------------------------------------------------------------------------------
Customer NPV at 3% discount rate added with:
---------------------------------------------------------------
SCC value of SCC value of SCC value of SCC value of
TSL $11.8/metric $39.7/metric $61.2/metric $117.0/metric
ton CO2* and ton CO2* and ton CO2* and ton CO2* and
medium value medium value medium value medium value
for NOX** for NOX** for NOX** for NOX**
----------------------------------------------------------------------------------------------------------------
billion 2012$
----------------------------------------------------------------------------------------------------------------
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
----------------------------------------------------------------------------------------------------------------
Customer NPV at 7% discount rate added with:
----------------------------------------------------------------------------------------------------------------
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
[[Page 7832]]
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 (discounted at 7 and 3
percent), emissions reductions, industry net present value, life-cycle
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 $413 393................... 391................... 390.................. 336.................. 305
million).
Ballast + Fixture Industry NPV (20.1)................ (21.5)................ (22.6)............... (76.6)............... (107.5)
(change in 2012$million).
Ballast + Fixture Industry NPV -4.9%................. -5.2%................. -5.5%................ -18.6%............... -26.1%
(% change).
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
NOX--3% discount rate (2012$ 29.4.................. 37.2.................. 38.2................. 67.0................. 78.5
million)**.
NOX--7% discount rate (2012$ 13.7.................. 17.3.................. 17.8................. 31.2................. 36.5
million)**.
Mean LCC Savings (and Percent
Customers Experiencing Net
Benefit)*** (2012$)
50to100W--Ind--OtherV****[dagge 26.97 (100)........... 27.00 (100)........... 27.00 (100).......... 42.50 (82)........... 37.25 (79)
r] (magnetic baseline).
50to100W--Outd--OtherV 34.24 (98)............ 34.88 (97)............ 34.88 (97)........... -4.98 (51)........... -11.15 (49)
(magnetic baseline).
50to100W--Ind--OtherV --.................... --.................... --................... --................... -5.25 (10)
(electronic baseline).
[[Page 7833]]
50to100W--Outd--OtherV --.................... --.................... --................... --................... -6.17 (12)
(electronic baseline).
101to150W--Ind--OtherV[Dagger]. 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[Dagger]. 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 1.4................... 4.5................... 4.5.................. 3.7.................. 6.0
baseline).
50to100W--Outd--OtherV 1.4................... 4.5................... 4.5.................. 12.0................. 14.7
(magnetic baseline).
50to100W--Ind--OtherV --.................... --.................... --................... --................... 31.5
(electronic baseline).
50to100W--Outd--OtherV --.................... --.................... --................... --................... 55.8
(electronic baseline).
101to150W--Ind--OtherV[Dagger]. 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[Dagger]. 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)
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 $2639/ton.
*** For LCCs, a negative value means an increase in LCC by the amount indicated.
**** ``Indoor'' and ``outdoor'' as defined in section V.A.2.
[dagger] Equipment class abbreviations in the form of 50 to100W--Ind--OtherV refers to the equipment class of fixtures with (1) a rated lamp wattage of
50 W to 100 W, (2) an indoor operating location, and (3) a tested input voltage other than 480 V. See section V.A.2 for more detail on equipment class
distinctions.
[Dagger] The >100 W and <=150 W equipment classes include 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps that
are also rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A) and contain a ballast that is rated to operate at ambient
air temperatures above 50 [deg]C, as specified by UL 1029-2007. The >=150 W and <=250 W equipment classes contain all other covered fixtures that are
rated only for 150 watt lamps.
Changes in 2022.
Table VII.50--Summary of Results for Metal Halide Lamp Fixtures
[High shipments scenario)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
National Energy Savings (quads)... 0.39.................. 0.49.................. 0.50.................. 0.88................. 1.03
NPV of Customer Benefits (2012$
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 478................... 491................... 497................... 501.................. 497
$453 million).
Ballast + Fixture Industry NPV 25.3.................. 38.0.................. 44.0.................. 48.1................. 44.2
(change in 2012$million).
Ballast + Fixture Industry NPV 5.6%.................. 8.4%.................. 9.7%.................. 10.6%................ 9.7%
(% change).
Cumulative Emissions Reduction
[[Page 7834]]
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$ 35.0.................. 44.2.................. 45.4.................. 79.4................. 93.1
million) **.
NOX--7% discount rate (2012$ 15.6.................. 19.8.................. 20.3.................. 35.5................. 41.6
million) **.
Mean LCC Savings (and Percent
Customers Experiencing Net
Benefit) *** (2012$)
50to100W--Ind--OtherV 26.97 (100)........... 27.00 (100)........... 27.00 (100)........... 42.50 (82)........... 37.25 (79)
****[dagger] (magnetic
baseline).
50to100W--Outd--OtherV 34.24 (98)............ 34.88 (97)............ 34.88 (97)............ -4.98 (51)........... -11.15 (49)
(magnetic baseline).
50to100W--Ind--OtherV ...................... ...................... ...................... ..................... -5.25 (10)
(electronic baseline).
50to100W--Outd--OtherV ...................... ...................... ...................... ..................... -6.17 (12)
(electronic baseline).
100to149W--Ind--OtherV[Dagger] 22.43 (100)........... 24.63 (99)............ 24.63 (99)............ 89.67 (94)........... 76.11 (89)
100to149W--Outd--OtherV....... 27.37 (97)............ 30.70 (97)............ 30.70 (97)............ 52.23 (66)........... 36.60 (62)
150to250W--Ind--OtherV[Dagger] 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 1.4................... 4.5................... 4.5................... 3.7.................. 6.0
(magnetic baseline).
50to100W--Outd--OtherV 1.4................... 4.5................... 4.5................... 12.0................. 14.7
(magnetic baseline).
50to100W--Ind--OtherV ...................... ...................... ...................... ..................... 31.5
(electronic baseline).
50to100W--Outd--OtherV ...................... ...................... ...................... ..................... 55.8
(electronic baseline).
100to149W--Ind--OtherV[Dagger] 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[Dagger] 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.
[dagger] 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.
[Dagger] 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 [deg]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.
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
[[Page 7835]]
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.
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 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 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.
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.
[[Page 7836]]
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 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 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 $1,632, 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 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 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+1.24xP[supcaret] (1+1.24xP[supcaret]
(-0.351)) [dagger]. (-0.351))
>100 W and <150 W *............... EL2............................. 1/ 1/
(1+1.24xP[supcaret] (1+1.24xP[supcaret]
(-0.351)). (-0.351))
>=150 W ** and <=250 W............ EL1............................. >=150 W and <=200 W: >=150 W and <=200 W:
0.88. 0.88
>200 W and <=250 W: >200 W and <=250 W:
0.000400xP + 0.800. 1/
(1+0.876xP[supcaret
](-0.351))
>250 W and <=500 W................ EL2............................. 0.910............... 1/
(1+0.876xP[supcaret
](-0.351))
>500 W and <=1000 W............... EL2............................. >500 W and <=750 W: >500 W and <=750 W:
0.910. 0.910
[[Page 7837]]
>750 W and <=1000 W: >750 W and <=1000 W:
0.000104xP + 0.832.. 0.000104xP + 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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] 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 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[dagger]
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W.................... EL2................................. (1/(1+1.24xP[supcaret](-0.351)) -
0.0200)
>100 W and <150 W *................... EL2................................. (1/(1+1.24xP[supcaret](-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+0.876xP[supcaret](-0.351)) -
0.0100
>500 W and <=1000 W................... EL2................................. >500 W and <=750 W: 0.900
>750 W and <=1000 W: 0.000104xP +
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 [deg]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 [deg]C, as specified by UL 1029-2007.
[dagger] 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 88 percent efficiency if pulse-start,
94 percent if probe-start magnetic, 90 percent if non-pulse-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 [deg]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 [deg]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 [deg]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 W \68\ range,
there are no existing federal 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
[deg]C) are not covered by any existing federal energy conservation
standards, so the standards set for such
[[Page 7838]]
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 W \69\ -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.
---------------------------------------------------------------------------
\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 [deg]C, as specified by UL 1029-2007.
\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 [deg]C, as specified by UL 1029-2007.
---------------------------------------------------------------------------
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 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 Adopted efficiency
lamps of the following rated Indoor/outdoor*** Test input Existing standards standards/
lamp wattage voltage[Dagger] (efficiency) equations[dagger] %
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W............. Indoor............ 480 V............. N/A............... (1/
(1+1.24xP[supcaret
](-0.351))) -
0.020
>=50 W and <=100 W............. Indoor............ All others........ N/A............... 1/
(1+1.24xP[supcaret
](-0.351))
>=50 W and <=100 W............. Outdoor........... 480 V............. N/A............... (1/
(1+1.24xP[supcaret
](-0.351))) -
0.020
>=50 W and <=100 W............. Outdoor........... All others........ N/A............... 1/
(1+1.24xP[supcaret
](-0.351))
>100 W and <150 W*............. Indoor............ 480 V............. N/A............... (1/
(1+1.24xP[supcaret
](-0.351))) -
0.020
>100 W and <150 W*............. Indoor............ All others........ N/A............... 1/
(1+1.24xP[supcaret
](-0.351))
>100 W and <150 W*............. Outdoor........... 480 V............. N/A............... (1/
(1+1.24xP[supcaret
](-0.351))) -
0.020
>100 W and <150 W*............. Outdoor........... All others........ N/A............... 1/
(1+1.24xP[supcaret
](-0.351))
>=150 W** and <=250 W.......... Indoor............ 480 V............. Varies from 88% to 0.880
94% depending on
ballast type.
>=150 W** and <=250 W.......... Indoor............ All others........ Varies from 88% to For >=150 W and
94% depending on <=200 W: 0.880
ballast type.
For >200 W and
<=250 W: 1/
(1+0.876xP[supcare
t](-0.351))
>=150 W** and <=250 W.......... Outdoor........... 480 V............. Varies from 88% to 0.880
94% depending on
ballast type.
>=150 W** and <=250 W.......... Outdoor........... All others........ Varies from 88% to For >=150 W and
94% depending on <=200 W: 0.880
ballast type.
For >200 W and
<=250 W: 1/
(1+0.876xP[supcare
t](-0.351))
>250 W and <=500 W............. Indoor............ 480 V............. Varies from 88% to For >250 W and <265
94% depending on W: 0.880
ballast type.
For >=265 W and
<=500 W;: (1/
(1+0.876xP[supcare
t](-0.351))--0.010
>250 W and <=500 W............. Indoor............ All others........ Varies from 88% to 1/
94% depending on (1+0.876xP[supcare
ballast type. t](-0.351))
>250 W and <=500 W............. Outdoor........... 480 V............. Varies from 88% to For >250 W and <265
94% depending on W: 0.880
ballast type.
For >=265 W and
<=500 W;: (1/
(1+0.876xP[supcare
t](-0.351)) -
0.010
>250 W and <=500 W............. Outdoor........... All others........ Varies from 88% to 1/
94% depending on (1+0.876xP[supcare
ballast type. t](-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:
0.000104xP+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:
0.000104xP+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:
0.000104xP+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
[[Page 7839]]
For >750 W and
<=1000 W:
0.000104xP+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 NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to
operate at ambient air temperatures above 50 [deg]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 [deg]C, as specified by UL 1029-2007.
***DOE's definitions for ``indoor'' and ``outdoor'' MHLFs are described in section V.A.2.
[dagger]P is defined as the rated wattage of the lamp the fixture is designed to operate.
[Dagger]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 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 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.
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 byE.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 Web site (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
[[Page 7840]]
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.
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.
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 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 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 Web sites, 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
[[Page 7841]]
serve the architectural or specialty lighting 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.
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.
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.
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 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
[[Page 7842]]
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.
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. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
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 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 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
[[Page 7843]]
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 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 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 Web site:
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).
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.
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, as set forth below:
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
0
2. Section 431.322 is amended by adding in alphabetical order
definitions for ``general lighting application'' ``high-frequency
electronic metal halide ballast,'' and ``nonpulse-start electronic
ballast,'' to read as follows:
Sec. 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.
* * * * *
0
3. Section 431.324 is amended by adding paragraph (b)(1)(iii) and
revising paragraphs (b)(3) and (c)(1) to read as follows:
Sec. 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.
(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) * * *
[[Page 7844]]
(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 Sec. 431.323). Ambient temperatures for the testing
period shall be maintained at 25 [deg]C 5 [deg]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.
* * * * *
0
4. Section 431.326 is amended by adding paragraphs (c), (d), and (e) to
read as follows:
Sec. 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 February 10, 2017, must contain a
metal halide ballast with an efficiency not less than the value
determined from the appropriate equation in the following table:
----------------------------------------------------------------------------------------------------------------
Designed to be operated with lamps of Tested input Minimum standard
the following rated lamp wattage voltage[Dagger][Dagger] equation[dagger][dagger] %
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W.................... Tested at 480 V..................... (1/(1+1.24xP[supcaret](-0.351))) -
0.020[dagger][dagger]
>=50 W and <=100 W.................... All others.......................... 1/(1+1.24xP[supcaret](-0.351))
>100 W and <150[dagger] W............. Tested at 480 V..................... (1/(1+1.24xP[supcaret](-0.351))) -
0.020
>100 W and <150[dagger] W............. All others.......................... 1/(1+1.24xP[supcaret](-0.351))
>=150 [Dagger] W and <=250 W.......... Tested at 480 V..................... 0.880
>=150 [Dagger] W and <=250 W.......... All others.......................... For >=150 W and <=200 W: 0.880
For >200 W and <=250 W: 1/
(1+0.876xP[supcaret](-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+0.876xP[supcaret](-0.351)) -
0.010
>250 W and <=500 W.................... All others.......................... 1/(1+0.876xP[supcaret](-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:
0.000104xP+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:
0.000104xP+0.832
For >500 W and <=1000 W: may not
utilize a probe-start ballast
----------------------------------------------------------------------------------------------------------------
[dagger] 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 NFPA 70 (incorporated by reference, see Sec.
431.323), section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures
above 50 [deg]C, as specified by UL 1029 (incorporated by reference, see Sec. 431.323).
[Dagger] 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 NFPA 70, section 410.4(A); and containing a
ballast that is rated to operate at ambient air temperatures above 50 [deg]C, as specified by UL 1029.
[dagger][dagger] P is defined as the rated wattage of the lamp the fixture is designed to operate.
[Dagger][Dagger] 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 February 10, 2017, that
operate lamps with rated wattage >500 W to <=1000 W must not contain a
probe-start metal halide ballast.
(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.
[FR Doc. 2014-02356 Filed 2-7-14; 8:45 am]
BILLING CODE 6450-01-P