Energy Conservation Program: Energy Conservation Standards for Metal Halide Lamp Fixtures, 47472-47506 [2020-14540]
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Federal Register / Vol. 85, No. 151 / Wednesday, August 5, 2020 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE–2017–BT–STD–0016]
RIN 1904–AD89
Energy Conservation Program: Energy
Conservation Standards for Metal
Halide Lamp Fixtures
Office of Energy Efficiency and
Renewable Energy, Department of
Energy (DOE).
ACTION: Notice of proposed
determination and request for comment.
AGENCY:
The Energy Policy and
Conservation Act, as amended
(‘‘EPCA’’), directs DOE to determine
whether standards for metal halide lamp
fixtures (‘‘MHLFs’’) should be amended.
In this notice of proposed determination
(‘‘NOPD’’), DOE has initially determined
that the energy conservation standards
for metal halide lamp fixtures do not
need to be amended and also asks for
comment on this proposed
determination and associated analyses
and results.
DATES:
Meeting: DOE will hold a webinar on
Thursday, August 27, 2020, from 10:00
a.m. to 3:00 p.m. See section VII,
‘‘Public Participation,’’ for webinar
registration information, participant
instructions, and information about the
capabilities available to webinar
participants. If no participants register
for the webinar than it will be cancelled.
DOE will hold a public meeting on this
proposed determination if one is
requested by August 19, 2020.
Comments: DOE will accept
comments, data, and information
regarding this NOPD no later than
October 19, 2020.
ADDRESSES: Interested persons are
encouraged to submit comments using
the Federal eRulemaking Portal at
https://www.regulations.gov. Follow the
instructions for submitting comments.
Alternatively, interested persons may
submit comments, identified by docket
number EERE–2017–BT–STD–0016, by
any of the following methods:
1. Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: MHLF2017STD0016@
ee.doe.gov. Include the docket number
EERE–2017–BT–STD–0016 in the
subject line of the message.
3. Postal Mail: Appliance and
Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–5B,
1000 Independence Avenue SW,
Washington, DC 20585–0121.
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Telephone: (202) 287–1445. If possible,
please submit all items on a compact
disc (‘‘CD’’), in which case it is not
necessary to include printed copies.
4. Hand Delivery/Courier: Appliance
and Equipment Standards Program, U.S.
Department of Energy, Building
Technologies Office, 950 L’Enfant Plaza
SW, 6th Floor, Washington, DC 20024.
Telephone: (202) 287–1445. If possible,
please submit all items on a CD, in
which case it is not necessary to include
printed copies.
No telefacsimilies (‘‘faxes’’) will be
accepted. For detailed instructions on
submitting comments and additional
information on this process, see section
VII of this document.
Docket: The docket, which includes
Federal Register notices, comments,
and other supporting documents/
materials, is available for review at
https://www.regulations.gov. All
documents in the docket are listed in
the https://www.regulations.gov index.
However, not all documents listed in
the index may be publicly available,
such as information that is exempt from
public disclosure.
The docket web page can be found at
https://www.regulations.gov/docket?
D=EERE-2017-BT-STD-0016. The docket
web page contains simple instructions
on how to access all documents,
including public comments, in the
docket. See section VII, ‘‘Public
Participation,’’ for further information
on how to submit comments through
https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Ms.
Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (202) 287–
1604. Email:
ApplianceStandardsQuestions@
ee.doe.gov.
Ms. Kathryn McIntosh, U.S.
Department of Energy, Office of the
General Counsel, GC–33, 1000
Independence Avenue SW, Washington,
DC 20585–0121. Telephone: (202) 586–
2002. Email: Kathryn.McIntosh@
hq.doe.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact the
Appliance and Equipment Standards
Program staff at (202) 287–1445 or by
email: ApplianceStandardsQuestions@
ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Determination
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II. Introduction
A. Authority and Background
1. Current Standards
2. History of Standards Rulemaking for
MHLFs
III. General Discussion
A. Product/Equipment Classes and Scope
of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers
and Consumers
b. Savings in Operating Costs Compared
To Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of
Products
e. Impact of Any Lessening of
Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related
Comments
A. Overall
B. Market and Technology Assessment
1. Scope of Coverage
2. Metric
3. Equipment Classes
a. Existing equipment classes
b. Summary
4. Technology Options
5. Screening Analysis
a. Screened-Out Technologies
b. Remaining Technologies
C. Engineering Analysis
1. Representative Equipment Classes
2. Baseline Ballasts
3. More-Efficient Ballasts
4. Efficiency Levels
5. Design Standard
6. Scaling to Other Equipment Classes
7. Manufacturer Selling Price
a. Fixtures
b. Ballasts
D. Markups Analysis
1. Distribution Channels
2. Estimation of Markups
3. Summary of Markups
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period
Analysis
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Replacement Costs
6. Equipment Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the NoNew-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. National Energy Savings
2. Net Present Value Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
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B. Economic Impacts on Individual
Customers
1. Life-Cycle Cost and Payback Period
2. Rebuttable Presumption Payback
C. National Impact Analysis
1. Significance of Energy Savings
2. Net Present Value of Customer Costs and
Benefits
D. Proposed Determination
1. Technological Feasibility
2. Significant Conservation of Energy
3. Economic Justification
4. Summary
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under Executive Orders 13771
and 13777
C. Review Under the Regulatory Flexibility
Act
D. Review Under the National
Environmental Policy Act
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. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Submission of Comments
C. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed
Determination
Title III, Part B 1 of EPCA,2 established
the Energy Conservation Program for
Consumer Products Other Than
Automobiles. (42 U.S.C. 6291–6309)
These products include metal halide
lamp fixtures (‘‘MHLFs’’), the subject of
this notice of proposed determination
(‘‘NOPD’’). (42 U.S.C. 6292(a)(19))
EPCA established initial standards for
MHLFs. (42 U.S.C. 6295(hh)(1)(A))
EPCA directed the U.S. Department of
Energy (‘‘DOE’’) to conduct a review of
the statutory standards to determine
whether they should be amended, and
a subsequent review to determine if the
standards then in effect should be
amended. (42 U.S.C. 6295(hh)(2) and
(3)) DOE conducted the first review of
MHLF energy conservation standards
and published a final rule amending
standards on February 10, 2014. 79 FR
7746.3 DOE is issuing this NOPD
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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 America’s Water
Infrastructure Act of 2018, Public Law 115–270
(Oct. 23, 2018).
3 DOE notes that because of the codification of the
MHLF provisions in 42 U.S.C. 6295, MHLF energy
conservation standards and the associated test
procedures are subject to the requirements of the
consumer products provisions of Part B of Title III
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pursuant to the EPCA requirement that
DOE conduct a second review of MHLF
energy conservation standards. (42
U.S.C. 6295(hh)(3)(A))
For this proposed determination, DOE
analyzed MHLFs subject to standards
specified in 10 CFR 431.326(c). DOE
first analyzed the technological
feasibility of more efficient MHLFs. For
those MHLFs for which DOE
determined higher standards to be
technologically feasible, DOE estimated
energy savings that could result from
potential energy conservation standards
by conducting a national impacts
analysis (‘‘NIA’’). DOE evaluated
whether higher standards would be cost
effective by conducting life-cycle cost
(‘‘LCC’’) and payback period (‘‘PBP’’)
analyses, and estimated the net present
value (‘‘NPV’’) of the total costs and
benefits experienced by consumers.
Based on the results of these analyses,
summarized in section V of this
document, DOE has tentatively
determined that current standards for
metal halide lamp fixtures do not need
to be amended because more stringent
standards would not have significant
energy savings and would not be
economically justified.
II. Introduction
The following section briefly
discusses the statutory authority
underlying this proposed determination,
as well as some of the relevant historical
background related to the establishment
of standards for MHLFs.
A. Authority and Background
EPCA authorizes DOE to regulate the
energy efficiency of a number of
consumer products and certain
industrial equipment. Title III, Part B of
EPCA established the Energy
Conservation Program for Consumer
Products Other Than Automobiles,
which includes MHLFs that are the
subject of this proposed determination.
(42 U.S.C. 6292(a)(19)) EPCA, as
amended by the Energy Independence
and Security Act of 2007 (Pub. L. 110–
140, EISA 2007), prescribed energy
conservation standards for this
equipment. (42 U.S.C. 6295(hh)(1))
EPCA directed DOE to conduct two
rulemaking cycles to determine whether
of EPCA. However, because MHLFs are generally
considered to be commercial equipment, DOE
established the requirements for MHLFs in 10 CFR
part 431 (‘‘Energy Efficiency Program for Certain
Commercial and Industrial Equipment’’) for ease of
reference. DOE notes that the location of the
provisions within the CFR does not affect either the
substance or applicable procedure for MHLFs.
Based upon their placement into 10 CFR part 431,
MHLFs are referred to as ‘‘equipment’’ throughout
this document, although covered by the consumer
product provisions of EPCA.
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to amend these standards. (42 U.S.C.
6295(hh)(2)(A) and (3)(A)) DOE
published a final rule amending the
standards on February 10, 2014 (‘‘2014
MHLF final rule’’). 79 FR 7746. Under
42 U.S.C. 6295(hh)(3)(A), the agency
must conduct a second review to
determine whether current standards
should be amended and publish a final
rule. This second MHLF standards
rulemaking was initiated through the
publication of a request for information
(‘‘RFI’’) document in the Federal
Register. 84 FR 31231 (‘‘July 2019 RFI’’)
Pursuant to EPCA, DOE’s energy
conservation program for covered
products, which as noted includes
MHLFs, consists essentially of four
parts: (1) Testing, (2) labeling, (3) the
establishment of Federal energy
conservation standards, and (4)
certification and enforcement
procedures. Relevant provisions of the
EPCA specifically include definitions
(42 U.S.C. 6291), test procedures (42
U.S.C. 6293), labeling provisions (42
U.S.C. 6294), energy conservation
standards (42 U.S.C. 6295), and the
authority to require information and
reports from manufacturers (42 U.S.C.
6296).
Federal energy efficiency
requirements for covered products
established under EPCA generally
supersede State laws and regulations
concerning energy conservation testing,
labeling, and standards. (42 U.S.C.
6297(a)–(c)) DOE may, however, grant
waivers of Federal preemption in
limited instances for particular State
laws or regulations, in accordance with
the procedures and other provisions set
forth under EPCA. (See 42 U.S.C.
6297(d)).
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 each covered
product, including MHLFs. (42 U.S.C.
6295(o)(3)(A) and (r)) Manufacturers of
covered products must use the
prescribed DOE test procedure as the
basis for certifying to DOE that their
products comply with the applicable
energy conservation standards adopted
under EPCA and when making
representations to the public regarding
the energy use or efficiency of those
products. (42 U.S.C. 6293(c) and
6295(s)) Similarly, DOE must use these
test procedures to determine whether
the products comply with standards
adopted pursuant to EPCA. (42 U.S.C.
6295(s)) The DOE test procedures for
MHLFs appear at 10 CFR 431.324.
DOE must follow specific statutory
criteria for prescribing new or amended
standards for covered products, which
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include MHLFs. Any new or amended
standard for a covered product must be
designed to achieve the maximum
improvement in energy efficiency that
the Secretary of Energy determines is
technologically feasible and
economically justified. (42 U.S.C.
6295(o)(2)(A) and (3)(B)) 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
products, including MHLFs, if no test
procedure has been established for the
product, or (2) if DOE determines by
rule that the standard is not
technologically feasible or economically
justified. (42 U.S.C. 6295(o)(3)(A)–(B))
In deciding whether a proposed
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
statutory factors:
(1) The economic impact of the standard
on manufacturers and consumers of the
products subject to the standard;
(2) The savings in operating costs
throughout the estimated average life of the
covered products in the type (or class)
compared to any increase in the price, initial
charges, or maintenance expenses for the
covered products that are likely to result
from the standard;
(3) The total projected amount of energy (or
as applicable, water) savings likely to result
directly from the standard;
(4) Any lessening of the utility or the
performance of the covered products likely to
result from 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 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))
Further, EPCA establishes a rebuttable
presumption that a standard is
economically justified if the Secretary
finds that the additional cost to the
consumer of purchasing a product
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 consumer
will receive as a result of the standard,
as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as
an ‘‘anti-backsliding’’ provision, which
prevents the Secretary from prescribing
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)) 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 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.
(42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies
requirements when promulgating an
energy conservation standard for a
covered product that has two or more
subcategories. DOE must specify a
different standard level for a type or
class of product that has the same
function or intended use, if DOE
determines that products within such
group: (A) Consume a different kind of
energy from that consumed by other
covered products within such type (or
class); or (B) have a capacity or other
performance-related feature which other
products within such type (or class) do
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
products, DOE must consider such
factors as the utility to the consumer of
the 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))
Pursuant to the amendments
contained in the EISA 2007, any final
rule for new or amended energy
conservation standards promulgated
after July 1, 2010, is required to address
standby mode and off mode energy use.
(42 U.S.C. 6295(gg)(3)) Specifically,
when DOE adopts a standard for a
covered products, including MHLFs,
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 a single standard, or, if that is not
feasible, adopt a separate standard for
such energy use. (42 U.S.C.
6295(gg)(3)(A)–(B)) DOE’s current test
procedure for MHLFs addresses standby
mode energy use. However, in the 2014
MHLF final rule, DOE stated that it had
yet to encounter an MHLF that used
energy in standby mode and therefore
concluded that it could not establish a
standard that incorporated standby
mode energy consumption. Regarding
off mode, DOE concluded in the same
final rule that it is not possible for
MHLFs to meet off mode criteria
because there is no condition in which
the components of a MHLF are
connected to the main power source and
are not already in a mode accounted for
in either active or standby mode. 79 FR
7757.
EPCA further provides that, not later
than 6 years after the issuance of any
final rule establishing or amending a
standard, DOE must publish either a
notice of determination that standards
for the product do not need to be
amended, or a NOPR including new
proposed energy conservation standards
(proceeding to a final rule, as
appropriate). (42 U.S.C. 6295(m)(1)).
This NOPD also satisfies the 6-year
review provision of EPCA.
1. Current Standards
In the 2014 MHLF final rule, DOE
prescribed the current energy
conservation standards for MHLFs
manufactured on and after February 10,
2017. 79 FR 7746. These standards are
set forth in DOE’s regulations at 10 CFR
431.326 and are repeated in Table II.1.
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TABLE II.1—CURRENT ENERGY CONSERVATION STANDARDS FOR MHLFS
Designed to be operated with lamps of
the following rated lamp wattage
Tested input voltage *
≥50W and ≤100W ..................................
≥50W and ≤100W ..................................
>100W and <150W † ............................
>100W and <150W † ............................
≥150W ‡ and ≤250W .............................
≥150W ‡ and ≤250W .............................
480 V ............................
All others .......................
480 V ............................
All others .......................
480 V ............................
All others .......................
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Minimum standard equation *
(%)
(1/(1+1.24×P∧(¥0.351)))¥0.0200.**
1/(1+1.24×P∧(¥0.351)).
(1/(1+1.24×P∧(¥0.351)))¥0.0200.
1/(1+1.24×P∧(¥0.351)).
0.880.
For ≥150W and ≤200W: 0.880.
(1+0.876×P∧(¥0.351)).
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TABLE II.1—CURRENT ENERGY CONSERVATION STANDARDS FOR MHLFS—Continued
Designed to be operated with lamps of
the following rated lamp wattage
Tested input voltage *
Minimum standard equation *
(%)
>250W and ≤500W ...............................
480 V ............................
>250W and ≤500W ...............................
>500W and ≤1,000W ............................
All others .......................
480 V ............................
>500W and ≤1,000W ............................
All others .......................
For >250W and <265W: 0.880. For ≥265W and ≤500W: (1/
(1+0.876×P∧(¥0.351)))¥0.0100.
1/(1+0.876×P∧(¥0.351)).
>500W and ≤750W: 0.900. >750W and ≤1,000W: 0.000104×P + 0.822. For
>500W and ≤1,000W: may not utilize a probe-start ballast.
For >500W and ≤750W: 0.910. For >750W and ≤1,000W:
0.000104×P+0.832. For >500W and ≤1,000W: may not utilize a probestart ballast.
* Tested input voltage is specified in 10 CFR 431.324.
** P is defined as the rated wattage of the lamp the fixture is designed to operate.
† Includes 150 watt (W) fixtures specified in paragraph (b)(3) of this section, that are fixtures rated only for 150W lamps; rated for use in wet
locations, as specified by the National Fire Protection Association (‘‘NFPA’’) 70 (incorporated by reference, see § 431.323), section 410.4(A); and
containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by Underwriters Laboratory (UL) 1029 (incorporated by reference, see § 431.323).
‡ Excludes 150W fixtures specified in paragraph (b)(3) of this section, that are fixtures rated only for 150W 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 °C,
as specified by UL 1029.
2. History of Standards Rulemaking for
MHLFs
As described in section II.A, EPCA, as
amended by Public Law 110–140, EISA
2007, prescribed energy conservation
standards for MHLFs. (42 U.S.C.
6295(hh)(1)) EPCA directed DOE to
conduct two rulemaking cycles to
determine whether to amend these
standards. (42 U.S.C. 6295(hh)(2)(A) and
(3)(A)) DOE completed the first of these
rulemaking cycles in 2014 by adopting
amended performance standards for
MHLFs manufactured on or after
February 10, 2017. 79 FR 7746. The
current energy conservation standards
are located in 10 CFR part 431. See 10
CFR 431.326 (detailing the applicable
energy conservation standards for
different classes of MHLFs). The
currently applicable DOE test
procedures for MHLFs appear at 10 CFR
431.324. Under 42 U.S.C.
6295(hh)(3)(A), the agency is instructed
to conduct a second review of its energy
conservation standards for MHLFs and
publish a final rule to determine
whether to amend those standards. DOE
initiated the second MHLF standards
rulemaking process on July 1, 2019, by
publishing the July 2019 RFI.
DOE received five comments in
response to the July 2019 RFI from the
interested parties listed in Table II.2.
TABLE II.2—JULY 2019 RFI WRITTEN COMMENTS
Organization(s)
Reference in this
NOPD
National Electrical Manufacturers Association ..............................................................................
Edison Electric Institute .................................................................................................................
The Institute for Policy Integrity at New York University School of Law ......................................
Pacific Gas and Electric, Southern California Edison, San Diego Gas and Electric ...................
Signify North America Corporation ...............................................................................................
NEMA .........................
EEI ..............................
IPI ...............................
CA IOUs .....................
Signify .........................
A parenthetical reference at the end of
a comment quotation or paraphrase
provides the location of the item in the
public record.4
III. General Discussion
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DOE developed this proposal after
considering oral and written comments,
data, and information from interested
parties that represent a variety of
interests. The following discussion
addresses issues raised by these
commenters.
4 The parenthetical reference provides a reference
for information located in the docket of DOE’s
rulemaking to develop energy conservation
standards for metal halide lamp fixtures. (Docket
No. EERE–2017–BT–STD–0016, which is
maintained at www.regulations.gov/
#!docketDetail;D=EERE-2017-BT-STD-0016). The
references are arranged as follows: (Commenter
name, comment docket ID number, page of that
document).
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Organization type
Trade Association.
Utility Association.
Think Tank.
Utilities.
Manufacturer.
A. Product/Equipment Classes and
Scope of Coverage
detail in section IV.B.1 of this
document.
When evaluating and establishing
energy conservation standards, DOE
divides covered product into product
classes by the type of energy used or by
capacity or other performance-related
features that justify differing standards.
In making a determination whether a
performance-related feature justifies a
different standard, DOE must consider
such factors as the utility of the feature
to the consumer and other factors DOE
determines are appropriate. (42 U.S.C.
6295(q)) This proposed determination
covers metal halide lamp fixtures
defined as light fixtures for general
lighting application designed to be
operated with a metal halide lamp and
a ballast for a metal halide lamp. 42
U.S.C. 6291(64); 10 CFR 431.322. The
scope of coverage is discussed in further
B. Test Procedure
EPCA sets forth generally applicable
criteria and procedures for DOE’s
adoption and amendment of test
procedures. (42 U.S.C. 6293)
Manufacturers of covered product must
use these test procedures to certify to
DOE that their product complies with
energy conservation standards and to
quantify the efficiency of their product.
DOE will finalize a test procedure
establishing methodologies used to
evaluate proposed energy conservation
standards at least 180 days prior to
publication of a NOPR proposing new or
amended energy conservation
standards. Section 8(d) of appendix A to
10 CFR part 430 subpart C (‘‘Process
Rule’’). DOE’s current energy
conservation standards for MHLFs are
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expressed in terms of the efficiency of
the ballast contained within the fixture.
(10 CFR 431.326)
DOE established an active mode and
standby mode power test method in a
final rule published on March 9, 2010.
75 FR 10950. The current test procedure
for MHLFs appears in 10 CFR 431.324
and specifies the ballast efficiency
calculation as lamp output power
divided by the ballast input power.
DOE has since published an RFI to
initiate a data collection process to
consider whether to amend DOE’s test
procedure for MHLFs. 83 FR 24680
(May 30, 2018).
C. Technological Feasibility
1. General
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In each energy conservation 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 are
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. Section
7(b)(1) of the Process Rule.
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, and service; (2)
adverse impacts on equipment utility or
availability; (3) adverse impacts on
health or safety, and (4) unique-pathway
proprietary technologies. Section
7(b)(2)–(5) of the Process Rule. Section
IV.B.5 of this document discusses the
results of the screening analysis for
MHLFs, particularly the designs DOE
considered, those it screened out, and
those that are considered in this
proposed determination. For further
details on the screening analysis for this
proposed determination, see chapter 4
of the NOPD technical support
document (‘‘TSD’’).
2. Maximum Technologically Feasible
Levels
When DOE proposes to adopt an
amended standard for a type or class of
covered equipment, it must determine
the maximum improvement in energy
efficiency or maximum reduction in
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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. The max-tech
levels that DOE determined for this
analysis are described in section IV.C.4
and in chapter 5 of the NOPD TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (‘‘TSL’’),
DOE projected energy savings from
application of the TSL to MHLFs
purchased in the 30-year period that
begins in the year of compliance with
the potential standards (2025–2054).5
The savings are measured over the
entire lifetime of MHLFs purchased in
the previous 30-year period. DOE
quantified the energy savings
attributable to each TSL as the
difference in energy consumption
between each standards case and the nonew-standards case. The no-newstandards case represents a projection of
energy consumption that reflects how
the market for a product would likely
evolve in the absence of amended
energy conservation standards.
DOE used its NIA spreadsheet model
to estimate national energy savings
(‘‘NES’’) from potential amended or new
standards for MHLFs. The NIA
spreadsheet model (described in section
IV.H of this document) calculates energy
savings in terms of site energy, which is
the energy directly consumed by
equipment at the location where it is
used. For electricity, DOE reports
national energy savings in terms of site
energy savings and source energy
savings, the latter of which is the
savings in the energy that is used to
generate and transmit the site
electricity. DOE also calculates NES in
terms of full-fuel-cycle (‘‘FFC’’) energy
savings. The FFC metric includes the
energy consumed in extracting,
processing, and transporting primary
fuels (i.e., coal, natural gas, petroleum
fuels), and thus presents a more
complete picture of the impacts of
energy conservation standards.6 DOE’s
approach is based on the calculation of
5 Each TSL is composed of specific efficiency
levels for each product class. The TSLs considered
for this NOPD are described in section V.A. DOE
conducted a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
6 The FFC metric is discussed in DOE’s statement
of policy and notice of policy amendment. 76 FR
51282 (Aug. 18, 2011), as amended at 77 FR 49701
(Aug. 17, 2012).
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an FFC multiplier for each of the energy
types used by covered products or
equipment. For more information on
FFC energy savings, see section IV.H.1
of this document.
2. Significance of Savings
To adopt any new or amended
standards for a covered product, DOE
must determine that such action would
result in significant energy savings. (42
U.S.C. 6295(o)(3)(B)) The term
‘‘significant’’ is not defined in EPCA.
DOE has established a significance
threshold for energy savings. Section
6(b) of the Process Rule. In evaluating
the significance of energy savings, DOE
conducts a two-step approach that
considers both an absolute site energy
savings threshold and a threshold that is
percent reduction in the covered energy
use. Id. DOE first evaluates the projected
energy savings from a potential maxtech standard over a 30-year period
against a 0.3 quads of site energy
threshold. Section 6(b)(2) of the Process
Rule. If the 0.3 quad-threshold is not
met, DOE then compares the max-tech
savings to the total energy usage of the
covered equipment to calculate a
percentage reduction in energy usage.
Section 6(b)(3) of the Process Rule. If
this comparison does not yield a
reduction in site energy use of at least
10 percent over a 30-year period, DOE
proposes that no significant energy
savings would likely result from setting
new or amended standards. Section
6(b)(3) of the Process Rule. The two-step
approach allows DOE to ascertain
whether a potential standard satisfies
EPCA’s significant energy savings
requirements in 42 U.S.C. 6295(o)(3)(B)
to ensure that DOE avoids setting a
standard that ‘‘will not result in
significant conservation of energy.’’
EPCA defines ‘‘energy efficiency’’ as
the ratio of the useful output of services
from a product to the energy use of such
product, measured according to the
Federal test procedures. (42 U.S.C.
6291(5), emphasis added) EPCA defines
‘‘energy use’’ as the quantity of energy
directly consumed by a consumer
product at point of use, as measured by
the Federal test procedures. (42 U.S.C.
6291(4)) Further, EPCA uses a
household energy consumption metric
as a threshold for setting standards for
new covered products (42 U.S.C.
6295(l)(1)). Given this context, DOE
relies on site energy as the appropriate
metric for evaluating the significance of
energy savings.
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E. Economic Justification
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1. Specific Criteria
As noted previously, 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)(I)–
(VII)) The following sections discuss
how DOE has addressed each of those
seven factors in this rulemaking.
a. Economic Impact on Manufacturers
and Consumers
In determining the impacts of a
potential amended standard on
manufacturers, DOE conducts a
manufacturer impact analysis (‘‘MIA’’).
DOE first uses an annual cash-flow
approach to determine the quantitative
impacts. This step includes both a shortterm 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. The industrywide impacts analyzed include (1)
industry net present value, which
values the industry on the basis of
expected future cash flows, (2) cash
flows by year, (3) changes in revenue
and income, and (4) other measures of
impact, as appropriate. Second, DOE
analyzes and reports the impacts on
different types of manufacturers,
including impacts on small
manufacturers. Third, DOE considers
the impact of standards on domestic
manufacturer employment and
manufacturing capacity, as well as the
potential for standards to result in plant
closures and loss of capital investment.
Finally, DOE takes into account
cumulative impacts of various DOE
regulations and other regulatory
requirements on manufacturers.
For individual consumers, measures
of economic impact include the changes
in the LCC and PBP associated with new
or amended standards. These measures
are discussed further in the following
section. For consumers in the aggregate,
DOE also calculates the national net
present value of the consumer costs and
benefits expected to result from
particular standards. DOE also evaluates
the impacts of potential standards on
identifiable subgroups of consumers
that may be affected disproportionately
by a standard.
DOE has concluded amended
standards for MHLFs would not result
in significant energy savings and, as
discussed further in section V.D of this
document, would not be economically
justified for the potential standard levels
evaluated based on the PBP analysis.
Therefore, DOE did not conduct an MIA
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analysis or LCC subgroup analysis for
this NOPD.
the NIA spreadsheet models to project
national energy savings.
b. Savings in Operating Costs Compared
to Increase in Price (LCC and PBP)
d. Lessening of Utility or Performance of
Products
In establishing product classes and in
evaluating design options and the
impact of potential standard levels, DOE
evaluates potential standards that would
not lessen the utility or performance of
the considered products. (42 U.S.C.
6295(o)(2)(B)(i)(IV)) The Secretary may
not prescribe an amended or new
standard if the Secretary finds (and
publishes such finding) that interested
persons have established by a
preponderance of the evidence that the
standard is 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
similar in the United States at the time
of the Secretary’s finding. (42 U.S.C.
6295(o)(4))
EPCA requires DOE to consider the
savings in operating costs throughout
the estimated average life of the covered
product in the type (or class) compared
to any increase in the price of, or in the
initial charges for, or maintenance
expenses of, the covered product that
are likely to result from a 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 a product (including its
installation) and the operating expense
(including energy, maintenance, and
repair expenditures) discounted over
the lifetime of the product. The LCC
analysis requires a variety of inputs,
such as product prices, product energy
consumption, energy prices,
maintenance and repair costs, product
lifetime, and discount rates appropriate
for consumers. To account for
uncertainty and variability in specific
inputs, such as product lifetime and
discount rate, DOE uses a distribution of
values, with probabilities attached to
each value.
The PBP is the estimated amount of
time (in years) it takes consumers to
recover the increased purchase cost
(including installation) of a moreefficient product through lower
operating costs. DOE calculates the PBP
by dividing the change in purchase cost
due to a more-stringent standard by the
change in annual operating cost for the
year that standards are assumed to take
effect.
For its LCC and PBP analysis, DOE
assumes that consumers will purchase
the covered products in the first year of
compliance with new or amended
standards. The LCC savings for the
considered efficiency levels are
calculated relative to the case that
reflects projected market trends in the
absence of new or amended standards.
DOE’s LCC and PBP analysis is
discussed in further detail in section
IV.F.
c. Energy Savings
Although significant conservation of
energy is a separate statutory
requirement for adopting an energy
conservation standard, EPCA requires
DOE, in determining the economic
justification of a standard, to consider
the total projected energy savings that
are expected to result directly from the
standard. (42 U.S.C. 6295(o)(2)(B)(i)(III))
As discussed in section III.D, DOE uses
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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 a proposed 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
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)(ii)) Because DOE is
not proposing standards for MHLFs,
DOE did not transmit a copy of its
proposed determination to the Attorney
General.
f. Need for National Energy
Conservation
In evaluating the need for national
energy conservation, 42 U.S.C.
6295(o)(2)(B)(i)(VI), DOE expects that
energy savings from amended standards
would likely 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. Energy savings from amended
standards also would likely result in
environmental benefits in the form of
reduced emissions of air pollutants and
greenhouse gases primarily associated
with fossil-fuel based energy
production. Because DOE has
tentatively concluded amended
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standards for MHLFs would not be
economically justified, DOE did not
conduct a utility impact analysis or
emissions analysis for this NOPD.
available on the DOE website for this
proposed determination (see DOCKET
section at the beginning of this proposed
determination).
g. Other Factors
In determining whether an energy
conservation standard is economically
justified, DOE may consider any other
factors that the Secretary deems to be
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
A. Overall
DOE received several comments from
stakeholders in response to the July
2019 RFI stating that DOE should not
amend standards for MHLFs. NEMA
stated that MHLF technology has
reached its practical limits in terms of
performance. NEMA noted that further
investment in efficiency for MHLF
products is no longer justified given
substantial market decline and the
inability for relevant manufacturers and
distributors to recover investments in
relatively minor efficiency gains. NEMA
pointed out that DOE has previously
declined to amend standards for a
product when it was deemed that no
new investments in higher efficiency
products is likely. (NEMA, No. 3 at pp.
2, 6)
NEMA also stated that a transition to
light-emitting diode (‘‘LED’’) products is
largely responsible for the declining
market for MHLF products, and as a
result, there is limited opportunity to
recapture investments in new designs
through sales of MHLF products.
(NEMA, No. 3 at p. 2–3) NEMA noted
that the decline of the MHLF market
means relevant efficiency regulations
have reached their end-states. (NEMA,
No. 3 at p. 6) According to NEMA, the
most likely outcome of strengthened
efficiency standards for MHLFs is
accelerated obsolescence of products
unable to meet new standards and an
accelerated decline of a market already
in decline. (NEMA, No. 3 at p. 6–7)
NEMA asserted that DOE does not need
to further accelerate the decline of the
MHLF market by further strengthening
MHLF efficiency requirements. (NEMA,
No. 3 at p. 9)
EEI and Signify both argue that the
best course of action is for DOE to issue
a ‘‘no new standard’’ determination for
MHLFs. EEI and Signify identified the
significant decline in the MHLF market
as a reason DOE should not consider
standards for MHLFs. (EEI, No. 2 at p.
3, Signify, No. 6 at p. 1) EEI added that
the market for lighting products has
outpaced the relevant regulatory
framework and market forces alone have
pushed customers away from MHLF
products, so there is no need for further
regulations. EEI commented that
amending standards for MHLFs could
be an inefficient and ineffective
expenditure of DOE’s resources. (EEI,
No. 2 at p. 3).
As discussed in section II.A, DOE is
required to conduct two rulemaking
cycles to determine whether to amend
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2. Rebuttable Presumption
EPCA creates a rebuttable
presumption that an energy
conservation standard is economically
justified if the additional cost to the
consumer of a product 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. 42 U.S.C.
6295(o)(2)(B)(iii) DOE’s LCC and PBP
analyses generate values used to
calculate the effects that proposed
energy conservation standards would
have on the payback period for
consumers. 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 consumers, 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 V.B.2 of this
document.
IV. Methodology and Discussion of
Related Comments
This section addresses the analyses
DOE has performed for this proposed
determination with regard to MHLFs.
Separate subsections address each
component of DOE’s analyses.
DOE used several analytical tools to
estimate the impact of the standards
proposed in this document. The first
tool is a spreadsheet that calculates the
LCC savings and PBP of potential
amended or new energy conservation
standards. The national impacts
analysis uses a second spreadsheet set
that provides shipments projections and
calculates national energy savings and
net present value of total consumer
costs and savings expected to result
from potential energy conservation
standards. These spreadsheet tools are
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standards for MHLFs. (42 U.S.C.
6295(hh)(2)(A) and (3)(A)) DOE
completed the first rulemaking cycle by
publishing a final rule amending MHLF
standards on February 10, 2014. 79 FR
7746. This determination represents the
second rulemaking cycle for MHLFs.
DOE discusses the methodology used to
analyze potential standards in section
IV and the results of the analysis in
section V.
Commenting on the analyses
conducted by DOE to evaluate standards
for MHLFs, IPI stated that DOE should
(1) continue to monetize the full climate
benefits of greenhouse gas emissions
reductions, using the best estimates,
which were derived by the Interagency
Working Group; (2) continue to use the
global estimate of the social cost of
greenhouse gases; and (3) rely only on
the best available science and
economics, and not on any ‘‘interim’’
estimates that do not include a range of
discount rates or global climate impacts.
They stated that DOE should factor
these benefits into its choice of the
maximum efficiency level that is
economically justified, consistent with
its statutory requirement to assess the
national need to conserve energy. (IPI,
No. 4, pp. 1–5)
In response, DOE notes that it has not
conducted an analysis of emissions
impacts that may result from amended
standards for MHLFs. As discussed
further in the document, DOE has
tentatively concluded that imposition of
a standard at any of the TSLs considered
is not economically justified because the
operating costs of the covered product
are insufficient to recover the upfront
cost. DOE continues to be of the view
that failure to meet one aspect of the
seven factors in EPCA’s consideration of
economic justification means that a
revised standard is not economically
justified without considering all of the
other factors. For example, on October
17, 2016, DOE published in the Federal
Register a final determination that more
stringent energy conservation standards
for direct heating equipment (‘‘DHE’’)
would not be economically justified,
and based this determination solely on
manufacturer impacts, the first EPCA
factor that DOE is required to evaluate
in 42 U.S.C. 6295(o)(2)(B)(i)(I). 81 FR
71325. Specifically, due to the lack of
advancement in the DHE industry in
terms of product offerings, available
technology options and associated costs,
and declining shipment volumes, DOE
concluded that amending the DHE
energy conservation standards would
impose a substantial burden on
manufacturers of DHE, particularly to
small manufacturers. Id. at 81 FR 71328.
Notably, DOE received no stakeholder
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comments in opposition to its
conclusions regarding economic
justification in the DHE standards
rulemaking.
In this NOPD, DOE remains consistent
with its approach in the DHE rule, and
finds no economic justification for
amending standards based on one of the
seven factors in 42 U.S.C.
6295(o)(2)(B)(i), namely, that the energy
savings in operating costs of the covered
product are insufficient to recover the
upfront cost.
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B. Market and Technology Assessment
DOE develops information in the
market and technology assessment that
provides an overall picture of the
market for the equipment concerned,
including the purpose of the equipment,
the industry structure, manufacturers,
market characteristics, and technologies
used in the equipment. This activity
includes both quantitative and
qualitative assessments, based primarily
on publicly-available information. The
key findings of DOE’s market
assessment are summarized in the
following sections. See chapter 3 of the
NOPD TSD for further discussion of the
market and technology assessment.
1. Scope of Coverage
MHLF is defined as a light fixture for
general lighting application designed to
be operated with a metal halide lamp
and a ballast for a metal halide lamp. 42
U.S.C. 6291(64); 10 CFR 431.322. Any
equipment meeting the definition of
MHLF is included in DOE’s scope of
coverage, though all equipment within
the scope of coverage may not be subject
to standards.
In the July 2019 RFI, DOE requested
comments on whether definitions
related to MHLFs in 10 CFR 431.322
require any revisions or whether
additional definitions are necessary for
DOE to clarify or otherwise implement
its regulatory requirements related to
MHLFs. 84 FR 31234. NEMA
commented that the MHLF technology
is mature and noted that no relevant
definitions have emerged since the last
rulemaking. (NEMA, No. 3 at p. 4–5)
DOE agrees with NEMA and is not
proposing to add any new definitions or
update any existing definitions for
MHLFs in this determination.
In response to the July 2019 RFI, CA
IOUs argued that DOE should consider
adopting a technology-agnostic
approach that groups together all
products used for the same application.
CA IOUs pointed out the transition
away from MHLF products and toward
LED products and suggested that DOE
establish a class of products based on
lumen output that would include all
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technologies that serve the same
application. (CA IOUs, No. 5 at p. 1–2)
DOE agrees with CA IOUs that a
technology-agnostic approach that
groups together all products used for the
same application could potentially have
benefits with regards to energy savings.
However, DOE notes that this proposed
determination addresses only metal
halide lamp fixtures defined as light
fixtures for general lighting application
designed to be operated with a metal
halide lamp and a ballast for a metal
halide lamp. 42 U.S.C. 6291(64); 10 CFR
431.322. DOE is not authorized to
consider any product not meeting this
definition, such as LED fixtures, as a
part of this determination.
CA IOUs also urged DOE to consider
agricultural applications when
developing an updated technologyagnostic standard for MHLFs. CA IOUs
noted that in agricultural applications,
there are limitations with LED
technology for certain indoor growing
operations that demand the use of highintensity discharge (‘‘HID’’) products,
and DOE should ensure that any new
standards will not eliminate these HID
products from the market (metal halide
products are a type of HID product). (CA
IOUs, No. 5 at p. 1–2)
DOE reviewed commercially available
MHLFs and found about 50 products
marketed for use in agricultural
applications (compared to 3,521
products in DOE’s compliance
certification database). The agricultural
MHLFs range in wattage from 175 watts
(‘‘W’’) to 1000 W. DOE did not find any
performance characteristics or features
of the agricultural MHLFs that would
prevent them from being used in general
lighting applications (i.e., providing an
interior or exterior area with overall
illumination). DOE reviewed available
agricultural MHLFs in light of the
efficiency levels discussed in section
IV.C.4 and determined that agricultural
MHLFs already meet or could meet the
efficiency levels considered in this
determination.
EISA 2007 established energy
conservation standards for MHLFs with
ballasts designed to operate lamps with
rated wattages between 150 W and 500
W and excluded three types of fixtures
within that wattage range from energy
conservation standards: (1) MHLFs with
regulated-lag ballasts; (2) MHLFs that
use electronic ballasts and operate at
480 volts; and (3) MHLFs that are rated
only for 150 watt lamps, are rated for
use in wet locations as specified by the
National Fire Protection Association
(‘‘NFPA’’) in NFPA 70, ‘‘National
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Electrical Code 2002 Edition,’’ 7 and
contain a ballast that is rated to operate
at ambient air temperatures above 50
degrees Celsius (‘‘°C’’) as specified by
Underwriters Laboratory (‘‘UL’’) in UL
1029, ‘‘Standard for Safety HighIntensity-Discharge Lamp Ballasts.’’ (42
U.S.C. 6295(hh)(1))
In the 2014 MHLF final rule, DOE
promulgated standards for the group of
MHLFs with ballasts designed to
operate lamps rated 50 W–150 W and
501 W–1,000 W. DOE also promulgated
standards for one type of previously
excluded fixture: A 150 W MHLF rated
for use in wet locations and containing
a ballast that is rated to operate at
ambient air temperatures greater than 50
°C—i.e., those fixtures that fall under 42
U.S.C. 6295(hh)(1)(B)(iii). DOE
continued to exclude from standards
MHLFs with regulated-lag ballasts and
480 volt (‘‘V’’) electronic ballasts. In
addition, due to a lack of applicable test
method for high-frequency electronic
(‘‘HFE’’) ballasts, in the 2014 MHLF
final rule, DOE did not establish
standards for MHLFs with HFE ballasts.
79 FR 7754–7756 (February 10, 2014).
In this analysis, based on a review of
manufacturer catalogs DOE again found
a range of efficiencies for MHLFs with
ballasts designed to operate lamps with
rated wattages >1000 W to ≤2000 W.
Hence, in this determination, DOE
assesses potential standards for this
equipment.
In summary, this proposed
determination evaluates MHLFs with
ballasts designed to operate lamps with
rated wattages ≥50 W to ≤2000 W with
the exception of MHLFs with regulatedlag ballasts and MHLFs that use
electronic ballasts that operate at 480
volts.
In response to the July 2019 RFI, EEI
suggested that DOE adopt a more
accurate description of the regulatory
category for which it is issuing
standards for MHLFs. EEI noted that
DOE is specifically reviewing standards
for metal halide ballasts, and not for
metal halide fixtures. (EEI, No. 2 at p.
2) EEI also noted that the focus on metal
halide ballasts and not fixtures during
the 2014 MHLF rulemaking produced
arguably flawed conclusions regarding
the payback period for the MHLF
efficiency standard adopted. (EEI, No. 2
at p. 2) In a comment on the previous
7 DOE notes that although the exclusion in 42
U.S.C. 6295(hh)(1)(B)(iii)(II) identifies those fixtures
that are rated for use in wet locations as specified
by the National Electrical Code 2002 section
410.4(A), the NFPA is responsible for authoring the
National Electrical Code, which is identified as
NFPA 70. Accordingly, DOE’s use of NFPA 70
under the MHLF-related provision in 10 CFR
431.326(b)(3)(iii) is identical to the statutory
exclusion set out by Congress.
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rulemaking, EEI stated that it is unclear
whether manufacturers will devote
resources to make new ballasts to meet
the standard and keep producing
replacement ballasts. EEI noted that
replacement costs increase substantially
if the entire fixture needs to be replaced
after ballast failure rather than just the
ballast. (EEI, No. 53 at pp. 3–4) 8
DOE prescribes efficiency standards
for MHLFs but, as noted by EEI,
standards for MHLFs are applicable to
the ballast contained within the MHLF
and not replacement metal halide
ballasts sold separately. In this proposed
determination DOE only has the
authority to evaluate amended
standards for MHLFs, not metal halide
ballasts sold outside of MHLFs. In
section IV.B.2, DOE considers other
metrics for MHLFs that pertain to the
performance of the fixture rather than
the ballast contained within the fixture.
In section IV.F.6, DOE discusses the
lifetime of ballasts and fixtures and in
section IV.F.9, DOE discusses the
payback period analysis.
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2. Metric
Current energy conservation
standards for MHLFs are based on
minimum allowable ballast efficiencies.
The ballast efficiency for the fixture is
calculated as the measured ballast
output power divided by the measured
ballast input power. The measurement
of ballast output power (approximated
in the test procedure as lamp output
power) and ballast input power and the
calculation of ballast efficiency for
MHLFs is included in the current test
procedure at 10 CFR 431.324.
In response to the July 2019 RFI, CA
IOUs recommended that DOE adopt a
new standard for MHLFs based on a
lumens-per-watt metric to align with
standards for other lighting products. In
addition, regarding agricultural MHLFs,
CA IOUs suggested that DOE evaluate
the metrics developed by the American
National Standards Institute (‘‘ANSI’’)
and the American Society of
Agricultural and Biological Engineers
for evaluating performance related to
agricultural operations. (CA IOUs, No. 5
at p. 1–2) CA IOUs noted that the
current ballast efficiency metric for
MHLFs does not promote more efficient
fixture designs, more efficient lamps, or
higher efficiency technologies such as
LEDs. CA IOUs also pointed out that
EISA 2007 gives DOE permission to
expand the scope of regulation for
MHLFs and to propose not only
8 The full written comment in response to the
Notice of Proposed Rulemaking for MHLFs
published at 78 FR 51164 (August 20, 2013) can be
found in Docket No. EERE–2009–BT–STD–0018.
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performance requirements, but also
design requirements. CA IOUs noted
that a fixture-level metric could save up
to 50 percent more energy than the
current approach that only considers
ballast efficiency and provide a
standardized metric to assess and
compare the performance of a product.
(CA IOUs, No. 5 at p. 2–3)
DOE agrees that a fixture metric
effectively accounts for the efficiency of
a fixture in different applications,
provides more technological flexibility,
and has the potential to yield overall
higher performance and energy savings.
DOE notes that metrics for agricultural
MHLFs focus on performance
characteristics that affect the
photosynthesis of plants and therefore
are not appropriate for MHLFs used in
general lighting applications. Instead, as
part of this determination, DOE
evaluated several alternative fixture
performance metrics, including lumens
per watt (‘‘lm/W’’), luminaire efficacy
rating (‘‘LER’’), target efficacy rating
(‘‘TER’’), and fitted target efficacy
(‘‘FTE’’).
A lumens-per-watt metric reflects the
light produced and energy consumed for
a lamp-and-ballast pairing. An increase
in lm/W could reflect the use of a more
efficacious lamp, a more efficient
ballast, or both. Although DOE’s current
test procedure does not measure lm/W,
ANSI C82.6–2015 9 and IES LM–51–
2013 10 provide a test method that could
be used to determine lm/W for lampand-ballast pairings. The inclusion of
lumen output in the metric necessitates
photometric measurements as part of
the test procedure whereas the
measurement of ballast efficiency
requires only electrical measurements.
Photometric measurements are more
expensive to conduct than electrical
measurements because of the equipment
and time required. While a lumens-perwatt metric is based on more than just
ballast performance, lm/W still does not
account for directionality of a fixture
(i.e., the fixture’s effectiveness in
delivering light to a specific target).
Because the covered product is a fixture,
DOE evaluated metrics that captured the
performance of the lamp, ballast, and
optics of a fixture.
DOE next considered the LER metric,
developed by NEMA in 1998. LER is
9 American National Standards Institute.
American National Standard for lamp ballasts—
Ballasts for High-Intensity Discharge Lamps—
Methods of Measurement. Approved September 17,
2015 available at www.ansi.org.
10 Illuminating Engineering Society. IES
Approved Method—The Electrical and Photometric
Measurement of High-Intensity Discharge Lamps.
Approved January 7, 2013 available at https://
webstore.iec.ch/home.
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expressed in units of lm/W but in
addition to the lamp-and-ballast pairing
described in the previous paragraph,
LER includes a factor that accounts for
luminaire efficiency, which is the ratio
of the lumens emitted from a luminaire
to the lumens emitted by the lamps
alone. LER is used to establish
minimum requirements for the Federal
Energy Management Program (‘‘FEMP’’)
for industrial luminaires.11 NEMA has
developed a test procedure for LER in
NEMA LE 5B–1998.12 The inclusion of
lumen output and luminaire efficiency
in the metric necessitates photometric
measurements. As stated previously,
photometric measurements are more
expensive to conduct than electrical
measurements. NEMA has since
developed a TER metric which is
similar to LER, but better accounts for
directionality. DOE determined that
TER would be a more applicable
alternative metric to measure the
performance of MHLFs.
The TER metric was developed by
NEMA’s luminaire division to succeed
the LER rating. TER calculates fixture
efficacy by multiplying the lamp lumens
by the coefficient of utilization (‘‘CU’’),
which factors in the percentage of rated
lumens reaching a specific target (that
varies based on the type of fixture). The
inclusion of lumen output and CU in
the metric necessitates photometric
measurements, which are more
expensive to conduct than electrical
measurements. NEMA developed the
NEMA LE–6–2014 standard 13 to
provide a test procedure for determining
the TER of commercial, industrial, and
residential luminaires. TER has 22
different types of luminaire
classifications, each with a different CU.
Despite the variety of luminaire
classifications available, TER explicitly
excludes fixtures intended to be aimed,
accent luminaires, rough or hazardous
use luminaires, and emergency lighting.
In the 2014 MHLF final rule, DOE
considered the TER metric but
ultimately chose not to adopt it out of
concern that certain fixtures could fall
within multiple luminaire
classifications due to their designs. DOE
11 FEMP provides guidance for purchasing
Energy-Efficient Industrial Luminaires (High/Low
Bay) with specifications in LER available here:
https://www.energy.gov/eere/femp/purchasingenergy-efficient-industrial-luminaires-highlow-bay.
12 National Electrical Manufacturers Association.
LE 5B—Procedure for Determining Luminaire
Efficacy Ratings for High-Intensity Discharge
Industrial Luminaires. Published January 1998
available at www.nema.org.
13 National Electrical Manufacturers Association.
LE 6—Procedure for Determining Target Efficacy
Ratings for Commercial, Industrial, and Residential
Luminaires. Published June 10, 2015 available at
www.nema.org.
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also determined that the exclusion of
certain fixture types such as fixtures
designed to be aimed does not allow all
MHLFs to be measured using TER. 79
FR 7757. DOE has not found any new
information since the 2014 MHLF final
rule regarding the TER metric.
Therefore, DOE considers these reasons
to still be valid and tentatively
concludes that TER is not a suitable
metric for measuring the performance of
MHLFs.
The FTE metric was developed by
DOE to quantify outdoor pole-mounted
fixture performance for ENERGY STAR
qualification purposes.14 In the FTE
approach, fixture performance is
measured by the amount of light hitting
a specified target. The target is defined
as the rectangle enclosing the uniform
‘‘pool’’ of light produced by the unique
intensity distribution of each luminaire.
FTE is calculated by multiplying the
luminous flux landing in this pool by
the percent coverage of the rectangular
target, and then dividing by input power
to the fixture. The inclusion of lumen
output in the metric necessitates
photometric measurements. As stated
previously, photometric measurements
are more expensive to conduct than
electrical measurements. In the 2014
MHLF final rule, DOE considered the
FTE metric but ultimately chose not to
adopt it because FTE is calculated using
a rectangular area. 79 FR 7757.
Therefore, fixtures designed to light
non-rectangular areas, produce a large
amount of unlighted area within the
rectangle, or produce specific light
patterns that light both a horizontal
plane and a vertical plane, or even
above the fixture would be at a
disadvantage. DOE continues to find
this rationale to be valid today. In
addition, currently, there is no industry
standard for determining FTE. For these
reasons, DOE determined that FTE is
not suitable for measuring the
performance of MHLFs.
In summary, DOE reviewed several
alternative metrics to ballast efficiency
in this proposed determination.
Changing metrics would impose a
significant burden on manufacturers. A
change in metric would require retesting
all MHLFs. While industry test
procedures exist for many of the
metrics, an industry-accepted test
procedure does not exist for the FTE
metric. Further, all metrics would
require photometric testing in addition
to the electrical measurements currently
required. Photometric measurements are
more expensive to conduct than
14 Overview of FTE metric available at: https://
www.illinoislighting.org/resources/
FTEoverview01Jul09.pdf.
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electrical measurements. While some
fixture manufacturers provide
photometric data, the information is not
available for all fixtures, all lamp-andballast pairings within fixtures, and all
performance characteristics required to
calculate the metrics described in this
section. For example, the CU needed to
calculate the TER metric is not available
publicly. Finally, because the metrics
account for the performance of both the
lamp and ballast components of the
fixture, adopting one of the metrics
described in this section would require
manufacturers to ship fixtures with
lamps in addition to ballasts. Therefore,
for the reasons described in this
paragraph, DOE has tentatively
concluded to maintain the current
ballast efficiency metric for MHLFs.
In addition to a metric that represents
fixture-level performance, CA IOUs
stated that DOE should consider the
benefits of fixtures with good lumen
maintenance because this will enable
lighting designers avoid over-lighting
spaces in anticipation of lumen
depreciation. (CA IOUs, No. 5 at p. 3)
DOE notes that lumen maintenance is
the ratio of lumen output at a certain
period in time during the life of a lamp
to the initial lumen output. Because
lumen maintenance requires conducting
photometric testing, and because the
testing must be conducted more than
once and with a potentially significant
period of time between tests, DOE
tentatively concludes that lumen
maintenance represents a significant test
burden for manufacturers. For this
reason, DOE did not consider adopting
a metric based on lumen maintenance in
this determination.
3. Equipment Classes
When evaluating and establishing
energy conservation standards, DOE
may divide covered products into
product classes by the type of energy
used, or by capacity or other
performance-related features that justify
a different standard. (42 U.S.C. 6295(q))
In making a determination whether
capacity or another performance-related
feature justifies a different standard,
DOE must consider such factors as the
utility of the feature to the consumer
and other factors DOE deems
appropriate. (Id.)
In describing which MHLFs are
included in current equipment classes,
DOE incorporates by reference the 2002
version of NFPA 70 and the 2007
version of UL 1029 in DOE’s
regulations. NFPA 70 is a national safety
standard for electrical design,
installation, and inspection, and is also
known as the 2002 National Electrical
Code. UL 1029 is a safety standard
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47481
specific to HID lamp ballasts; a metal
halide lamp ballast is a type of HID
lamp ballast. Both NFPA 70 and UL
1029 are used to describe the applicable
equipment class for MHLFs that EISA
2007 excluded from the statutory
standards enacted by Congress but that
were later included as part of the 2014
MHLF final rule. In the July 2019 RFI,
DOE found that a 2017 version of NFPA
70 (NFPA 70–2017) ‘‘NFPA 70 National
Electrical Code 2017 Edition’’ 15 and a
2014 version of UL 1029 (UL 1029–
2014) ‘‘Standard for Safety HighIntensity-Discharge Lamp Ballasts’’ 16
are now available.
In response to the July 2019 RFI,
NEMA commented that updating the
industry standards incorporated by
reference in DOE’s regulations, NFPA 70
and UL 1029, to the newer versions,
NFPA 70–2017 and UL 1029–2014, is
unlikely to have any impact on MHLFs
included in each equipment class.
However, NEMA pointed out that any
updates could impose financial and
administrative burdens on
manufacturers, especially given the
general market decline of MHLF
technology. (NEMA, No. 3 at p. 3–4)
DOE agrees with NEMA that there is
unlikely to be any impact on MHLFs
included in each equipment class.
Consequentially, DOE has not been able
to identify any additional financial or
administrative burden as testing
requirements and equipment classes
will remain unaffected. However, as
discussed in section V.D, because DOE
is not proposing to amend standards for
MHLFs, DOE is not proposing to
incorporate by reference the updated
industry standards NFPA 70–2017 and
UL 1029–2014 in this determination.
In this analysis, DOE reviewed metal
halide lamp fixtures and the ballasts
contained within them to identify
performance-related features that could
potentially justify a separate equipment
class. In the following sections, DOE
discusses the equipment classes
considered in this analysis.
a. Existing Equipment Classes
The current equipment classes are
based on input voltage, rated lamp
wattage, and designation for indoor
versus outdoor application. NEMA
commented in response to the July 2019
RFI that the current equipment classes
for MHLFs remain viable and do not
need to be changed. NEMA also noted
that there are no new products that will
benefit from an additional equipment
class. (NEMA, No. 3 at p. 3; NEMA, No.
3 at p. 5)
15 Approved
16 Approved
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Regarding 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-inputvoltage ballasts are able to operate at
120 V, 208 V, 240 V, and 277 V). DOE
determined in the 2014 MHLF final rule
that the input voltage at which a MHLF
is capable of operating represents a
performance-related feature that affects
consumer utility as certain applications
demand specific input voltages. 79 FR
7762. In the 2014 MHLF final rule,
DOE’s ballast testing did not indicate a
prevailing relationship between discrete
input voltages and ballast efficiencies
(e.g., higher voltages are not always
more efficient), with one exception.
DOE found that ballasts tested at 480 V
were less efficient on average than
ballasts tested at 120 V or 277 V. 79 FR
7781. NEMA stated that it remains
appropriate to include separate classes
for 480 V products given the differences
in how those products perform in
testing. (NEMA, No. 3 at p. 6) 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, DOE maintains
separate equipment classes for ballasts
tested at 480 V in this determination.
See chapter 3 of the NOPD TSD for
further details.
As lamp wattage increases, lamp-andballast systems generally produce
increasing amounts of light (lumens).
Because certain applications require
more light than others, wattage often
varies by application. For example, lowwattage (less than 150 W) lamps are
typically used in commercial
applications. Medium-wattage (150 W–
500 W) lamps are commonly used in
warehouse, street, and 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
represents consumer utility. The
wattage operated by a ballast is
correlated with the ballast efficiency;
ballast efficiency generally increases as
lamp wattage increases. Therefore, DOE
maintains separation of equipment
classes by wattage. See chapter 3 of the
NOPD TSD for further details.
DOE determined in the 2014 MHLF
final rule that indoor and outdoor
MHLFs are subject to separate costefficiency relationships at electronic
ballast levels. 79 FR 7763–7764. First, as
outdoor applications can be subject to
large voltage transients, MHLFs in such
applications require 10 kV voltage
transient protection. Magnetic metal
halide ballasts are typically resistant to
voltage variations of this magnitude,
while electronic metal halide ballasts
are generally not as resilient. Therefore,
in order to address large voltage
transients, 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. Second, DOE
noted that indoor fixtures can require
the inclusion of a 120 V auxiliary tap.
79 FR 7763. This output is used to
operate emergency lighting after a
temporary loss of power while the metal
halide 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, however, 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 IV.C.7 of this
NOPD). As these incremental costs
could affect the cost-effectiveness of
fixtures for indoor versus outdoor
applications, DOE maintains separate
equipment classes for indoor and
outdoor fixtures. See chapter 3 of the
NOPD TSD for further details.
b. Summary
In summary, for the purpose of this
proposed determination DOE
considered equipment classes using
three class-setting factors: Input voltage,
rated lamp wattage, and fixture
application. DOE presents the resulting
equipment classes in Table IV.1.
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TABLE IV.1—EQUIPMENT CLASSES
Designed to be operated with lamps of the following rated lamp wattage
Indoor/outdoor
≥50 W and ≤100 W .................................................................................................
≥50 W and ≤100 W .................................................................................................
≥50 W and ≤100 W .................................................................................................
≥50 W and ≤100 W .................................................................................................
>100 W and <150 W * ............................................................................................
>100 W and <150 W * ............................................................................................
>100 W and <150 W * ............................................................................................
>100 W and <150 W * ............................................................................................
≥150 W ** and ≤250 W ...........................................................................................
≥150 W ** and ≤250 W ...........................................................................................
≥150 W ** and ≤250 W ...........................................................................................
≥150 W ** and ≤250 W ...........................................................................................
>250 W and ≤500 W ...............................................................................................
>250 W and ≤500 W ...............................................................................................
>250 W and ≤500 W ...............................................................................................
>250 W and ≤500 W ...............................................................................................
>500 W and ≤1000 W .............................................................................................
>500 W and ≤1000 W .............................................................................................
>500 W and ≤1000 W .............................................................................................
>500 W and ≤1000 W .............................................................................................
>1000 W and ≤2000 W ...........................................................................................
>1000 W and ≤2000 W ...........................................................................................
>1000 W and ≤2000 W ...........................................................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
Outdoor ..................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
Outdoor ..................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
Outdoor ..................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
Outdoor ..................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
Outdoor ..................................................
Indoor .....................................................
Indoor .....................................................
Outdoor ..................................................
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Input voltage type ‡
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
All others.
Tested at 480
V.
V.
V.
V.
V.
V.
V.
V.
V.
V.
V.
V.
Federal Register / Vol. 85, No. 151 / Wednesday, August 5, 2020 / Proposed Rules
47483
TABLE IV.1—EQUIPMENT CLASSES—Continued
Designed to be operated with lamps of the following rated lamp wattage
Indoor/outdoor
>1000 W and ≤2000 W ...........................................................................................
Outdoor ..................................................
Input voltage type ‡
All others.
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* Includes 150 W MHLFs initially exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as
specified by the NFPA 70–2002, section 410.4(A);); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as
specified by UL 1029–2007.
** Excludes 150 W MHLFs initially exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as
specified by the NFPA 70–2002, section 410.4(A);); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as
specified by UL 1029–2007.
‡ 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.
4. Technology Options
In the technology assessment, DOE
identifies technology options that would
be expected to improve the efficiency of
MHLFs, as measured by the DOE test
procedure. The energy conservation
standard requirements and DOE test
procedure for MHLFs are based on the
efficiency of the metal halide ballast
contained within the fixture. Hence
DOE identified technology options that
would improve the efficiency of metal
halide ballasts. To develop a list of
technology options, DOE reviewed
manufacturer catalogs, recent trade
publications and technical journals, and
consulted with technical experts.
In response to the July 2019 RFI,
NEMA commented that there are no
new technology options for MHLFs
given the maturity of MHLF technology.
NEMA added that technology options
such as ‘‘increased stack height’’ and
‘‘increased conductor cross sections’’
lead to an increase in the size of the
ballast and have been implemented in
accordance with 2014 MHLF final rule
to the limit of their practicality. (NEMA,
No. 3 at p. 4)
DOE’s review of technology options
for this determination indicates that the
technology options identified in the
2014 MHLF final rule remain valid with
certain clarifications and additional
detail. Specifically, DOE is revising
‘‘increased stack height’’ to be
‘‘improved steel laminations.’’ As
described for the 2014 MHLF final rule,
increased stack height is adding steel
laminations to increase the core crosssection and thereby lower the flux
density and losses.17 Hence the
mechanism for efficiency improvement
is the addition of steel laminations. The
2014 MHLF final rule also noted that
use of thinner laminations allows for
maintaining the stack height and
thereby ballast footprint.18 In addition
17 See chapter 3 of 2014 MHLF final rule TSD,
available at https://www.regulations.gov/docket?
D=EERE-2009-BT-STD-0018.
18 See chapter 3 of 2014 MHLF final rule TSD,
available at https://www.regulations.gov/docket?
D=EERE-2009-BT-STD-0018.
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thinner laminations and well insulated
will reduce eddy current losses.19 To
more appropriately reflect the
technology in this document, DOE refers
to this option as ‘‘improved steel
laminations’’ and describes it as adding
steel laminations to lower core losses by
using thin and insulated laminations.
In the 2014 MHLF final rule
‘‘increased conductor cross section’’ was
described as reducing winding losses
through use of larger wire gauges,
multiple strands of wire operating in
parallel as well use of litz wire for
electronic ballasts.20 In this analysis,
DOE notes that improvements in
windings can also be achieved by using
multiple smaller coils to increase the
number of turns and thereby increase
the induced voltage. Additionally,
optimizing the shape of the wires by
wrapping them close together makes
transfer of power through the core more
efficient. Hence, to more appropriately
reflect the technology, in this document
DOE refers to this option as ‘‘improved
windings’’ and describes it as use of
optimized-gauge copper wire; multiple,
smaller coils; shape-optimized coils to
reduce winding losses for magnetic and
electronic ballasts; and in addition, for
electronic ballasts, the use of litz wire.
NEMA commented that technology
options such as improved core steel,
and copper winding have been
implemented in accordance with the
2014 MHLF final rule and reached the
limit of their practicality. (NEMA, No. 3
at p. 4) In this determination, DOE
found magnetic ballasts with varying
levels of efficiency in its compliance
certification database. Therefore, DOE
has tentatively determined that
technology options, such as a higher
grade of steel could still be used to
improve the efficiency of magnetic
ballasts. DOE’s research has not
indicated any technological issues with
utilizing higher-grade steel in magnetic
ballasts. In addition, based on
19 AK Steel, Selection of Electrical Steels for
Magnetic Cores.
20 See chapter 3 of 2014 MHLF final rule TSD.
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teardowns conducted in 2019, DOE
determined that magnetic ballast
manufacturers still utilize aluminum
wiring in their ballasts. DOE determined
that incorporating copper wiring in all
magnetic ballasts can still be considered
a technology option to improve the
efficiency of magnetic ballasts. DOE has
tentatively determined that it will
continue to consider improved core
steel and copper wiring as technology
options to improve the efficiency of
magnetic ballasts.
NEMA noted that the use of electronic
ballasts in new metal halide fixtures has
declined significantly and at the same
pace as magnetic ballasts and provided
data to illustrate this. (NEMA, No. 3 at
p. 4)
DOE agrees that there has been a
decline in the use of metal halide
technology as whole affecting both
electronic and magnetic metal halide
ballasts. However, DOE determined that
electronic ballast technology remains a
viable technology option to improve the
efficiency of MHLFs with magnetic
ballasts, therefore, DOE considered
electronic ballasts as a technology
option in its analysis.
DOE is removing the technology
option of laminated grain-oriented
silicon steel and amorphous steel for
electronic ballasts. In the context of this
determination, DOE has tentatively
determined that using laminated sheets
of steel (silicon or amorphous) to create
the core of the inductor may not
minimize losses in ballasts that operate
at high frequencies.21 Because
electronic ballasts operate at high
frequencies, DOE is not considering
improved steel laminations or
amorphous steel laminations as
technology options for improving the
efficiency of these ballasts.
21 DOE came to the same conclusion for
fluorescent lamp ballasts. See notice of proposed
determination for fluorescent lamp ballasts at 84 FR
56540, 56552 (October 22, 2019); available at
https://www.regulations.gov/document?D=EERE2015-BT-STD-0006-0019.
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A complete list of technology options
DOE considered for this analysis
appears in Table IV.2.
TABLE IV.2—TECHNOLOGY 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.
Use copper wiring in place of aluminum wiring to lower resistive
losses.
Add steel laminations to lower core losses by using thin and insulated laminations.
Use of optimized-gauge copper wire; multiple, smaller coils; shapeoptimized coils to reduce winding losses.
Replace magnetic ballasts with electronic ballasts.
Create the core of the inductor from
laminated sheets of amorphous steel
insulated from each other.
Copper Wiring .........................................................
Improved Steel Laminations ...................................
Improved Windings .................................................
Electronic Ballast .....................................................
Amorphous Steel .....................................................
Electronic ................
Improved Components
Magnetics .....................
Diodes ..........................
Capacitors ....................
Improved Circuit Design
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5. Screening Analysis
DOE uses the following five screening
criteria to determine which technology
options are suitable for further
consideration in an energy conservation
standards rulemaking:
(1) Technological feasibility.
Technologies that are not incorporated
in commercial products or in working
prototypes will not be considered
further.
(2) Practicability to manufacture,
install, and service. If it is determined
that mass production and reliable
installation and servicing of a
technology in commercial products
could not be achieved on the scale
necessary to serve the relevant market at
the time of the projected compliance
date of the standard, then that
technology will not be considered
further.
(3) Impacts on product utility or
product availability. If it is determined
that a technology would have significant
adverse impact on the utility of the
product to significant subgroups of
consumers or would result in the
unavailability of any covered product
type with performance characteristics
(including reliability), features, sizes,
capacities, and volumes that are
substantially the same as products
generally available in the United States
at the time, it will not be considered
further.
(4) Adverse impacts on health or
safety. If it is determined that a
technology would have significant
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Transistors ....................
Integrated Circuits ........
Improved Windings: Use of optimized-gauge copper wire; multiple,
smaller coils; shape-optimized coils; litz wire to reduce winding
losses.
Use diodes with lower losses.
Use capacitors with a lower effective series resistance and output
capacitance.
Use transistors with lower drain-to-source resistance.
Substitute discrete components with an integrated circuit.
adverse impacts on health or safety, it
will not be considered further.
(5) Unique-Pathway Proprietary
Technologies. If a design option utilizes
proprietary technology that represents a
unique pathway to achieving a given
efficiency level, that technology will not
be considered further.
Sections 6(c)(3) and 7(b) of the
Process Rule.
In sum, if DOE determines that a
technology, or a combination of
technologies, fails to meet one or more
of the listed five criteria, it will be
excluded from further consideration in
the engineering analysis. DOE only
considers potential efficiency levels
achieved through the use of proprietary
designs in the engineering analysis if
they are not part of a unique pathway
to achieve that efficiency level (i.e., if
there are other non-proprietary
technologies capable of achieving the
same efficiency level).
The subsequent sections include
comments from interested parties
pertinent to the screening criteria and
whether DOE determined that a
technology option should be excluded
(‘‘screened out’’) based on the screening
criteria.
a. Screened-Out Technologies
For magnetic ballasts, DOE is
screening out the technology option of
using laminated sheets of amorphous
steel. Due to the random arrangement of
molecules allowing for an easier switch
from magnetization to de-magnetization
of the material, amorphous steel results
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in lower core losses than the commonlyused silicon steel. In the 2014 MHLF
final rule, DOE screened out amorphous
steel technology because it failed to pass
the ‘‘practicable to manufacture, install,
and service’’ criterion. Additionally,
DOE determined that 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. 79 FR 7766.
In response to the July 2019 RFI,
NEMA commented that amorphous steel
technology was screened out in the 2014
MHLF final rule because it increases the
size and weight of metal halide ballasts,
which remains true today. NEMA added
that the current cost of amorphous steel
ribbon that is used as a raw material for
making magnetic cores is 20 to 30 times
higher than the cost of other highergrade steel used in magnetic ballasts.
(NEMA, No. 3 at p. 4)
In its assessment for this analysis,
DOE found that brittleness remained an
issue in using amorphous steel in metal
halide ballasts.22 Further amorphous
steel is implemented as laminations to
ensure losses due to eddy currents do
not offset efficiency gains. Typically,
amorphous steel laminations have a
larger cross-sectional area, which
increases the overall size of the ballast,
when compared to silicon steel
22 Technical Editor, ‘‘Advantages and
disadvantages of an amorphous metal transformer.’’
Polytechnic Hub, March 8, 2018, available at
https://www.polytechnichub.com/advantagesdisadvantages-amorphous-metal-transformer/.
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laminations. Hence, in this analysis,
DOE continues to screen out the use of
amorphous steel due to practicability to
manufacture and adverse impacts on
equipment utility.
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b. Remaining Technologies
DOE tentatively concludes that all of
the other identified technologies listed
in section IV.B.4 meet all five screening
criteria to be examined further as design
options. In summary, DOE did not
screen out the following technology
options:
• Magnetic Ballasts
Æ Improved Core Steel
Æ Copper Wiring
Æ Improved Steel Laminations
Æ Improved Windings
Æ Electronic Ballast
• Electronic Ballasts
Æ Improved Components
Æ Improved Circuit Design
For additional details, see chapter 4 of
the NOPD TSD.
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C. Engineering Analysis
In the engineering analysis, DOE
develops cost-efficiency relationships
characterizing the incremental costs of
achieving increased ballast efficiency.
This relationship serves as the basis for
cost-benefit calculations for individual
consumers and the nation. The
methodology for the engineering
analysis consists of the following steps:
(1) Selecting representative equipment
classes; (2) selecting baseline metal
halide ballasts; (3) identifying more
efficient substitutes; (4) developing
efficiency levels; and (5) scaling
efficiency levels to non-representative
equipment classes. The details of the
engineering analysis are discussed in
chapter 5 of the NOPD TSD.
1. Representative Equipment Classes
DOE selects certain equipment classes
as ‘‘representative’’ to focus its analysis.
DOE chooses equipment classes as
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representative primarily because of their
high market volumes and/or unique
characteristics. DOE established 24
equipment classes based on input
voltage, rated lamp wattage, and indoor/
outdoor designation. DOE did not
directly analyze the equipment classes
containing only fixtures with ballasts
tested at 480 V due to low shipment
volumes. DOE determined that only 19
percent of fixtures in its compliance
certification database are fixtures with
ballasts tested at 480 V. DOE selected all
other equipment classes as
representative, resulting in a total of 12
representative classes covering the full
range of lamp wattages, as well as
indoor and outdoor designations.
In summary, DOE directly analyzed
the equipment classes shown in gray in
Table IV.3 of this document. See chapter
5 of the NOPD TSD for further
discussion.
BILLING CODE 6450–01–P
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BILLING CODE 6450–01–C
Metal halide lamp fixtures are
designed to be operated with lamps of
certain rated lamp wattages and contain
ballasts that can operate lamps at these
wattages. To further focus the analysis,
DOE selected a representative rated
wattage in each equipment class. Each
representative wattage was the most
common wattage within each
equipment class. DOE found that
common wattages within each
equipment class were the same for
outdoor and indoor fixtures.
Specifically, DOE selected 70 W, 150 W,
250 W, 400 W, 1000 W and 1500 W as
representative wattages to analyze.
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The >100 W and <150 W equipment
class includes fixtures designed to
operate 150 W lamps that are rated for
use in wet locations, as specified by the
National Electrical Code 2002, section
410.4(A) and contain a ballast that is
rated to operate at ambient air
temperatures above 50 °C, as specified
by UL 1029–2007. These fixtures were
initially exempted by EISA 2007. (42
U.S.C. 6295(hh)(1)(B)(iii)) In the 2014
MHLF final rule, DOE included 150 W
MHLFs previously exempted by EISA
2007 in the >100 W and <150 W
equipment class. 79 FR 7754–7755. In
this analysis, DOE found that 150 W
was the most common wattage in this
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equipment class and selected it as the
representative wattage.
The representative wattages for each
equipment class are summarized in
Table IV.4 of this document. See chapter
5 of the NOPD TSD for further
discussion.
TABLE IV.4—REPRESENTATIVE
WATTAGES
Representative equipment
class
≥50 W and ≤100 W .............
>100 W and <150 W * .........
≥150 W and ≤250 W ** ........
>250 W and ≤500 W ...........
>500 W and ≤1000 W .........
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Representative
wattage
70 W
150 W
250 W
400 W
1000 W
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TABLE IV.4—REPRESENTATIVE
WATTAGES—Continued
Representative equipment
class
>1000 W and ≤2000 W .......
Representative
wattage
1500 W
* Includes 150 W fixtures initially exempted
by EISA 2007, which are fixtures rated only for
150 watt lamps; rated for use in wet locations,
as specified by the NFPA 70–2002, section
410.4(A); and containing a ballast that is rated
to operate at ambient air temperatures above
50 °C, as specified by UL 1029–2007.
** Excludes 150 W fixtures initially exempted
by EISA 2007, which are fixtures rated only for
150 watt lamps; rated for use in wet locations,
as specified by the NFPA 70–2002, section
410.4(A); and containing a ballast that is rated
to operate at ambient air temperatures above
50 °C, as specified by UL 1029–2007.
2. Baseline Ballasts
For each representative equipment
class, DOE selected baseline ballasts to
serve as reference points against which
DOE measured changes from potential
amended energy conservation
standards. Typically, the baseline
ballast is the most common, least
efficient ballast that meets existing
energy conservation standards. In this
analysis, DOE selected as baselines the
least efficient ballast meeting standards
47487
that have common attributes for ballasts
in each equipment class such as circuit
type, input voltage and ballast type.
DOE used the efficiency values of
ballasts contained in MHLFs certified in
DOE’s compliance certification database
to identify baseline ballasts for all
equipment classes except the >1000 W
and ≤2000 W equipment class. Because
fixtures in this equipment class are not
currently subject to standards, and
therefore do not have DOE certification
data, DOE determined ballast efficiency
values by using catalog data. In
summary, DOE directly analyzed the
baseline ballasts shown in Table IV.5 of
this document. See chapter 5 of the
NOPD TSD for more detail.
TABLE IV.5—BASELINE MODELS
Representative equipment class
Wattage
≥50 W and ≤100 W ............................
>100 W and <150 W * ........................
≥150 W and ≤250 W ** .......................
>250 W and ≤500 W ..........................
>500 W and ≤1000 W ........................
>1000 W and ≤2000 W ......................
70
150
250
400
1000
1500
Ballast type
Magnetic
Magnetic
Magnetic
Magnetic
Magnetic
Magnetic
Circuit type
...........
...........
...........
...........
...........
...........
HX–HPF ...........
HX–HPF ...........
CWA .................
CWA .................
CWA .................
CWA .................
Starting method
Pulse
Pulse
Pulse
Pulse
Pulse
Probe
................
................
................
................
................
................
Input voltage
Quad
Quad
Quad
Quad
Quad
Quad
System input
power
................
................
................
................
................
................
89.5
182.0
281.5
443.0
1068.4
1625.0
Ballast
efficiency
0.782
0.824
0.888
0.903
0.936
0.923
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* Includes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA
70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.
** Excludes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the
NFPA 70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.
3. More-Efficient Ballasts
DOE selected more-efficient ballasts
as replacements for each of the baseline
ballasts by considering commercially
available ballasts. DOE also selected
more-efficient ballasts with similar
attributes as the baseline ballast when
possible (e.g., circuit type, input
voltage). As with the baseline ballasts,
DOE used the ballast efficiency values
from the compliance certification
database to identify more efficient
ballasts for all equipment classes except
the >1000 W and ≤2000 W equipment
class which does not have certification
data available. For this equipment class,
DOE determined ballast efficiency
values by first gathering and analyzing
catalog data. DOE then tested the
ballasts to verify the ballast efficiency
reported by the manufacturer. For
instances where the catalog data did not
align with the tested data, DOE selected
more-efficient ballasts based on the
tested ballast efficiency.
As noted in section IV.C.1, the
representative wattage for the >100 W
and <150 W equipment class is 150 W.
This equipment class includes 150 W
MHLFs that are rated for wet-location
and high-temperature. All other 150 W
MHLFs are included in the ≥150 W and
≤250 W equipment class. In the 2014
MHLF final rule, based on test data of
wet-location and high-temperature 150
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W ballasts, DOE identified two
efficiency levels for electronic ballasts
in the >100 W and <150 W equipment
class. 79 FR 7777. In this analysis, based
on its review of the compliance
certification database DOE was unable
to identify 150 W MHLFs rated for wetlocation and high-temperature that
contain electronic ballasts. DOE then
assessed the efficiencies of 150 W
electronic ballasts not rated for wetlocation and high temperature that are
certified in the compliance certification
database. DOE found these electronic
ballast efficiencies to be similar to those
identified in the 2014 MHLF final rule
for the >100 W and <150 W equipment
class. Hence, for the >100 W and <150
W equipment class, DOE selected moreefficient electronic ballasts based on
compliance-certification-database
efficiencies of 150 W MHLFs not rated
for wet-locations and high temperatures.
In response to the July 2019 RFI, EEI
commented that there is minimal energy
savings potential for MHLF technology.
EEI also expressed concerns about
whether the metal halide ballasts
reported in the RFI to be 0.8 percent to
3.3 percent more efficient than the
maximum efficiency levels from the
2014 MHLF final rule are commercially
available for all lamp wattages. EEI also
raised questions about the possibility of
these more efficient metal halide
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ballasts including proprietary
technology or being exclusively
manufactured by one company. (EEI,
No. 2 at p. 2–3)
DOE agrees with EEI that
commercially available metal halide
ballasts are not up to 0.8 percent to 3.3
percent more efficient than the
maximum efficiency levels analyzed in
the 2014 MHLF final rule. Since the July
2019 RFI, DOE updated its analysis and
found that metal halide ballasts that
were more efficient than the maximum
efficiency levels analyzed in the 2014
MHLF final rule no longer appear in its
compliance certification database. (See
section IV.C.4 for further details.)
4. Efficiency Levels
Based on the more-efficient ballasts
selected for analysis, DOE developed
ELs for the representative equipment
classes. DOE identified one magnetic EL
in every equipment class. The moreefficient magnetic EL represents a
magnetic ballast with a higher grade of
steel compared to the baseline. DOE
identified one electronic EL for the ≥150
W and ≤250 W and >250 W and ≤500
W equipment classes. The standard
electronic level represents a ballast with
standard electronic circuitry. DOE
identified a more efficient electronic EL
in the ≥50 W and ≤100 W and >100 W
and <150 W equipment classes. The
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more-efficient electronic EL represents
an electronic ballast with an improved
circuit design and/or more efficient
components compared to the standard
electronic level.
The characteristics of the moreefficient representative units are
summarized in Table IV.6 through Table
IV.11 of this document. See chapter 5 of
the NOPD TSD for more detail.
TABLE IV.6—70 W REPRESENTATIVE UNITS
Equipment class
EL
≥50 W and ≤100 W ..........................
Technology
EL1
EL2
EL3
Rated wattage
Starting method
Input voltage
70
70
70
Pulse ................
Pulse ................
Pulse ................
Tri .....................
Quad ................
Quad ................
More Efficient Magnetic
Standard Electronic ......
Electronic Max Tech .....
System
input power
88.3
0.814
77.7
Ballast
efficiency
0.793
0.860
0.901
TABLE IV.7—150 W REPRESENTATIVE UNITS
Equipment class
EL
>100 W and <150 W * ......................
Technology
EL1
EL2
EL3
Rated wattage
Starting method
Input voltage
150
150
150
Pulse ................
Pulse ................
Pulse ................
Quad ................
Quad ................
Quad ................
More Efficient Magnetic
Standard Electronic ......
Electronic Max Tech .....
System input
power
178.6
166.7
162.2
Ballast
efficiency
0.84
0.9
0.925
* Includes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA
70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.
TABLE IV.8—250 W REPRESENTATIVE UNITS
Equipment class
EL
≥150 W and ≤250 W * ......................
Technology
EL1
EL2
Rated wattage
Starting method
Input voltage
250
250
Pulse ................
Pulse ................
Quad ................
Tri .....................
More Efficient Magnetic
Electronic Max Tech .....
System input
power
276.5
266.2
Ballast
efficiency
0.904
0.939
* Excludes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the
NFPA 70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029–2007.
TABLE IV.9—400 W REPRESENTATIVE UNITS
Equipment class
EL
>250 W and ≤500 W ........................
Technology
EL1
EL2
Rated wattage
Starting method
Input voltage
400
400
Pulse ................
Pulse ................
Quad ................
Tri .....................
More Efficient Magnetic
Electronic Max Tech .....
System input
power
440.5
426.0
Ballast
efficiency
0.908
0.939
TABLE IV.10—1000 W REPRESENTATIVE UNITS
Equipment class
EL
>500 W and ≤1000 W ......................
Technology
EL1
Rated wattage
Starting method
Input voltage
1000
Pulse ................
Quad ................
More Efficient Magnetic
System input
power
1063.8
Ballast
efficiency
0.94
TABLE IV.11—1500 W REPRESENTATIVE UNITS
Equipment class
EL
>500 W and ≤1000 W ......................
Technology
EL1
Starting method
Input voltage
1000
Pulse ................
Quad ................
More Efficient Magnetic
In the 2014 MHLF final rule, DOE
determined that except in a few cases
where the linear form was more
appropriate, a power-law equation best
captured the metal halide ballast
efficiency data. 79 FR 7777. In this
analysis, DOE determined that the
power-law equation and in some cases
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Rated wattage
the linear equation remain valid
representations of the metal halide
ballast efficiency data. DOE ensured that
equations best fit the more-efficient
representative units identified in each
equipment class while forming one
continuous equation across equipment
classes, where possible.
System input
power
1063.8
Ballast
efficiency
0.94
Table IV.12 summarizes the efficiency
requirements and associated equations
at each EL for the representative
equipment classes. DOE requests
comment on the ELs under
consideration for the representative
equipment classes, including the maxtech levels.
TABLE IV.12—SUMMARY OF ELS FOR REPRESENTATIVE EQUIPMENT CLASSES
Equipment class
EL
≥50 W and ≤100 W ........................................................
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EL2
EL3
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Minimum efficiency equation for
ballasts not tested at 480 V *
Technology
More Efficient Magnetic ....................
Standard Electronic ..........................
Electronic Max Tech .........................
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47489
TABLE IV.12—SUMMARY OF ELS FOR REPRESENTATIVE EQUIPMENT CLASSES—Continued
Equipment class
EL
>100 W and <150 W ......................................................
≥150 W and ≤250 W ......................................................
>250 W and ≤500 W ......................................................
>500 W and ≤1000 W ....................................................
>1000 W and ≤2000 W ..................................................
EL1
EL2
EL3
EL1
EL2
EL3
EL1
EL2
EL3
EL1
EL1
Minimum efficiency equation for
ballasts not tested at 480 V *
Technology
More Efficient Magnetic ....................
Standard Electronic ..........................
Electronic Max Tech .........................
More Efficient Magnetic ....................
Standard Electronic ..........................
Electronic Max Tech .........................
More Efficient Magnetic ....................
Standard Electronic ..........................
Electronic Max Tech .........................
More Efficient Magnetic ....................
More Efficient Magnetic ....................
1/(1+1.16*P∧(¥0.345))
1/(1+1*P∧(¥0.42))
1/(1+0.4*P∧(¥0.3))
1/(1+0.5017*P∧(¥0.26))
1/(1+1*P∧(¥0.42))
1/(1+0.4*P∧(¥0.3))
1/(1+0.5017*P∧(¥0.26))
1/(1+1*P∧(-0.42))
1/(1+0.4*P∧(¥0.3))
0.000057*P+0.881
¥0.000008*P+0.946
* P is defined as the rated wattage of the lamp the fixture is designed to operate.
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CA IOUs recommended that DOE
consider fixtures that include ballasts
meeting the 90–92 percent efficiency
California Appliance Efficiency
Standards for fixtures between 13,050
and 43,500 lumens when determining
new efficiency levels. (CA IOUs, No. 5
at p. 2–3) CA IOUs also commented that
if DOE is unable to move toward a
technology-agnostic standard that
incorporates the entire fixture, DOE
should at least adopt efficiency levels
based on electronic ballast technology
and not magnetic ballast technology.
(CA IOUs, No. 5 at p. 3)
Table IV.6 through Table IV.11 in this
section describe the more efficient
ballasts analyzed at each EL, including
the ballast efficiency of each unit. As
described in this section, some ELs can
only be met by electronic ballast
technology. DOE considers the benefits
and burdens of each level in section V.D
of this document.
5. Design Standard
Under 42 U.S.C. 6295(hh)(4), DOE is
permitted to establish a standard based
on both design and performance
requirements. Existing design standards
for MHLFs relate to fixtures that contain
probe-start ballasts. EISA 2007 required
that MHLFs designed to operate lamps
rated at or above 150 W but at or less
than 500 W contain magnetic probe-start
ballasts that are at least 94 percent
efficient. (42 U.S.C. 6295(hh)(1)(A)(ii))
In the 2014 MHLF final rule, DOE
adopted a design standard that prohibits
the sale of probe-start ballasts in newly
sold fixtures that are designed to operate
rated lamp wattages from 501 W–1000
W. 79 FR 7778; 10 CFR 431.326(d). DOE
reviewed MHLFs currently offered on
the market and did not find any ballast
characteristics or other performance
features of the fixtures during the
analysis for this NOPD to lead it to
conclude that a new design standard
would result in significant energy
savings. Therefore, in this analysis, DOE
is not proposing any new design
standards for MHLFs.
6. Scaling to Other Equipment Classes
DOE did not directly analyze MHLFs
with ballasts that would be 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, for each
representative wattage certified to DOE,
DOE compared quad-voltage ballasts
from the representative equipment
classes to their 480 V ballast
counterparts using information from the
compliance certification database.
Ballasts capable of operating 120 V or
277 V are predominantly quad-voltage
ballasts, therefore, DOE chose to
compare quad-voltage ballasts with 480
V ballasts to develop a scaling factor.
Based on its review of the compliance
certification database, DOE determined
that the average reduction in ballast
efficiency for 480 V ballasts compared
to quad ballasts is greater for ballasts
designed to operate lamps rated less
than 150 W compared to ballasts
designed to operate lamps rated greater
than or equal to 150 W. Hence, using the
method described above, DOE
developed two separate scaling factors,
one for the 50 W–150 W range and the
second for the 150 W–1000 W range. For
non-representative equipment classes in
the 50 W–150 W range, DOE found the
average reduction in ballast efficiency to
be 3.0 percent, and for those in the 150
W–1000 W range, DOE found the
average reduction in ballast efficiency to
be 1.0 percent. DOE applied these
scaling factors to the representative
equipment class EL equations to
develop corresponding EL equations for
ballasts tested at an input voltage of
480V. Specifically, for the nonrepresentative equipment classes in the
50 W–150 W range, DOE used a
multiplier of 0.97, and for those in the
150 W–1000 W range, DOE used a
multiplier of 0.99.
For ballasts greater than 1000 W, DOE
determined the need for a scaling factor
based on manufacturer catalog data.
DOE determined that ballasts greater
than 1000 W do not show a difference
in efficiency between 480 V and non480 V ballasts. DOE did not apply a
scaling factor to develop efficiency
levels for 480 V ballasts in this
equipment class, however, DOE
continues to consider the 480 V and
non-480 V equipment classes separately
for MHLFs greater than 1000 W for the
purposes of this analysis.
Additionally, for the ≥150 W and
≤250 W non-representative equipment
class, DOE adjusted the resulting scaled
equations to ensure all ELs were equal
to or more stringent than the EISA 2007
minimum ballast efficiency standard.
See chapter 5 of the NOPD TSD for
additional details.
Table IV.13 summarizes the efficiency
requirements at each EL for the nonrepresentative equipment classes. DOE
requests comment on the ELs under
consideration for the non-representative
equipment classes, including the maxtech levels.
TABLE IV.13—SUMMARY OF ELS FOR NON-REPRESENTATIVE EQUIPMENT CLASSES
Equipment class
EL
≥50 W and ≤100 W ........................................................
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Minimum efficiency equation for
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Technology
Improved magnetic ...........................
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TABLE IV.13—SUMMARY OF ELS FOR NON-REPRESENTATIVE EQUIPMENT CLASSES—Continued
Equipment class
EL
>100 W and <150 W * ....................................................
≥150 W and ≤250 W ** ...................................................
>250 W and ≤500 W ......................................................
>500 W and ≤1000W .....................................................
>1000 W and ≤2000 W ..................................................
EL2
EL3
EL1
EL2
EL3
EL1
Minimum efficiency equation for
ballasts tested at 480 V
Technology
Standard Electronic ..........................
Electronic Max Tech .........................
Improved magnetic ...........................
Standard Electronic ..........................
Electronic Max Tech .........................
Improved magnetic ...........................
EL2
EL3
EL1
EL2
EL3
EL1
EL1
Standard Electronic ..........................
Electronic Max Tech .........................
Improved magnetic ...........................
Standard Electronic ..........................
Electronic Max Tech .........................
Improved magnetic ...........................
Improved magnetic ...........................
0.97/(1+1*P∧(¥0.42))
0.97/(1+0.4*P∧(¥0.3))
0.97*(0.0006*P+0.748)
0.97/(1+1*P∧(¥0.42))
0.97/(1+0.4*P∧(¥0.3))
≥150 W and <210 W: 0.88
≥210 W and ≤250 W:
(1+0.5017*P∧(¥0.26))
0.99/(1+1*P∧(¥0.42))
0.99/(1+0.4*P∧(¥0.3))
0.99/(1+0.5017*P∧(¥0.26))
0.99/(1+1*P∧(¥0.42))
0.99/(1+0.4*P∧(¥0.3))
0.99*(0.0001*P+0.881)
0.99*(¥0.000008*P+0.946)
0.99/
* P is defined as the rated wattage of the lamp the fixture is designed to operate.
7. Manufacturer Selling Price
DOE develops manufacturer selling
prices (‘‘MSPs’’) for covered equipment
and applies markups to create end-user
prices to use as inputs to the LCC
analysis and NIA. The MSP of a MHLF
comprises of the MSP of the fixture
components including any necessary
additional features and the MSP of the
metal halide ballast contained in the
fixture. For this analysis, DOE
conducted teardown analyses on 31
commercially available MHLFs and the
ballasts included in these fixtures.
Using the information from these
teardowns, DOE summed the direct
material, labor, and overhead costs used
to manufacture a MHLF or metal halide
ballast, to calculate the manufacturing
production cost (‘‘MPC’’).23 The
following sections describe the
development of MSPs of fixture
components and more-efficient MH
ballasts identified for each efficiency
level considered in this analysis.
a. Fixtures
To determine the fixture components
MSPs, DOE conducted fixture
teardowns to derive MPCs of empty
fixtures (i.e., lamp enclosure and
optics). The empty fixture does not
include the ballast or lamp. DOE then
added the other components required by
the system (including ballast and any
cost adders associated with
electronically ballasted systems) and
applied appropriate markups to obtain a
final MSP for the entire fixture.
To calculate an empty fixture price,
DOE identified the applications
commonly served by the representative
wattage in each equipment class. DOE
recognizes that technological changes in
the ballast, specifically moving from
magnetic ballasts to electronic ballasts,
can necessitate alterations to the fixture.
These changes often incur additional
costs that are dependent on the price of
the baseline fixture that is altered. DOE
estimates a baseline empty fixture cost
as well as incremental costs at ELs that
require electronic ballasts. The cost
adders to the fixtures are discussed later
in this section.
DOE selected one to four
representative fixture types for each
rated wattage range based on the most
common application(s) within that
range. DOE determined the common
application(s) by reviewing all fixtures
in DOE’s compliance certification
database, identifying the type of fixture
for each basic model, and then using a
product count to determine the most
popular fixture types in each equipment
class. DOE selected representative
fixture types separately for indoor and
outdoor applications. The representative
fixture types for each equipment class,
are shown in Table IV.14 below. See
chapter 5 of the NOPD TSD for further
discussion.
TABLE IV.14—REPRESENTATIVE FIXTURE TYPES
Representative equipment class
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≥50 W and ≤100 W .................................
>100 W and <150 W * .............................
≥150 W and ≤250 W ** ............................
>250 W and ≤500 W ...............................
>500 W and ≤1000 W .............................
>1000 W and ≤2000 W ...........................
Representative fixture types
Representative
wattage
Indoor
70 W .................
150 W ...............
250 W ...............
400 W ...............
1000 W .............
1500 W .............
Downlight ...............................................
Downlight ...............................................
High-Bay ................................................
High-Bay ................................................
High-Bay ................................................
Sports .....................................................
Outdoor
Bollard, Flood, Post Top, Wallpack.
Area, Flood, Post Top, Wallpack.
Area, Flood, Post Top, Cobrahead.
Area, Flood, Post Top, Cobrahead.
Area, Flood, Sports.
Sports.
* Includes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations,
specified by the NFPA 70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C,
specified by UL 1029–2007.
** Excludes 150 W fixtures initially exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations,
specified by the NFPA 70–2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C,
specified by UL 1029–2007.
23 When viewed from the company-wide
perspective, the sum of all material, labor, and
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The MPCs of empty fixtures were
determined using teardowns.
Teardowns were conducted for 31
fixtures that spanned the representative
wattages and the applications identified
for each representative wattage. The
MPC of the empty fixture for each
representative wattage was calculated
by weighting the empty fixture cost for
each application by the popularity of
each application. DOE determined the
weightings based on the number of
fixtures for each application at each
representative wattage in DOE’s
certification database. See chapter 5 of
the NOPD TSD for further details.
While the empty fixture MPCs remain
the same at each magnetic efficiency
level, incremental costs are added when
the fixture contains an electronic
ballast. In the 2014 MHLF final rule
DOE applied cost adders to fixtures that
use electronic ballasts for (1) transient
protection, (2) thermal management,
and (3) 120 V auxiliary power
functionality. 79 FR 7781. These costs
varied based on whether the fixture
application was indoor, indoor
industrial, or outdoor.
Fixtures with electronic ballasts that
are used in outdoor or indoor industrial
applications must be able to withstand
10 kilovolt voltage transients. Therefore,
in the 2014 MHLF final rule, DOE
included the high-volume cost of a
voltage transient protection device
which it determined to be $10.31. 79 FR
7781. In this analysis, based on market
research, DOE determined the price of
voltage transient protection to be $9.03.
DOE added $9.03 to the empty fixture
MPC for outdoor and indoor industrial
fixtures at efficiency levels requiring an
electronic ballast.
Compared to magnetic ballasts,
electronic ballasts are more vulnerable
to high ambient temperatures, which
can cause premature ballast failure.
Hence, in the 2014 MHLF final rule,
DOE included the cost of thermal
management and determined it to be a
20 percent increase in MPC based on
manufacturer feedback and teardown
analysis. 79 FR 7782. In this analysis,
DOE determined that the 20 percent
increase in the empty fixture cost for
thermal management in mental halide
fixtures containing electronic ballasts
remains valid. Therefore, DOE applied a
20 percent increase to the empty fixture
MPC at efficiency levels requiring an
electronic ballast.
As discussed in the 2014 MHLF final
rule, indoor applications may require a
120 V auxiliary tap used to operate
emergency lighting, which can be easily
incorporated into a magnetic ballast but
requires additional design for an
electronic ballast. 79 FR 7782. In the
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2014 MHLF final rule, DOE included
the cost of an auxiliary tap, determining
that auxiliary taps cost about $7.50 but
because the tap is needed in only 10
percent of the ballasts in indoor fixtures
DOE applied a cost of $0.75. Id. In this
determination, DOE conducted market
research and found the average market
price of the 120 V auxiliary tap to be
$7.38. Similarly, because the auxiliary
tap is needed in only 10 percent of the
ballasts in indoor fixtures, DOE added
$0.74 to the indoor empty fixture MPC
for efficiency levels requiring an
electronic ballast.
The manufacturer markup converts
MPC to MSP. For this analysis, DOE
maintained the manufacturer markup
developed in the 2014 MHLF final rule.
In that rule, DOE determined the fixture
manufacturer markup to be 1.58 based
on financial information from
manufacturers’ SEC 10–K reports, as
well as feedback from manufacturer
interviews. 79 FR 7783. Hence, in this
analysis, DOE applied the fixture
manufacturer markup of 1.58 to the
empty fixture MPC to determine the
MSP of the fixture at each efficiency
level.
b. Ballasts
To determine the MPCs of the metal
halide ballasts identified in this
analysis, DOE used data from the
teardown analysis which included cost
data for magnetic ballasts at the baseline
in each equipment class. To determine
the ballast MPC at the higher efficiency
levels, DOE developed a ratio between
the average retail price of ballasts at the
efficiency level under consideration and
ballasts at the baseline. DOE collected
retail prices from electrical distributors
(e.g., Grainger, Graybar) as well as
internet retailers to determine average
retail prices for ballasts. For efficiency
levels without retail prices available,
DOE used a ratio between the same
efficiency levels in a different wattage
class or interpolated based on efficiency
and ballast MPC.
The manufacturer markup converts
MPC to MSP. For this analysis, DOE
maintained the manufacturer markup
developed in the 2014 MHLF final rule.
In that rule, DOE determined the ballast
manufacturer markup to be 1.47 based
on financial information from
manufacturers’ SEC 10–K reports, as
well as feedback from manufacturer
interviews. 79 FR 7783. Hence, in this
analysis, DOE applied the ballast
manufacturer markup of 1.47 to the
ballast MPC to determine the MSP of
replacement ballasts at each efficiency
level. If the ballast was sold within a
new fixture, DOE applied the ballast
manufacturer markup of 1.47 and the
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fixture manufacturer markup of 1.58 to
the ballast MPC.
The total empty fixture MSPs,
replacement ballast MSPs, and fixture
with ballast MSPs are detailed the
NOPD TSD. DOE requests comment on
the methodology and resulting MSPs
developed for all equipment classes.
D. Markups Analysis
The markups analysis develops
appropriate markups (e.g., retailer
markups, distributor markups,
contractor markups) in the distribution
chain and sales taxes to convert the
MSP estimates derived in the
engineering analysis to customer prices,
which are then used in the LCC and PBP
analysis. At each step in the distribution
channel, companies mark up the price
of the product to cover business costs
and profit margin. DOE used the same
distribution channels and markups as in
the 2014 MHLF final rule.
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). Indoor fixtures are all assumed
to go through the electrical wholesaler
distribution channel. Outdoor fixtures
are assumed to go through all three
distribution channels as follows: 60
percent electrical wholesaler, 20 percent
contractor, and 20 percent utility.
2. Estimation of Markups
To estimate wholesaler and utility
markups, DOE used financial data from
10–K reports of publicly owned
electrical wholesalers and utilities.
DOE’s markup analysis developed both
baseline and incremental markups to
transform the fixture MSP into an enduser 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 higherefficiency designs sold under market
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conditions with new and amended
energy conservation standards.
In the 2014 MHLF final rule, DOE
assumed a wholesaler baseline markup
of 1.23 and a contractor markup of 1.13,
yielding a total wholesaler distribution
channel baseline markup of 1.49. The
lower wholesaler incremental markup of
1.05 yields a lower total incremental
markup through this distribution
channel of 1.27. DOE also assumed a
utility markup of 1.00 for the utility
distribution channel in which the
manufacturer sells a fixture directly to
the end-user. DOE again assumed a
contractor markup of 1.13 for the utility
distribution channel in which a
manufacturer sells a fixture to a
contractor who in turn sells it to the
end-user yielding an overall markup of
1.21 for this channel. 79 FR 7783. DOE
used these same markups for this NOPD
analysis.
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.24 These data represent
weighted averages that include state,
county, and city rates. DOE then
calculated population-weighted average
tax values for each census division and
large state, and then derived U.S.
average tax values using a populationweighted average of the census division
and large state values. For this NOPD,
this approach provided a national
average tax rate of 7.2 percent.
3. Summary of Markups
Table IV.15 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 IV.15—SUMMARY OF FIXTURE DISTRIBUTION CHANNEL MARKUPS
Wholesaler distribution
Utility distribution
Via wholesaler and contractor
Baseline
Baseline
Electrical Wholesaler (Distributor) ...........
Utility ........................................................
Contractor or Installer ..............................
1.23
N/A
1.13
Sales Tax .................................................
1.49
Incremental
N/A
1.00
1.13
N/A
1.00
1.13
1.07
1.27
Baseline
Incremental
N/A
1.00
N/A
N/A
1.00
N/A
1.07
1.21
1.21
1.07
1.07
and DOE has continued to use the same
methodology in this NOPD (with
updated inputs as appropriate). (NEMA,
No. 3 at pp. 7–8) Chapter 7 of the NOPD
TSD provides details on DOE’s energy
use analysis for MHLFs. DOE welcomes
any relevant data and comments on the
energy use analysis methodology.
The purpose of the energy use
analysis is to determine the annual
energy consumption of MHLFs at
different efficiencies in the commercial,
industrial, and outdoor stationary
sectors, and to assess the energy savings
potential of increased MHLF efficiency.
The energy use analysis estimates the
range of energy use of MHLFs in the
field (i.e., as they are actually used by
customers). The energy use analysis
provides the basis for other analyses
DOE performed, particularly
assessments of the energy savings and
the savings in operating costs that could
result from adoption of amended or new
standards.
To develop annual energy use
estimates, DOE multiplied the lampand-ballast system input power (in
watts) by annual usage (in hours per
year). DOE characterized representative
lamp-and-ballast systems in the
engineering analysis, which provided
measured input power ratings. To
characterize the country’s average usage
of fixtures for a typical year, DOE
developed annual operating hour
distributions by sector, using data
published in the 2015 U.S. Lighting
Market Characterization (‘‘LMC’’).25 For
the ≥50 W and ≤100 W to >500 W and
≤1000 W equipment classes, DOE
obtained weighted-average annual
operating hours for the commercial,
industrial, and outdoor stationary
sectors of approximately 2,300 hours,
5,100 hours, and 5,000 hours,
respectively. For the 1,500 W equipment
class, DOE assigned annual operating
hours of approximately 770 hours for all
lamps according to the 2015 LMC
estimate of 2.1 hours per day for sports
field lighting, consistent with the
methodology from the 2014 MHLF final
rule.26
All comments received in response to
the July 2019 RFI regarding the
methodology to develop annual
operating hours and energy use from the
2014 MHLF final rule were supportive,
24 Sales Tax Clearinghouse, Inc. The Sales Tax
Clearinghouse. (Last accessed December 5, 2019.)
https://thestc.com/STRates.stm.
25 Navigant Consulting, Inc. 2015 U.S. Lighting
Market Characterization. 2017. U.S. Department of
Energy: Washington, DC Report No. DOE/EE–1719.
(Last accessed December 5, 2019.) https://
energy.gov/eere/ssl/downloads/2015-us-lightingmarket-characterization.
26 U.S. Department of Energy—Office of Energy
Efficiency and Renewable Energy. Technical
Support Document: Energy Conservation Program
for Consumer Products and Certain Commercial and
Industrial Equipment: Metal Halide Lamp Fixtures.
January 2014. Washington, DC (Last accessed
December 5, 2019.) https://www.regulations.gov/
document?D=EERE-2009-BT-STD-0018-0069.
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 NOPD TSD
provides details on DOE’s development
of markups for MHLFs. DOE welcomes
any relevant data and comments on the
markups analysis methodology.
E. Energy Use Analysis
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1.05
N/A
1.13
1.07
Overall ......................................................
Direct to end user
Incremental
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F. Life-Cycle Cost and Payback Period
Analysis
DOE conducted LCC and PBP
analyses to evaluate the economic
impacts on individual customers of
potential energy conservation standards
for MHLFs. The effect of new or
amended energy conservation standards
on individual customers usually
involves a reduction in operating cost
and an increase in purchase cost. DOE
used the following two metrics to
measure customer impacts:
• The LCC is the total customer
expense of equipment over the life of
that equipment, consisting of total
installed cost (manufacturer selling
price, distribution chain markups, sales
tax, and installation costs) plus
operating costs (expenses for energy use,
maintenance, and repair). To compute
the operating costs, DOE discounts
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future operating costs to the time of
purchase and sums 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 a moreefficient equipment through lower
operating costs. DOE calculates the PBP
by dividing the change in purchase cost
at higher efficiency levels by the change
in annual operating cost for the year that
amended or new standards are assumed
to take effect.
For any given efficiency level, DOE
measured the change in LCC relative to
the LCC in the no-new-standards case,
which reflects the estimated efficiency
distribution of MHLFs in the absence of
new or amended energy conservation
standards. In contrast, the PBP for a
given efficiency level is measured
relative to the baseline equipment.
For each considered efficiency level
in each equipment class, DOE
calculated the LCC and PBP for a
nationally representative set of building
types. As stated previously, DOE
developed customer samples from the
2015 LMC. For each sample customer,
DOE determined the energy
consumption for the MHLF and the
appropriate electricity price. By
developing a representative sample of
building types, the analysis captured the
variability in energy consumption and
energy prices associated with the use of
MHLFs.
Inputs to the calculation of total
installed cost include the cost of the
equipment—which includes MPCs,
manufacturer markups, retailer and
distributor 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, and discount rates.
DOE created distributions of values for
operating hours, equipment lifetime,
discount rates, electricity prices, and
sales taxes, with probabilities attached
to each value, to account for their
uncertainty and variability. 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 BallTM (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 MHLF user
samples. The model calculated the LCC
and PBP for equipment at each
efficiency level for 10,000 customers per
simulation run. The analytical results
47493
include a distribution of 10,000 data
points showing the range of LCC savings
for a given efficiency level relative to
the no-new-standards case efficiency
distribution. In performing an iteration
of the Monte Carlo simulation for a
given consumer, product efficiency is
chosen based on its probability. If the
chosen product efficiency is greater than
or equal to the efficiency of the standard
level under consideration, the LCC and
PBP calculation reveals that a consumer
is not impacted by the standard level.
By accounting for consumers who
already purchase more-efficient
products, DOE avoids overstating the
potential benefits from increasing
product efficiency.
DOE calculated the LCC and PBP for
all customers of MHLFs as if each were
to purchase new equipment in the
expected year of required compliance
with new or amended standards. Any
amended standards would apply to
MHLFs manufactured three years after
the date on which any new or amended
standard is published. (42 U.S.C.
6295(hh)(3)(B)) At this time, DOE
estimates publication of a final rule in
the latter half of 2021. Therefore, for
purposes of its analysis, DOE used 2025
as the first year of compliance with any
amended standards for MHLFs.
Table IV.16 summarizes the approach
and data DOE used to derive inputs to
the LCC and PBP calculations. The
subsections that follow provide further
discussion. Details of the spreadsheet
model, and of all the inputs to the LCC
and PBP analyses, are contained in
chapter 8 of the NOPD TSD and its
appendices.
TABLE IV.16—SUMMARY OF INPUTS AND METHODS FOR THE LCC AND PBP ANALYSIS*
Inputs
Source/method
Equipment Cost ....................................
Derived by multiplying MSPs by distribution channel markups (taken from the 2014 MHLF final rule)
and sales tax.
Used the same installation costs as in the 2014 MHLF final rule, but inflated to 2018$. The 2014 MHLF
final rule costs were calculated using estimated labor times and applicable labor rates from ‘‘RS
Means Electrical Cost Data’’ (2013), Sweets Electrical Cost Guide 2013, and the U.S. Bureau of
Labor Statistics.
The total annual energy use multiplied by the operating hours per year, which were determined separately for indoor and outdoor fixtures. Average number of hours based on the 2015 LMC.
Electricity: Based on Edison Electric Institute data for 2018.
Variability: Regional energy prices determined for 13 census divisions and large states.
Based on AEO 2019 price projections.
Used the same labor and material costs for lamp and ballast replacements as in the 2014 MHLF final
rule, but inflated to 2018$.
Used the same lifetimes as in the 2014 MHLF final rule.
Ballasts: Assumed an average of 50,000 hours for magnetic ballasts and 40,000 hours for electronic
ballasts.
Fixtures: Assumed an average of 20 years for indoor fixtures and 25 years for outdoor fixtures.
Developed a distribution of discount rates for the commercial, industrial, and outdoor stationary sectors.
2025.
Installation Costs ..................................
Annual Energy Use ..............................
Energy Prices .......................................
Energy Price Trends ............................
Replacement Costs ..............................
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Equipment Lifetime ...............................
Discount Rates .....................................
Compliance Date ..................................
* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the NOPD TSD.
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1. Equipment Cost
To calculate customer equipment
costs, DOE multiplied the MSPs
developed in the engineering analysis
by the markups described previously
(along with sales taxes). DOE used
different markups for baseline
equipment and higher-efficiency
equipment, because DOE applies an
incremental markup to the increase in
MSP associated with higher-efficiency
equipment. See section IV.D for further
details.
2. Installation Cost
Installation cost is the cost to install
the fixture such as the labor, overhead,
and any miscellaneous materials and
parts needed. DOE used the installation
costs from the 2014 MHLF final rule but
inflated to 2018$.
3. Annual Energy Consumption
For each sampled customer, DOE
determined the energy consumption for
an MHLF at different efficiency levels
using the approach described previously
in section IV.E of this document. For
this NOPD, 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 (approximately 770 hours per
year) for the 1,500 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
DOE derived average and marginal
annual commercial and industrial
electricity prices for 13 regions (9
Census Divisions and 4 large states)
using 2018 data from Edison Electric
Institute.27
To estimate energy prices in future
years, DOE multiplied the average
regional energy prices by a projection of
annual change in national-average
commercial and industrial energy prices
in the Reference case of Annual Energy
Outlook 2019 (AEO 2019).28 AEO 2019
has an end year of 2050. To estimate
price trends after 2050, DOE used the
compound annual growth rate of change
in prices between 2035 and 2050.
ballast, and lamp lifetimes by applying
Weibull survival distributions to the
components’ rated lifetimes.
Furthermore, DOE included a residual
value calculation for lamps and ballasts
to account for the residual monetary
value associated with the remaining life
in the lamp and ballast at the end of the
fixture lifetime. All assumptions for
estimating equipment lifetime are taken
from the 2014 MHLF final rule. 79 FR
7787.
5. Replacement Costs
The discount rate is the rate at which
future expenditures are discounted to
estimate their present value. In this
NOPD, DOE estimated separate discount
rates for commercial, industrial, and
outdoor stationary applications. DOE
used discount rate data from a 2019
Lawrence Berkeley National Laboratory
report.29 The average discount rates,
weighted by the shares of each rate
value in the sectoral distributions, are
8.3 percent for commercial end-users,
8.8 percent for industrial end-users, and
3.2 percent for outdoor stationary endusers. For more information regarding
discount rates, see chapter 8 of the
NOPD TSD.
7. Discount Rates
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. The costs are taken from the
2014 MHLF final rule but inflated to
2018$. 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 associated with
lamp or ballast replacements are
included in the calculation of operating
costs.
6. Equipment Lifetime
8. Energy Efficiency Distribution in the
No-New-Standards Case
DOE defined equipment lifetime as
the age when a fixture, ballast, or lamp
is retired from service. For fixtures in all
equipment classes, DOE assumed
average lifetimes for indoor and outdoor
fixtures of 20 and 25 years, respectively.
DOE also assumed that magnetic
ballasts had a rated lifetime of 50,000
hours and electronic ballasts had a rated
lifetime of 40,000 hours. DOE used
manufacturer catalog data to obtain
rated lifetime estimates (in hours) for
lamps in each equipment class. DOE
accounted for uncertainty in the fixture,
DOE developed a no-new-standards
case efficiency distribution using model
count data from the compliance
certification database collected on
October 10, 2019. The compliance
certification database does not contain
models in the >1000 W and ≤2000 W
equipment class; therefore, DOE
assumed 56 percent of the market is at
the baseline and 44 percent of the
market is at EL 1, based on MHLF
catalog data. The complete efficiency
distribution for 2025 is shown in Table
IV.17.
TABLE IV.17—MHLF EFFICIENCY DISTRIBUTION BY EQUIPMENT CLASS FOR 2025
Equipment class *
≥50 W and
≤100 W
(%)
Efficiency level
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0
1
2
3
...............................................................
...............................................................
...............................................................
...............................................................
>100 W and
<150 W
(%)
83.1
0.3
9.2
7.4
88.1
6.0
0.0
5.9
≥150 W and
≤250 W
(%)
>250 W and
≤500 W
(%)
>500 W and
≤1000 W
(%)
>1000 W and
≤2000 W
(%)
73.6
18.9
7.5
........................
87.6
0.3
12.2
........................
99.5
0.5
........................
........................
56.0
44.0
........................
........................
* Columns may not sum to 100% due to rounding.
27 Edison Electric Institute. Typical Bills and
Average Rates Report. Winter 2017, Summer 2017:
Washington, DC.
28 U.S. Energy Information Administration.
Annual Energy Outlook 2019 with Projections to
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2050. 2019. Washington, DC Report No. AEO2019.
(Last accessed May 13, 2019.) https://www.eia.gov/
outlooks/aeo/pdf/aeo2019.pdf.
29 Fujita, K.S. Commercial, Industrial, and
Institutional Discount Rate Estimation for Efficiency
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Standards Analysis: Sector-Level Data 1998–2018.
2019. Lawrence Berkeley National Laboratory:
Berkeley, CA. (Last accessed January 15, 2020.)
https://eta.lbl.gov/publications/commercialindustrial-institutional.
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9. Payback Period Analysis
The payback period is the amount of
time it takes the customer to recover the
additional installed cost of moreefficient equipment, compared to
baseline equipment, through energy cost
savings. Payback periods are expressed
in years. Payback periods that exceed
the life of the equipment mean that the
increased total installed cost is not
recovered in reduced operating
expenses.
The inputs to the PBP calculation for
each efficiency level are the change in
total installed cost of the equipment and
the change in the first-year annual
operating expenditures relative to the
baseline. The PBP calculation uses the
same inputs as the LCC analysis, except
that discount rates are not needed.
As noted previously, EPCA
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 first
year’s energy savings resulting from the
standard, as calculated under the
applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered
efficiency level, DOE determined the
value of the first year’s energy savings
by calculating the energy savings in
accordance with the applicable DOE test
procedure, and multiplying those
savings by the average energy price
projection for the year in which
compliance with the amended standards
would be required.
DOE welcomes any relevant data and
comments on the life-cycle cost and
payback period analysis methodology.
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G. Shipments Analysis
DOE uses projections of annual
equipment shipments to calculate the
national impacts of potential amended
or new energy conservation standards
on energy use and NPV.30 The
shipments model takes an accounting
approach, tracking market shares of
each equipment class and the vintage of
units in the stock. Stock accounting uses
equipment shipments as inputs to
estimate the age distribution of inservice equipment stocks for all years.
The age distribution of in-service
equipment stocks is a key input to
calculations of both the NES and NPV,
because operating costs for any year
30 DOE uses data on manufacturer shipments as
a proxy for national sales, as aggregate data on sales
are lacking. In general one would expect a close
correspondence between shipments and sales.
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depend on the age distribution of the
stock.
The stock turnover model calculates
demand for new MHLFs based on the
expected demand for replacement
MHLFs and the decrease in MHLF
demand due to the adoption of out-ofscope LED alternatives. The model is
initialized using a time series of
historical shipments data compiled from
the 2014 MHLF final rule and data from
NEMA. The historical shipments for
2008 from the 2014 MHLF final rule
were projected to 2018 using NEMA
sales indices from 2008 to 2018. 79 FR
7788–7789.
NEMA commented in response to the
July 2019 RFI that out-of-scope LED
alternatives are now the preferred
technology for traditional MHLF
customers. (NEMA, No. 3 at pp. 2–3)
DOE assumed an increasing fraction of
the MHLF market will move to out-ofscope LED alternatives over the course
of the shipments analysis period. DOE
modelled the incursion of LED
equipment in the form of a Bass
diffusion curve.31 The parameters for
the Bass diffusion curve are based on
fitting a Bass diffusion curve to market
share data for general service LED lamps
based on data published by NEMA. This
same approach was used in the final
determination for general service
incandescent lamps; see chapter 9 of the
final determination TSD.32 84 FR 71626,
71658 (December 27, 2019).
DOE apportioned the total shipments
of MHLFs to each EL in the no-newstandards case using data downloaded
from the compliance certification
database 33 and data provided by NEMA
in comments to the July 2019 RFI.
(NEMA, No. 3 at pp.11–14). Equipment
listed in the CCMS database were
categorized by equipment class,
efficiency level, and ballast type. The
counts for each category were scaled
based on ballast type by the NEMA
market shares for magnetic and
electronic ballasts reported in 2018.
For the standards cases, DOE used a
‘‘roll-up’’ approach to estimate market
share for each EL for the year that
standards are assumed to become
effective (2025). For each standards
case, the market shares of ELs in the nonew-standards case that do not meet the
standard under consideration ‘‘roll up’’
to meet the new standard level, and the
market share of equipment above the
standard remains unchanged.
For both the no-new-standards and
standards cases, DOE assumed no
efficiency trend over the analysis
period. For a given case, market shares
were held fixed to their 2025
distribution.
DOE typically includes the impact of
price learning in its analysis. In a
standard price learning model,34 the
price of a given technology is related to
its cumulative production, as
represented by total cumulative
shipments. In response to the July 2019
RFI, NEMA indicated that MHLFs are a
mature technology and are no longer a
preferred technology. (NEMA, No. 3 at
p. 2) DOE assumed MHLFs have
reached a stable price point due to the
high volume of total cumulative
shipments and would not undergo price
learning in this NOPD analysis. DOE
welcomes any relevant data and
comments on the shipments analysis
methodology.
31 Bass, F.M. A New Product Growth Model for
Consumer Durables. Management Science. 1969.
15(5): pp. 215–227.
32 Chapter 9 of the GSIL final determination TSD
is available at https://www.regulations.gov/
document?D=EERE-2019-BT-STD-0022-0116
33 See https://www.regulations.doe.gov/
certification-data/products.html (Last accessed on
January 21, 2020).
34 Taylor, M. and S.K. Fujita. Accounting for
Technological Change in Regulatory Impact
Analyses: The Learning Curve Technique. 2013.
Lawrence Berkeley National Laboratory: Berkeley,
CA. Report No. LBNL–6195E. (Last accessed
January 7, 2020.) https://eta.lbl.gov/publications/
accounting-technological-change.
35 The NIA accounts for impacts in the 50 states
and U.S. territories.
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H. National Impact Analysis
The NIA assesses the NES and the
NPV from a national perspective of total
customer costs and savings that would
be expected to result from new or
amended standards at specific efficiency
levels.35 DOE calculates the NES and
NPV for the potential standard levels
considered based on projections of
annual equipment shipments, along
with the annual energy consumption
and total installed cost data from the
energy use and LCC analyses. For the
present analysis, DOE projected the
energy savings, operating cost savings,
equipment costs, and NPV of customer
benefits over the lifetime of MHLFs sold
from 2025 through 2054.
DOE evaluates the impacts of new or
amended standards by comparing a case
without such standards with standardscase projections. The no-new-standards
case characterizes energy use and
customer costs for each equipment class
in the absence of new or amended
energy conservation standards. DOE
compares the no-new-standards case
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.
For the standards cases, DOE considers
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from each TSL. Interested parties can
review DOE’s analyses by changing
various input quantities within the
spreadsheet. The NIA spreadsheet
model uses typical values (as opposed
to probability distributions) as inputs.
how a given standard would likely
affect the market shares of equipment
with efficiencies greater than the
standard.
DOE uses a spreadsheet model to
calculate the energy savings and the
national customer costs and savings
Table IV.18 summarizes the inputs
and methods DOE used for the NIA
analysis for this NOPD. Discussion of
these inputs and methods follows the
table. See chapter 10 of the NOPD TSD
for further details.
TABLE IV.18—SUMMARY OF INPUTS AND METHODS FOR THE NATIONAL IMPACT ANALYSIS
Inputs
Method
Shipments ...........................................................
First Full Year of Standard Compliance .............
No-new-standards Case Efficiency Trend ..........
Standards Case Efficiency Trend .......................
Annual Energy Consumption per Unit ................
Total Installed Cost per Unit ...............................
Repair and Maintenance Cost per Unit ..............
Residual Value per Unit ......................................
Electricity Prices .................................................
Electricity Price Trends .......................................
Energy Site-to-Primary and FFC Conversion .....
Discount Rate .....................................................
Present Year .......................................................
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1. National Energy Savings
The NES analysis involves a
comparison of national energy
consumption of the considered
equipment between each potential TSL
and the case with no new or amended
energy conservation standards. DOE
calculated the national energy
consumption by multiplying the
number of units (stock) of each
equipment type (by vintage or age) by
the unit energy consumption (also by
vintage). DOE calculated annual NES
based on the difference in national
energy consumption for the no-new
standards case and for each higher
efficiency standard case. DOE estimated
energy consumption and savings based
on site energy and converted the
electricity consumption and savings to
primary energy (i.e., the energy
consumed by power plants to generate
site electricity) using annual conversion
factors derived from AEO 2019.
Cumulative energy savings are the sum
of the NES for each year over the
timeframe of the analysis.
DOE generally accounts for the direct
rebound effect in its NES analyses.
Direct rebound reflects the idea that as
appliances become more efficient,
customers use more of their service
because their operating cost is reduced.
In the case of lighting, the rebound
effect could be manifested in increased
hours of use or in increased lighting
density (lumens per square foot). In
response to the July 2019 RFI, NEMA
commented that a rebound rate of 0 is
appropriate. (NEMA, No. 3 at p. 9) DOE
assumed no rebound effect for MHLFs
in this NOPD.
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Annual shipments from shipments model for each considered TSL.
2025.
No trend assumed.
No trend assumed.
Calculated for each efficiency level based on inputs from the energy use analysis.
MHLF prices and installation costs from the LCC analysis.
Cost to replace lamp and ballast over the lifetime of the fixture.
The monetary value of remaining lamp and ballast lifetime at the end of the fixture lifetime.
Estimated marginal electricity prices from the LCC analysis.
AEO 2019 forecasts (to 2050) and extrapolation thereafter.
A time-series conversion factor based on AEO 2019.
3 percent and 7 percent.
2020.
In 2011, 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 Sciences, DOE
announced its intention to use FFC
measures of energy use and greenhouse
gas and other emissions to the extent
that emissions analyses are conducted.
76 FR 51281 (Aug. 18, 2011). After
evaluating the approaches discussed in
the August 18, 2011 proposal, DOE
published a statement of amended
policy in which DOE explained its
determination that Energy Information
Administration’s (EIA’s) National
Energy Modeling System (‘‘NEMS’’) is
the most appropriate tool for its FFC
analysis and its intention to use NEMS
for that purpose. 77 FR 49701 (Aug. 17,
2012). NEMS is a public domain, multisector, partial equilibrium model of the
U.S. energy sector 36 that EIA uses to
prepare its Annual Energy Outlook. The
FFC factors incorporate losses in
production and delivery in the case of
natural gas (including fugitive
emissions) and additional energy used
to produce and deliver the various fuels
used by power plants. The approach
used for deriving FFC measures of
energy use and emissions is described
in appendix 10B of the NOPD TSD.
2. Net Present Value Analysis
The inputs for determining the NPV
of the total costs and benefits
36 For more information on NEMS, refer to The
National Energy Modeling System: An Overview
2009, DOE/EIA–0581(2009), October 2009.
Available at https://www.eia.gov/forecasts/aeo/
index.cfm.
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experienced by customers are (1) total
annual installed cost, (2) total annual
operating costs (energy costs and repair
and maintenance costs), and (3) a
discount factor to calculate the present
value of costs and savings. DOE
calculates net savings each year as the
difference between the no-newstandards case and each standards case
in terms of total savings in operating
costs versus total increases in installed
costs. DOE calculates operating cost
savings over the lifetime of equipment
shipped during the analysis period.
Energy cost savings, which are part of
operating cost savings, are calculated
using the estimated energy savings in
each year and the projected price of the
appropriate form of energy. To estimate
energy prices in future years, DOE
multiplied the average national
marginal electricity prices by the
forecast of annual national-average
commercial or industrial electricity
price changes in the Reference case from
AEO 2019, which has an end year of
2050. To estimate price trends after
2050, DOE used the average annual rate
of change in prices from 2041 to 2050.
DOE includes the cost of replacing
failed lamps and ballasts over the course
of the lifetime of the fixture. DOE
assumed that lamps and ballasts were
replaced at their rated lifetime. When
replacing a ballast, DOE assumed the
lamp was also replaced at the same
time, independent of the timing of the
previous lamp replacement. For more
details see chapter 10 of the NOPD TSD.
DOE also estimates the residual
monetary value remaining in the lamp
and ballast at the end of the fixture
lifetime and applies it as a credit to
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operating costs (i.e., the residual value
is deducted from operating costs). See
chapter 10 of the NOPD TSD for more
details on DOE’s calculation of the
residual value.
In calculating the NPV, DOE
multiplies the net savings in future
years by a discount factor to determine
their present value. For this NOPD, DOE
estimated the NPV of customer benefits
using both a 3-percent and a 7-percent
real discount rate. DOE uses these
discount rates in accordance with
guidance provided by the Office of
Management and Budget (‘‘OMB’’) to
Federal agencies on the development of
regulatory analysis.37 The discount rates
for the determination of NPV are in
contrast to the discount rates used in the
LCC analysis, which are designed to
reflect a customer’s perspective. The 7percent real value is an estimate of the
average before-tax rate of return to
private capital in the U.S. economy. The
3-percent real value represents the
‘‘social rate of time preference,’’ which
is the rate at which society discounts
future consumption flows to their
present value.
V. Analytical Results and Conclusions
The following section addresses the
results from DOE’s analyses with
respect to the considered energy
conservation standards for MHLFs. It
addresses the ELs examined by DOE and
the projected impacts of each of these
levels. Additional details regarding
DOE’s analyses are contained in the
NOPD TSD.
A. Trial Standard Levels
DOE analyzed the benefits and
burdens of three TSLs for MHLFs. TSL
1 is composed of EL 1 for all equipment
classes. TSL 2 is composed of the
efficiency levels corresponding to the
least efficient electronic ballast level for
each equipment class, if any efficiency
levels corresponding to an electronic
ballast exist. TSL 3 is composed of the
max-tech level for each equipment class.
Table V.1 presents the TSLs and the
corresponding efficiency levels that
DOE has identified for potential
amended energy conservation standards
for MHLFs.
TABLE V.1—TRIAL STANDARD LEVELS FOR MHLFS
≥50 W and
≤100 W
TSL
TSL
TSL
TSL
0
1
2
3
.......................................................
.......................................................
.......................................................
.......................................................
0
1
2
3
B. Economic Impacts on Individual
Customers
DOE analyzed the cost effectiveness
(i.e., any savings in operating costs
compared to any increase in purchase
price likely to result from the
imposition of a standard) by considering
the LCC and PBP. These analyses are
discussed in the following sections.
1. Life-Cycle Cost and Payback Period
In general, higher efficiency
equipment affects consumers in two
ways: (1) Purchase price increases and
(2) annual operating costs decrease.38
Inputs used for calculating the LCC and
PBP include total installed costs (i.e.,
product price plus installation costs),
and operating costs (i.e., annual energy
use, energy prices, energy price trends,
≥150 W and
≤250 W
>100 W and
<150 W
0
1
2
3
>250 W and
≤500 W
0
1
2
2
and replacement costs). The LCC
calculation also uses product lifetime
and a discount rate. Chapter 8 of the
NOPD TSD provides detailed
information on the LCC and PBP
analyses.
Table V.2 through Table V.13 show
the LCC and PBP results for the ELs and
TSLs considered for each equipment
class, with indoor and outdoor
installations aggregated together using
equipment shipments in the analysis
period start year (2025). Results for each
equipment class are shown in two
tables. In the first table, the simple
payback is measured relative to the
baseline product. For ELs having a
higher first year’s operating cost than
that of the baseline, the payback period
is ‘‘Never,’’ because the additional
>500 W and
≤1000 W
0
1
2
2
>1000 W and
≤2000 W
0
1
1
1
0
1
1
1
installed cost relative to the baseline is
not recouped. In the second table,
impacts are measured relative to the
efficiency distribution in the no-newstandards case in the compliance year
(see section IV.F.8 of this document).
Because some customers purchase
products with higher efficiency in the
no-new-standards case, the average
savings are less than the difference
between the average LCC of the baseline
product and the average LCC at each
TSL. The savings refer only to
customers who are affected by a
standard at a given TSL. Those who
already purchase equipment with
efficiency at or above a given TSL are
not affected. Customers for whom the
LCC increases at a given TSL experience
a net cost.
TABLE V.2—AVERAGE LCC AND PBP RESULTS FOR THE ≥50 W AND ≤100 W EQUIPMENT CLASS
Average costs (2018$)
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Efficiency level
Installed
cost
0 ...............................................................
1 ...............................................................
2 ...............................................................
835.94
848.48
878.81
37 United States Office of Management and
Budget. Circular A–4: Regulatory Analysis.
September 17, 2003. Section E. Available at https://
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First year’s
operating
cost
Lifetime
operating
cost
123.58
123.51
124.20
1,534.59
1,532.13
1,549.40
www.whitehouse.gov/omb/memoranda/m0321.html.
38 While it is generally true that higher-efficiency
equipment has lower operating costs, MHLF
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Simple
payback
(years)
LCC
2,370.53
2,380.61
2,428.21
........................
182.0
Never
Average
fixture
lifetime
(years)
24.1
24.1
24.1
operating costs in this analysis also incorporate the
costs of lamp and ballast replacements. Due to these
replacement costs, higher operating costs can be
experienced at efficiency levels above the baseline.
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TABLE V.2—AVERAGE LCC AND PBP RESULTS FOR THE ≥50 W AND ≤100 W EQUIPMENT CLASS—Continued
Average costs (2018$)
Efficiency level
Installed
cost
3 ...............................................................
First year’s
operating
cost
895.39
Lifetime
operating
cost
123.51
LCC
1,538.46
Average
fixture
lifetime
(years)
Simple
payback
(years)
2,433.85
893.2
24.1
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
TABLE V.3—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE ≥50 W AND ≤100 W
EQUIPMENT CLASS
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
2
3
Percent of
consumers that
experience
net cost
(10.09)
(57.39)
(57.38)
83.2
62.7
72.1
* The savings represent the average LCC for affected consumers.
TABLE V.4—AVERAGE LCC AND PBP RESULTS FOR THE >100 W AND <150 W EQUIPMENT CLASS
Average costs (2018$)
Efficiency level
0
1
2
3
Installed
cost
...............................................................
...............................................................
...............................................................
...............................................................
First year’s
operating
cost
803.46
817.04
853.41
970.98
Lifetime
operating
cost
146.31
145.35
143.65
147.00
LCC
1,702.74
1,690.07
1,678.31
1,706.26
Average
fixture
lifetime
(years)
Simple
payback
(years)
2,506.20
2,507.11
2,531.72
2,677.25
........................
14.2
18.8
Never
23.5
23.5
23.5
23.5
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
TABLE V.5—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE >100 W AND <150 W
EQUIPMENT CLASS
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
2
3
Percent of
consumers that
experience
net cost
(0.87)
(25.22)
(170.66)
57.4
50.4
90.7
* The savings represent the average LCC for affected consumers.
TABLE V.6—AVERAGE LCC AND PBP RESULTS FOR THE ≥150 W AND ≤250 W EQUIPMENT CLASS
Average costs (2018$)
jbell on DSKJLSW7X2PROD with PROPOSALS2
Efficiency level
Installed
cost
0 ...............................................................
1 ...............................................................
2 ...............................................................
963.46
988.66
1,149.72
First year’s
operating
cost
Lifetime
operating
cost
181.07
180.75
184.26
2,089.02
2,082.57
2,123.00
Simple
payback
(years)
LCC
3,052.48
3,071.23
3,272.71
........................
79.4
Never
Average
fixture
lifetime
(years)
23.5
23.5
23.5
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
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TABLE V.7—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE ≥150 W AND ≤250 W
EQUIPMENT CLASS
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
2
2
Percent of
consumers that
experience
net cost
(18.70)
(216.24)
(216.24)
73.4
90.9
90.9
* The savings represent the average LCC for affected consumers.
TABLE V.8—AVERAGE LCC AND PBP RESULTS FOR THE >250 W AND ≤500 W EQUIPMENT CLASS
Average costs (2018$)
Efficiency level
Installed
cost
0 ...............................................................
1 ...............................................................
2 ...............................................................
First year’s
operating
cost
1,098.78
1,122.58
1,376.47
Lifetime
operating
cost
237.28
237.08
245.60
LCC
2,713.41
2,708.49
2,800.48
Average
fixture
lifetime
(years)
Simple
payback
(years)
3,812.19
3,831.07
4,176.95
........................
121.8
Never
23.5
23.5
23.5
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
TABLE V.9—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE >250 W AND ≤500 W
EQUIPMENT CLASS
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
2
2
Percent of
consumers that
experience
net cost
(18.87)
(364.30)
(364.30)
86.9
87.2
87.2
* The savings represent the average LCC for affected consumers.
TABLE V.10—AVERAGE LCC AND PBP RESULTS FOR THE >500 W AND ≤1000 W EQUIPMENT CLASS
Average costs (2018$)
Efficiency level
Installed
cost
0 ...............................................................
1 ...............................................................
First year’s
operating
cost
1,305.39
1,336.23
Lifetime
operating
cost
555.06
554.15
Simple
payback
(years)
LCC
6,526.50
6,512.29
7,831.89
7,848.52
Average
fixture
lifetime
(years)
........................
33.6
23.7
23.7
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
TABLE V.11—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE >500 W AND ≤1000 W
EQUIPMENT CLASS
jbell on DSKJLSW7X2PROD with PROPOSALS2
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
1
1
(16.64)
(16.64)
(16.64)
* The savings represent the average LCC for affected consumers.
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Percent of
consumers that
experience
net cost
93.3
93.3
93.3
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Federal Register / Vol. 85, No. 151 / Wednesday, August 5, 2020 / Proposed Rules
TABLE V.12—AVERAGE LCC AND PBP RESULTS FOR THE >1000 W AND ≤2000 W EQUIPMENT CLASS
Average costs (2018$)
Efficiency level
First year’s
operating
cost
Installed
cost
0 ...............................................................
1 ...............................................................
1,392.61
1,423.31
Lifetime
operating
cost
179.13
177.41
LCC
2,145.92
2,124.97
Average
fixture
lifetime
years
Simple
payback
years
3,538.52
3,548.28
0.0
17.9
23.7
23.7
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative
to the baseline equipment.
TABLE V.13—AVERAGE LCC SAVINGS RELATIVE TO THE NO-NEW-STANDARDS CASE FOR THE >1000 W AND ≤2000 W
EQUIPMENT CLASS
Life-cycle cost savings
Efficiency
level
TSL
1 .......................................................................................................................................
2 .......................................................................................................................................
3 .......................................................................................................................................
Average
LCC savings *
(2018$)
1
1
1
Percent of
consumers that
experience
net cost
(9.80)
(9.80)
(9.80)
48.0
48.0
48.0
* The savings represent the average LCC for affected consumers.
2. Rebuttable Presumption Payback
As discussed in section IV.F.9 of this
document, EPCA establishes a
rebuttable presumption that an energy
conservation standard is economically
justified if the increased purchase cost
for equipment that meets the standard is
less than three times the value of the
first-year energy savings resulting from
the standard. In calculating a rebuttable
presumption payback period for each of
the considered ELs, DOE used discrete
values, and, as required by EPCA, based
the energy use calculation on the DOE
test procedure for MHLFs. In contrast,
the PBPs presented in section V.B.1 of
this document were calculated using
distributions that reflect the range of
energy use in the field. See chapter 8 of
the NOPD TSD for more information on
the rebuttable presumption payback
analysis.
C. National Impact Analysis
This section presents DOE’s estimates
of NES and the NPV of customer
benefits that would result from each of
the TSLs considered as potential
amended standards.
1. Significance of Energy Savings
To estimate the energy savings
attributable to potential amended
standards for MHLFs, DOE compared
the energy consumption under the nonew-standards case to the anticipated
energy consumption under each TSL.
The savings are measured over the
entire lifetime of equipment purchased
in the 30-year period that begins in the
year of anticipated compliance with
amended standards (2025–2054). Table
V.14 presents DOE’s projections of the
national energy savings for each TSL
considered for MHLFs. The savings
were calculated using the approach
described in section IV.H.1 of this
document.
TABLE V.14—CUMULATIVE NATIONAL ENERGY SAVINGS FOR MHLFS; 30 YEARS OF SHIPMENTS
[2025–2054]
Trial standard level
Equipment class
1
Site Energy Savings (quads) ..........................
jbell on DSKJLSW7X2PROD with PROPOSALS2
Primary Energy Savings (quads) ....................
FFC Energy Savings (quads) .........................
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3
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.000006
0.000005
0.00001
0.00001
0.00001
0.0000003
0.00004
0.00002
0.00007
0.0001
0.00001
0.0000003
0.00006
0.00003
0.00007
0.0001
0.00001
0.0000003
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.00005
0.00002
0.00001
0.00003
0.00004
0.00003
0.0000007
0.0002
0.0001
0.00007
0.0002
0.0003
0.00003
0.0000007
0.0003
0.0002
0.00008
0.0002
0.0003
0.00003
0.0000007
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
0.0001
0.00002
0.00001
0.00003
0.0007
0.0001
0.00007
0.0002
0.0007
0.0002
0.00009
0.0002
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47501
TABLE V.14—CUMULATIVE NATIONAL ENERGY SAVINGS FOR MHLFS; 30 YEARS OF SHIPMENTS—Continued
[2025–2054]
Trial standard level
Equipment class
1
2
3
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.00004
0.00003
0.0000008
0.0003
0.00003
0.0000008
0.0003
0.00003
0.0000008
Total * ......................................................
0.0001
0.0007
0.0008
* Total may not equal sum due to rounding.
OMB Circular A–4 39 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 9 years, rather than 30 years, of
equipment 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.40 The review
timeframe established in EPCA is
generally not synchronized with the
equipment lifetime, equipment
manufacturing cycles, or other factors
specific to MHLFs. Thus, such results
are presented for informational
purposes only and are not indicative of
any change in DOE’s analytical
methodology. The NES sensitivity
analysis results based on a 9-year
analytical period are presented in Table
V.15 of this document. The impacts are
counted over the lifetime of MHLFs
purchased in 2025–2033.
TABLE V.15—CUMULATIVE NATIONAL ENERGY SAVINGS FOR MHLFS; 9 YEARS OF SHIPMENTS
[2025–2033]
Trial standard level
Equipment class
1
Site Energy Savings (quads) ..........................
Primary Energy Savings (quads) ....................
FFC Energy Savings (quads) .........................
2
3
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.000006
0.000005
0.00001
0.00001
0.00001
0.0000003
0.00004
0.00002
0.00007
0.0001
0.00001
0.0000003
0.00006
0.00003
0.00007
0.0001
0.00001
0.0000003
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.00005
0.00002
0.00001
0.00003
0.00004
0.00003
0.0000007
0.0002
0.0001
0.00007
0.0002
0.0003
0.00003
0.0000007
0.0003
0.0002
0.00008
0.0002
0.0003
0.00003
0.0000007
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
0.0001
0.00002
0.00001
0.00003
0.00004
0.00003
0.0000008
0.0007
0.0001
0.00007
0.0002
0.0003
0.00003
0.0000008
0.0007
0.0002
0.00009
0.0002
0.0003
0.00003
0.0000008
Total * ......................................................
0.0001
0.0007
0.0008
jbell on DSKJLSW7X2PROD with PROPOSALS2
* Total may not equal sum due to rounding.
The NES results for the 30-years and
9-years of shipments presented in Table
V.15 and Table V.16, respectively, are
nearly identical due to the significant
shift to out-of-scope LED equipment that
occurs over the course of the analysis
period. DOE projects that MHLF
shipments drop by more than 99 percent
in 2030 relative to shipments in 2019
due to the incursion of out-of-scope LED
equipment.
39 U.S. Office of Management and Budget.
Circular A–4: Regulatory Analysis. September 17,
2003. https://www.whitehouse.gov/omb/circulars_
a004_a-4/.
40 Section 325(m) of 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. A 9-year analysis
period may not be appropriate given the variability
that occurs in the timing of standards reviews and
the fact that for some products, the compliance
period is 5 years rather than 3 years.
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2. 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 MHLFs. In accordance
with OMB’s guidelines on regulatory
analysis,41 DOE calculated NPV using
both a 7-percent and a 3-percent real
discount rate. Table V.16 shows the
customer NPV results with impacts
counted over the lifetime of equipment
purchased in 2025–2054.
TABLE V.16—CUMULATIVE NET PRESENT VALUE OF CUSTOMER BENEFITS FOR MHLFS; 30 YEARS OF SHIPMENTS
[2025–2054]
Trial standard level
Equipment class
3 percent (millions 2018$) ..............................
7 percent (millions 2018$) ..............................
1
2
3
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
¥0.13
0.012
¥0.19
¥0.29
¥0.077
0.00026
¥2.08
¥0.49
¥4.57
¥3.33
¥0.077
0.00026
¥2.11
¥1.19
¥4.57
¥3.33
¥0.077
0.00026
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
¥0.68
¥0.10
¥0.0022
¥0.15
¥0.22
¥0.071
¥0.0010
¥10.54
¥1.14
¥0.28
¥2.83
¥2.83
¥0.071
¥0.0010
¥11.29
¥1.20
¥0.76
¥2.83
¥2.83
¥0.071
¥0.0010
Total * ......................................................
¥0.54
¥7.16
¥7.70
* Total may not equal sum due to rounding.
The NPV results based on the
aforementioned 9-year analytical period
are presented in Table V.17 of this
document. The impacts are counted
over the lifetime of equipment
purchased in 2025–2033. As mentioned
previously, such results are presented
for informational purposes only and are
not indicative of any change in DOE’s
analytical methodology or decision
criteria.
TABLE V.17—CUMULATIVE NET PRESENT VALUE OF CUSTOMER BENEFITS FOR MHLFS; 9 YEARS OF SHIPMENTS
[2025–2033]
Trial standard level
Equipment class
3 percent (millions 2018$) ..............................
7 percent (millions 2018$) ..............................
1
2
3
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
¥0.13
0.012
¥0.19
¥0.29
¥0.077
0.00026
¥2.07
¥0.48
¥4.56
¥3.32
¥0.077
0.00026
¥2.11
¥1.19
¥4.56
¥3.32
¥0.077
0.00026
Total * ......................................................
≥50 W and ≤100 W ........................................
>100 W and <150 W ......................................
≥150 W and ≤250 W ......................................
>250 W and ≤500 W ......................................
>500 W and ≤1000 W ....................................
>1000 W and ≤2000 W ..................................
¥0.68
¥0.10
0.00
¥0.15
¥0.22
¥0.071
¥0.00095
¥10.52
¥1.14
¥0.28
¥2.83
¥2.83
¥0.071
¥0.00095
¥11.26
¥1.20
¥0.76
¥2.83
¥2.83
¥0.071
¥0.00095
Total * ......................................................
¥0.54
¥7.15
¥7.68
jbell on DSKJLSW7X2PROD with PROPOSALS2
* Total may not equal sum due to rounding.
The NPV results for the 30-years and
9-years of shipments presented in Table
V.16 and Table V.17, respectively, are
nearly identical due to the significant
shift to out-of-scope LED equipment that
occurs over the course of the analysis
period. The previous results reflect
DOE’s assumption of no price trend over
the analysis period (see section IV.G).
41 U.S. Office of Management and Budget.
Circular A–4: Regulatory Analysis. September 17,
2003. https://www.whitehouse.gov/omb/circulars_
a004_a-4/.
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When considering amended energy
conservation standards, the standards
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that DOE adopts for any type (or class)
of covered equipment must be designed
to achieve the maximum improvement
in energy efficiency that the Secretary
determines is technologically feasible
and economically justified. (42 U.S.C.
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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 by, to the greatest extent
practicable, considering the seven
statutory factors discussed previously.
(42 U.S.C. 6295(o)(2)(B)(i)) The new or
amended standard must also result in
significant conservation of energy. (42
U.S.C. 6295(o)(3)(B))
For this NOPD, DOE considered the
impacts of amended standards for
MHLFs at analyzed TSLs, beginning
with the maximum technologically
feasible level, to determine whether that
level would result in a significant
conservation of energy. DOE also
considered whether that level was
economically justified. Where the maxtech level was not economically
justified, DOE then considered the next
most efficient level and undertook the
same evaluation.
Because an analysis of potential
energy savings and economic
justification first requires an evaluation
of the relevant technology, in the
following sections DOE first discusses
the technological feasibility of amended
standards. DOE then addresses the
energy savings and economic
justification associated with potential
amended standards.
jbell on DSKJLSW7X2PROD with PROPOSALS2
1. Technological Feasibility
EPCA mandates that DOE consider
whether amended energy conservation
standards for MHLFs would be
technologically feasible. (42 U.S.C.
6295(o)(2)(A) and (3)(B)) DOE has
tentatively determined that there are
technology options that would improve
the efficiency of ballasts contained
within MHLFs. These technology
options are being used in commercially
available MHLFs and therefore are
technologically feasible. (See section
IV.B.4 for further information.) Hence,
DOE has tentatively determined that
amended energy conservation standards
for MHLFs are technologically feasible.
2. Significant Conservation of Energy
EPCA also mandates that DOE
consider whether amended energy
conservation standards for MHLF would
result in significant energy savings. (42
U.S.C. 6295(o)(3)(B)) On February 14,
2020 DOE issued a final rule that
defined a significant energy savings
threshold (‘‘Process Rule’’). 85 FR 8626.
The Process Rule establishes a two-step
process for determining the significance
of energy savings using an absolute and
percentage threshold. Section 6 of the
Process Rule. DOE first evaluates
whether standards at the max-tech level
would result in a minimum site-energy
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savings of 0.3 quads over a 30-year
period. Section 6(b)(2) of the Process
Rule. If the 0.3 quad threshold is not
met, DOE then evaluates whether energy
savings at the max-tech level represent
at least 10 percent of the total energy
usage of the covered equipment over a
30-year period. Section 6(b)(3) of the
Process Rule. If the percentage threshold
is not met, DOE proposes to determine
that no significant energy savings would
likely result from setting amended
standards. Section 6(b)(4) of the Process
Rule.
In this analysis, DOE estimates that
amended standards for MHLFs would
result in site energy savings of 0.0003
quads at max-tech levels over a 30-year
analysis period (2025–2054). (See
results in Table V.14.) Because the site
energy savings do not meet the 0.3
quads threshold set forth in Section
6(b)(2) of the Process Rule, DOE
compared the max-tech savings to the
total energy usage to calculate a
percentage reduction in energy usage.
This comparison yielded a reduction in
site energy use of 3.6 percent over a 30year period. Because the reduction in
site energy use is less than 10 percent
as set forth in Section 6(b)(3) and (4) of
the Process Rule, DOE determined that
amended standards for metal halide
lamp fixtures would not result in
significant energy savings.
periods are much higher than the
average fixture lifetime with the
exception of the >100 W and <150 W
equipment class at EL 1 and EL 2 and
for the >1000 W and ≤2000 W
equipment class at EL 1.
Based on these negative LCC and
predominantly negative NPV (i.e., the
second EPCA factor of savings in
operating costs), DOE has tentatively
determined that any potential positive
impact of the other statutory factors
would not outweigh the increased costs
to consumers. Hence DOE has
tentatively determined that amended
standards at the TSLs under
consideration are not economically
justified.
3. Economic Justification
In determining whether a standard is
economically justified, the Secretary
must determine whether the benefits of
the standard exceed its burdens,
considering to the greatest extent
practicable the seven statutory factors
discussed previously. (42 U.S.C.
6295(o)(2)(B)(i)) One of those seven
factors is 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 standard.
This factor is assessed using the life
cycle cost and payback period analysis,
discussed in section IV.F, and the
national net present value, discussed in
section IV.H.2 of this document.
At TSL 3, TSL 2, and TSL 1 the
average LCC savings are negative for all
equipment classes (see section V.B.1 of
this document). The NPV benefits at
these TSLs are also negative for all
equipment classes at the 3-percent and
7-percent discount rates except for the
>1000 W and ≤2000 W equipment class
which has positive NPV of $0.00026
million at the 3-percent discount rate
(see section V.C.2 of this document).
Additionally, the simple payback
This proposed determination has been
determined to be not significant for
purposes of Executive Order (E.O.)
12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993). As
a result, OMB did not review this
proposed determination.
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4. Summary
In this proposed determination, DOE
has tentatively determined that
amended standards for MHLF would
not result in significant conservation of
energy or be economically justified.
Hence, DOE’s initial determination is to
not amend standards for MHLFs. DOE
requests comments on its initial
determination that energy conservation
standards should not be amended for
MHLFs.
VI. Procedural Issues and Regulatory
Review
A. Review Under Executive Order 12866
B. Review Under Executive Orders
13771 and 13777
On January 30, 2017, the President
issued E.O. 13771, ‘‘Reducing
Regulation and Controlling Regulatory
Costs.’’ 82 FR 9339 (Feb. 3, 2017). E.O.
13771 stated the policy of the executive
branch is to be prudent and financially
responsible in the expenditure of funds,
from both public and private sources.
E.O. 13771 stated it is essential to
manage the costs associated with the
governmental imposition of private
expenditures required to comply with
Federal regulations.
Additionally, on February 24, 2017,
the President issued E.O. 13777,
‘‘Enforcing the Regulatory Reform
Agenda.’’ 82 FR 12285 (March 1, 2017).
E.O. 13777 required the head of each
agency to designate an agency official as
its Regulatory Reform Officer (‘‘RRO’’).
Each RRO oversees the implementation
of regulatory reform initiatives and
policies to ensure that agencies
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effectively carry out regulatory reforms,
consistent with applicable law. Further,
E.O. 13777 requires the establishment of
a regulatory task force at each agency.
The regulatory task force is required to
make recommendations to the agency
head regarding the repeal, replacement,
or modification of existing regulations,
consistent with applicable law. At a
minimum, each regulatory reform task
force must attempt to identify
regulations that:
(i) Eliminate jobs, or inhibit job
creation;
(ii) Are outdated, unnecessary, or
ineffective;
(iii) Impose costs that exceed benefits;
(iv) Create a serious inconsistency or
otherwise interfere with regulatory
reform initiatives and policies;
(v) Are inconsistent with the
requirements of Information Quality
Act, or the guidance issued pursuant to
that Act, in particular those regulations
that rely in whole or in part on data,
information, or methods that are not
publicly available or that are
insufficiently transparent to meet the
standard for reproducibility; or
(vi) Derive from or implement
Executive Orders or other Presidential
directives that have been subsequently
rescinded or substantially modified.
DOE initially concludes that this
proposed determination is consistent
with the directives set forth in these
executive orders.
As discussed in this document, DOE
is proposing to not amend energy
conservation standards for MHLFs.
Therefore, if finalized as proposed, this
determination is expected to be an E.O.
13771 other action.
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C. 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, unless the agency certifies
that the rule, if promulgated, will not
have a significant economic impact on
a substantial number of small entities.
As required by E.O. 13272, ‘‘Proper
Consideration of Small Entities in
Agency Rulemaking,’’ 67 FR 53461
(Aug. 16, 2002), DOE published
procedures and policies on February 19,
2003, to ensure that the potential
impacts of its rules on small entities are
properly considered during the
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of the General
Counsel’s website (https://energy.gov/gc/
office-general-counsel).
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DOE reviewed this proposed
determination under the provisions of
the Regulatory Flexibility Act and the
policies and procedures published on
February 19, 2003. Because DOE is not
proposing to amend standards for
MHLFs, if finalized, the determination
would not amend any energy
conservation standards. On the basis of
the foregoing, DOE certifies that the
proposed determination, if finalized,
would have no significant economic
impact on a substantial number of small
entities. Accordingly, DOE has not
prepared an IRFA for this proposed
determination. DOE will transmit this
certification and supporting statement
of factual basis to the Chief Counsel for
Advocacy of the Small Business
Administration for review under 5
U.S.C. 605(b).
D. Review Under the National
Environmental Policy Act
DOE is analyzing this proposed action
in accordance with the National
Environmental Policy Act (‘‘NEPA’’)
and DOE’s NEPA implementing
regulations (10 CFR part 1021). DOE’s
regulations include a categorical
exclusion for actions which are
interpretations or rulings with respect to
existing regulations. 10 CFR part 1021,
subpart D, appendix A4. DOE
anticipates that this action qualifies for
categorical exclusion A4 because it is an
interpretation or ruling in regards to an
existing regulation and otherwise meets
the requirements for application of a
categorical exclusion. See 10 CFR
1021.410. DOE will complete its NEPA
review before issuing the final action.
E. Review Under Executive Order 13132
E.O. 13132, ‘‘Federalism,’’ 64 FR
43255 (Aug. 10, 1999), imposes certain
requirements on Federal agencies
formulating and implementing policies
or regulations that preempt State law or
that have federalism implications. The
Executive Order requires agencies to
examine the constitutional and statutory
authority supporting any action that
would limit the policymaking discretion
of the States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have federalism implications. On March
14, 2000, DOE published a statement of
policy describing the intergovernmental
consultation process it will follow in the
development of such regulations. 65 FR
13735. DOE has examined this proposed
determination and has tentatively
determined that it would not have a
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substantial direct effect on the States, on
the relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
levels of government. EPCA governs and
prescribes Federal preemption of State
regulations as to energy conservation for
the products that are the subject of this
proposed 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)
Therefore, no further action is required
by E.O. 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 E.O.
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, (3) provide a clear
legal standard for affected conduct
rather than a general standard, and (4)
promote simplification and burden
reduction. 61 FR 4729 (Feb. 7, 1996).
Regarding the review required by
section 3(a), section 3(b) of E.O. 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 proposed
determination meets the relevant
standards of E.O. 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
proposed regulatory action likely to
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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 proposed ‘‘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 them. 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 https://energy.gov/sites/
prod/files/gcprod/documents/umra_
97.pdf.
This proposed determination does not
contain a Federal intergovernmental
mandate, nor is it expected to require
expenditures of $100 million or more in
any one year by the private sector. As
a result, the analytical requirements of
UMRA do not apply.
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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
proposed determination 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
Pursuant to E.O. 12630,
‘‘Governmental Actions and Interference
with Constitutionally Protected Property
Rights,’’ 53 FR 8859 (Mar. 15, 1988),
DOE has determined that this proposed
determination 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
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Act, 2001 (44 U.S.C. 3516 note) provides
for Federal agencies to review most
disseminations of information to the
public under information quality
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 this NOPD 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
E.O. 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 proposed 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 Executive 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 proposed
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.
Because this proposed determination
does not propose amended energy
conservation standards for MHLFs, it is
not a significant energy action, nor has
it been designated as such by the
Administrator at OIRA. Accordingly,
DOE has not prepared a Statement of
Energy Effects.
L. Information Quality
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
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47505
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.’’ Id. at 70 FR 2667.
In response to OMB’s Bulletin, DOE
conducted formal peer reviews of the
energy conservation standards
development process and the analyses
that are typically used and has prepared
a report describing that peer review.42
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. DOE has
determined that the peer-reviewed
analytical process continues to reflect
current practice, and the Department
followed that process for developing
energy conservation standards in the
case of the present action.
VII. Public Participation
A. Participation in the Webinar
The time and date of the webinar are
listed in the DATES section at the
beginning of this document. If no
participants register for the webinar
then it will be cancelled. Webinar
registration information, participant
instructions, and information about the
capabilities available to webinar
participants will be published on DOE’s
website: https://www1.eere.energy.gov/
buildings/appliance_standards/
standards.aspx?productid=14.
Participants are responsible for ensuring
their systems are compatible with the
webinar software.
Additionally, you may request an inperson meeting to be held prior to the
close of the request period provided in
the DATES section of this document.
Requests for an in-person meeting may
be made by contacting Appliance and
Equipment Standards Program staff at
(202) 287–1445 or by email: Appliance_
Standards_Public_Meetings@ee.doe.gov.
B. Submission of Comments
DOE will accept comments, data, and
information regarding this proposed
determination no later than the date
provided in the DATES section at the
42 ‘‘Energy Conservation Standards Rulemaking
Peer Review Report.’’ 2007. Available at https://
energy.gov/eere/buildings/downloads/energyconservation-standards-rulemaking-peer-reviewreport-0.
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beginning of this proposed
determination. Interested parties may
submit comments, data, and other
information using any of the methods
described in the ADDRESSES section at
the beginning of this document.
Submitting comments via https://
www.regulations.gov. The https://
www.regulations.gov web page will
require you to provide your name and
contact information. Your contact
information will be viewable to DOE
Building Technologies staff only. Your
contact information will not be publicly
viewable except for your first and last
names, organization name (if any), and
submitter representative name (if any).
If your comment is not processed
properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment itself or in any
documents attached to your comment.
Any information that you do not want
to be publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Otherwise, persons viewing comments
will see only first and last names,
organization names, correspondence
containing comments, and any
documents submitted with the
comments.
Do not submit to https://
www.regulations.gov information for
which disclosure is restricted by statute,
such as trade secrets and commercial or
financial information (hereinafter
referred to as Confidential Business
Information (‘‘CBI’’)). Comments
submitted through https://
www.regulations.gov cannot be claimed
as CBI. Comments received through the
website will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through https://www.regulations.gov
before posting. Normally, comments
will be posted within a few days of
being submitted. However, if large
volumes of comments are being
processed simultaneously, your
comment may not be viewable for up to
several weeks. Please keep the comment
tracking number that https://
www.regulations.gov provides after you
have successfully uploaded your
comment.
Submitting comments via email, hand
delivery/courier, or postal mail.
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Comments and documents submitted
via email, hand delivery/courier, or
postal mail also will be posted to https://
www.regulations.gov. If you do not want
your personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information in a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. With this
instruction followed, the cover letter
will not be publicly viewable as long as
it does not include any comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
submit via postal mail or hand delivery/
courier, please provide all items on a
CD, if feasible, in which case it is not
necessary to submit printed copies. No
faxes will be accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, that are written in English, and
that are free of any defects or viruses.
Documents should not contain special
characters or any form of encryption
and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
Pursuant to 10 CFR 1004.11, any person
submitting information that he or she
believes to be confidential and exempt
by law from public disclosure should
submit via email, postal mail, or hand
delivery/courier two well-marked
copies: one copy of the document
marked ‘‘confidential’’ including all the
information believed to be confidential,
and one copy of the document marked
‘‘non-confidential’’ with the information
believed to be confidential deleted.
Submit these documents via email or on
a CD, if feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
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C. Issues on Which DOE Seeks
Comment
Although DOE welcomes comments
on any aspect of this proposed
determination, DOE is particularly
interested in receiving comments and
views of interested parties concerning
the following issues:
(1) DOE requests comment on the ELs
under consideration for the equipment
classes, including the max-tech levels.
See section IV.C.4 and IV.C.6 of this
document.
(2) DOE requests comment on the
methodology and resulting MSPs
developed for all equipment classes. See
section IV.C.7 of this document.
(3) DOE welcomes any relevant data
and comments on the markups analysis
methodology. See section IV.D.3 of this
document.
(4) DOE welcomes any relevant data
and comments on the life-cycle cost and
payback period analysis methodology.
See section IV.F of this document.
(5) DOE welcomes any relevant data
and comments on the shipments
analysis methodology. See section IV.G
of this document.
(6) DOE requests comments on its
initial determination that energy
conservation standards should not be
adopted for MHLFs. See section V.D.4 of
this document.
VIII. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of this document of
proposed determination.
Signing Authority
This document of the Department of
Energy was signed on June 30, 2020, by
Daniel R Simmons, Assistant Secretary,
Office Energy Efficiency and Renewable
Energy, pursuant to delegated authority
from the Secretary of Energy. That
document with the original signature
and date is maintained by DOE. For
administrative purposes only, and in
compliance with requirements of the
Office of the Federal Register, the
undersigned DOE Federal Register
Liaison Officer has been authorized to
sign and submit the document in
electronic format for publication, as an
official document of the Department of
Energy. This administrative process in
no way alters the legal effect of this
document upon publication in the
Federal Register.
Signed in Washington, DC, on July 1, 2020.
Treena V. Garrett,
Federal Register Liaison Officer, U.S.
Department of Energy.
[FR Doc. 2020–14540 Filed 8–4–20; 8:45 am]
BILLING CODE 6450–01–P
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[Federal Register Volume 85, Number 151 (Wednesday, August 5, 2020)]
[Proposed Rules]
[Pages 47472-47506]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-14540]
[[Page 47471]]
Vol. 85
Wednesday,
No. 151
August 5, 2020
Part II
Department of Energy
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10 CFR Part 431
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Energy Conservation Program: Energy Conservation Standards for Metal
Halide Lamp Fixtures; Proposed Rule
Federal Register / Vol. 85, No. 151 / Wednesday, August 5, 2020 /
Proposed Rules
[[Page 47472]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2017-BT-STD-0016]
RIN 1904-AD89
Energy Conservation Program: Energy Conservation Standards for
Metal Halide Lamp Fixtures
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy (DOE).
ACTION: Notice of proposed determination and request for comment.
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
directs DOE to determine whether standards for metal halide lamp
fixtures (``MHLFs'') should be amended. In this notice of proposed
determination (``NOPD''), DOE has initially determined that the energy
conservation standards for metal halide lamp fixtures do not need to be
amended and also asks for comment on this proposed determination and
associated analyses and results.
DATES:
Meeting: DOE will hold a webinar on Thursday, August 27, 2020, from
10:00 a.m. to 3:00 p.m. See section VII, ``Public Participation,'' for
webinar registration information, participant instructions, and
information about the capabilities available to webinar participants.
If no participants register for the webinar than it will be cancelled.
DOE will hold a public meeting on this proposed determination if one is
requested by August 19, 2020.
Comments: DOE will accept comments, data, and information regarding
this NOPD no later than October 19, 2020.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at https://www.regulations.gov. Follow
the instructions for submitting comments. Alternatively, interested
persons may submit comments, identified by docket number EERE-2017-BT-
STD-0016, by any of the following methods:
1. Federal eRulemaking Portal: https://www.regulations.gov. Follow
the instructions for submitting comments.
2. Email: [email protected]. Include the docket number
EERE-2017-BT-STD-0016 in the subject line of the message.
3. Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
4. Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202)
287-1445. If possible, please submit all items on a CD, in which case
it is not necessary to include printed copies.
No telefacsimilies (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII of this document.
Docket: The docket, which includes Federal Register notices,
comments, and other supporting documents/materials, is available for
review at https://www.regulations.gov. All documents in the docket are
listed in the https://www.regulations.gov index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket web page can be found at https://www.regulations.gov/docket?D=EERE-2017-BT-STD-0016. The docket web page contains simple
instructions on how to access all documents, including public comments,
in the docket. See section VII, ``Public Participation,'' for further
information on how to submit comments through https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 287-1604. Email:
[email protected].
Ms. Kathryn McIntosh, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-2002. Email:
[email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Determination
II. Introduction
A. Authority and Background
1. Current Standards
2. History of Standards Rulemaking for MHLFs
III. General Discussion
A. Product/Equipment Classes and Scope of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared To Increase in Price
(LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Overall
B. Market and Technology Assessment
1. Scope of Coverage
2. Metric
3. Equipment Classes
a. Existing equipment classes
b. Summary
4. Technology Options
5. Screening Analysis
a. Screened-Out Technologies
b. Remaining Technologies
C. Engineering Analysis
1. Representative Equipment Classes
2. Baseline Ballasts
3. More-Efficient Ballasts
4. Efficiency Levels
5. Design Standard
6. Scaling to Other Equipment Classes
7. Manufacturer Selling Price
a. Fixtures
b. Ballasts
D. Markups Analysis
1. Distribution Channels
2. Estimation of Markups
3. Summary of Markups
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Replacement Costs
6. Equipment Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the No-New-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. National Energy Savings
2. Net Present Value Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
[[Page 47473]]
B. Economic Impacts on Individual Customers
1. Life-Cycle Cost and Payback Period
2. Rebuttable Presumption Payback
C. National Impact Analysis
1. Significance of Energy Savings
2. Net Present Value of Customer Costs and Benefits
D. Proposed Determination
1. Technological Feasibility
2. Significant Conservation of Energy
3. Economic Justification
4. Summary
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under Executive Orders 13771 and 13777
C. Review Under the Regulatory Flexibility Act
D. Review Under the National Environmental Policy Act
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. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Submission of Comments
C. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Determination
Title III, Part B \1\ of EPCA,\2\ established the Energy
Conservation Program for Consumer Products Other Than Automobiles. (42
U.S.C. 6291-6309) These products include metal halide lamp fixtures
(``MHLFs''), the subject of this notice of proposed determination
(``NOPD''). (42 U.S.C. 6292(a)(19))
---------------------------------------------------------------------------
\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 America's Water Infrastructure Act of 2018,
Public Law 115-270 (Oct. 23, 2018).
---------------------------------------------------------------------------
EPCA established initial standards for MHLFs. (42 U.S.C.
6295(hh)(1)(A)) EPCA directed the U.S. Department of Energy (``DOE'')
to conduct a review of the statutory standards to determine whether
they should be amended, and a subsequent review to determine if the
standards then in effect should be amended. (42 U.S.C. 6295(hh)(2) and
(3)) DOE conducted the first review of MHLF energy conservation
standards and published a final rule amending standards on February 10,
2014. 79 FR 7746.\3\ DOE is issuing this NOPD pursuant to the EPCA
requirement that DOE conduct a second review of MHLF energy
conservation standards. (42 U.S.C. 6295(hh)(3)(A))
---------------------------------------------------------------------------
\3\ DOE notes that because of the codification of the MHLF
provisions in 42 U.S.C. 6295, MHLF energy conservation standards and
the associated test procedures are subject to the requirements of
the consumer products provisions of Part B of Title III of EPCA.
However, because MHLFs are generally considered to be commercial
equipment, DOE established the requirements for MHLFs in 10 CFR part
431 (``Energy Efficiency Program for Certain Commercial and
Industrial Equipment'') for ease of reference. DOE notes that the
location of the provisions within the CFR does not affect either the
substance or applicable procedure for MHLFs. Based upon their
placement into 10 CFR part 431, MHLFs are referred to as
``equipment'' throughout this document, although covered by the
consumer product provisions of EPCA.
---------------------------------------------------------------------------
For this proposed determination, DOE analyzed MHLFs subject to
standards specified in 10 CFR 431.326(c). DOE first analyzed the
technological feasibility of more efficient MHLFs. For those MHLFs for
which DOE determined higher standards to be technologically feasible,
DOE estimated energy savings that could result from potential energy
conservation standards by conducting a national impacts analysis
(``NIA''). DOE evaluated whether higher standards would be cost
effective by conducting life-cycle cost (``LCC'') and payback period
(``PBP'') analyses, and estimated the net present value (``NPV'') of
the total costs and benefits experienced by consumers.
Based on the results of these analyses, summarized in section V of
this document, DOE has tentatively determined that current standards
for metal halide lamp fixtures do not need to be amended because more
stringent standards would not have significant energy savings and would
not be economically justified.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed determination, as well as some of the relevant
historical background related to the establishment of standards for
MHLFs.
A. Authority and Background
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
B of EPCA established the Energy Conservation Program for Consumer
Products Other Than Automobiles, which includes MHLFs that are the
subject of this proposed determination. (42 U.S.C. 6292(a)(19)) EPCA,
as amended by the Energy Independence and Security Act of 2007 (Pub. L.
110-140, EISA 2007), prescribed energy conservation standards for this
equipment. (42 U.S.C. 6295(hh)(1)) EPCA directed DOE to conduct two
rulemaking cycles to determine whether to amend these standards. (42
U.S.C. 6295(hh)(2)(A) and (3)(A)) DOE published a final rule amending
the standards on February 10, 2014 (``2014 MHLF final rule''). 79 FR
7746. Under 42 U.S.C. 6295(hh)(3)(A), the agency must conduct a second
review to determine whether current standards should be amended and
publish a final rule. This second MHLF standards rulemaking was
initiated through the publication of a request for information
(``RFI'') document in the Federal Register. 84 FR 31231 (``July 2019
RFI'')
Pursuant to EPCA, DOE's energy conservation program for covered
products, which as noted includes MHLFs, consists essentially of four
parts: (1) Testing, (2) labeling, (3) the establishment of Federal
energy conservation standards, and (4) certification and enforcement
procedures. Relevant provisions of the EPCA specifically include
definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293),
labeling provisions (42 U.S.C. 6294), energy conservation standards (42
U.S.C. 6295), and the authority to require information and reports from
manufacturers (42 U.S.C. 6296).
Federal energy efficiency requirements for covered products
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal
preemption in limited instances for particular State laws or
regulations, in accordance with the procedures and other provisions set
forth under EPCA. (See 42 U.S.C. 6297(d)).
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 each covered product, including
MHLFs. (42 U.S.C. 6295(o)(3)(A) and (r)) Manufacturers of covered
products must use the prescribed DOE test procedure as the basis for
certifying to DOE that their products comply with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use
these test procedures to determine whether the products comply with
standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) The DOE test
procedures for MHLFs appear at 10 CFR 431.324.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, which
[[Page 47474]]
include MHLFs. Any new or amended standard for a covered product must
be designed to achieve the maximum improvement in energy efficiency
that the Secretary of Energy determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A) and (3)(B))
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 products,
including MHLFs, if no test procedure has been established for the
product, or (2) if DOE determines by rule that the standard is not
technologically feasible or economically justified. (42 U.S.C.
6295(o)(3)(A)-(B)) In deciding whether a proposed 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 statutory factors:
(1) The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated
average life of the covered products in the type (or class) compared
to any increase in the price, initial charges, or maintenance
expenses for the covered products that are likely to result from the
standard;
(3) The total projected amount of energy (or as applicable,
water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the
covered products likely to result from 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
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))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing a product 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 consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing 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)) 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 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. (42 U.S.C.
6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
subcategories. DOE must specify a different standard level for a type
or class of product that has the same function or intended use, if DOE
determines that products within such group: (A) Consume a different
kind of energy from that consumed by other covered products within such
type (or class); or (B) have a capacity or other performance-related
feature which other products within such type (or class) do 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 products, DOE must
consider such factors as the utility to the consumer of the 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))
Pursuant to the amendments contained in the EISA 2007, any final
rule for new or amended energy conservation standards promulgated after
July 1, 2010, is required to address standby mode and off mode energy
use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard
for a covered products, including MHLFs, 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
a single standard, or, if that is not feasible, adopt a separate
standard for such energy use. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE's
current test procedure for MHLFs addresses standby mode energy use.
However, in the 2014 MHLF final rule, DOE stated that it had yet to
encounter an MHLF that used energy in standby mode and therefore
concluded that it could not establish a standard that incorporated
standby mode energy consumption. Regarding off mode, DOE concluded in
the same final rule that it is not possible for MHLFs to meet off mode
criteria because there is no condition in which the components of a
MHLF are connected to the main power source and are not already in a
mode accounted for in either active or standby mode. 79 FR 7757.
EPCA further provides that, not later than 6 years after the
issuance of any final rule establishing or amending a standard, DOE
must publish either a notice of determination that standards for the
product do not need to be amended, or a NOPR including new proposed
energy conservation standards (proceeding to a final rule, as
appropriate). (42 U.S.C. 6295(m)(1)). This NOPD also satisfies the 6-
year review provision of EPCA.
1. Current Standards
In the 2014 MHLF final rule, DOE prescribed the current energy
conservation standards for MHLFs manufactured on and after February 10,
2017. 79 FR 7746. These standards are set forth in DOE's regulations at
10 CFR 431.326 and are repeated in Table II.1.
Table II.1--Current Energy Conservation Standards for MHLFs
----------------------------------------------------------------------------------------------------------------
Designed to be operated with lamps of
the following rated lamp wattage Tested input voltage * Minimum standard equation * (%)
----------------------------------------------------------------------------------------------------------------
>=50W and <=100W........................ 480 V..................... (1/(1+1.24xP[supcaret](-0.351)))-0.0200.**
>=50W and <=100W........................ All others................ 1/(1+1.24xP[supcaret](-0.351)).
>100W and <150W [dagger]................ 480 V..................... (1/(1+1.24xP[supcaret](-0.351)))-0.0200.
>100W and <150W [dagger]................ All others................ 1/(1+1.24xP[supcaret](-0.351)).
>=150W [Dagger] and <=250W.............. 480 V..................... 0.880.
>=150W [Dagger] and <=250W.............. All others................ For >=150W and <=200W: 0.880. For >200W
and <=250W: 1/(1+0.876xP[supcaret](-
0.351)).
[[Page 47475]]
>250W and <=500W........................ 480 V..................... For >250W and <265W: 0.880. For >=265W and
<=500W: (1/(1+0.876xP[supcaret](-0.351)))-
0.0100.
>250W and <=500W........................ All others................ 1/(1+0.876xP[supcaret](-0.351)).
>500W and <=1,000W...................... 480 V..................... >500W and <=750W: 0.900. >750W and
<=1,000W: 0.000104xP + 0.822. For >500W
and <=1,000W: may not utilize a probe-
start ballast.
>500W and <=1,000W...................... All others................ For >500W and <=750W: 0.910. For >750W and
<=1,000W: 0.000104xP+0.832. For >500W and
<=1,000W: may not utilize a probe-start
ballast.
----------------------------------------------------------------------------------------------------------------
* Tested input voltage is specified in 10 CFR 431.324.
** P is defined as the rated wattage of the lamp the fixture is designed to operate.
[dagger] Includes 150 watt (W) fixtures specified in paragraph (b)(3) of this section, that are fixtures rated
only for 150W lamps; rated for use in wet locations, as specified by the National Fire Protection Association
(``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 Underwriters Laboratory (UL)
1029 (incorporated by reference, see Sec. 431.323).
[Dagger] Excludes 150W fixtures specified in paragraph (b)(3) of this section, that are fixtures rated only for
150W 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.
2. History of Standards Rulemaking for MHLFs
As described in section II.A, EPCA, as amended by Public Law 110-
140, EISA 2007, prescribed energy conservation standards for MHLFs. (42
U.S.C. 6295(hh)(1)) EPCA directed DOE to conduct two rulemaking cycles
to determine whether to amend these standards. (42 U.S.C.
6295(hh)(2)(A) and (3)(A)) DOE completed the first of these rulemaking
cycles in 2014 by adopting amended performance standards for MHLFs
manufactured on or after February 10, 2017. 79 FR 7746. The current
energy conservation standards are located in 10 CFR part 431. See 10
CFR 431.326 (detailing the applicable energy conservation standards for
different classes of MHLFs). The currently applicable DOE test
procedures for MHLFs appear at 10 CFR 431.324. Under 42 U.S.C.
6295(hh)(3)(A), the agency is instructed to conduct a second review of
its energy conservation standards for MHLFs and publish a final rule to
determine whether to amend those standards. DOE initiated the second
MHLF standards rulemaking process on July 1, 2019, by publishing the
July 2019 RFI.
DOE received five comments in response to the July 2019 RFI from
the interested parties listed in Table II.2.
Table II.2--July 2019 RFI Written Comments
----------------------------------------------------------------------------------------------------------------
Organization(s) Reference in this NOPD Organization type
----------------------------------------------------------------------------------------------------------------
National Electrical Manufacturers Association........ NEMA........................ Trade Association.
Edison Electric Institute............................ EEI......................... Utility Association.
The Institute for Policy Integrity at New York IPI......................... Think Tank.
University School of Law.
Pacific Gas and Electric, Southern California Edison, CA IOUs..................... Utilities.
San Diego Gas and Electric.
Signify North America Corporation.................... Signify..................... Manufacturer.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\4\
---------------------------------------------------------------------------
\4\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for metal halide lamp fixtures.
(Docket No. EERE-2017-BT-STD-0016, which is maintained at
www.regulations.gov/#!docketDetail;D=EERE-2017-BT-STD-0016). The
references are arranged as follows: (Commenter name, comment docket
ID number, page of that document).
---------------------------------------------------------------------------
III. General Discussion
DOE developed this proposal after considering oral and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
A. Product/Equipment Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered product into product classes by the type of energy used
or by capacity or other performance-related features that justify
differing standards. In making a determination whether a performance-
related feature justifies a different standard, DOE must consider such
factors as the utility of the feature to the consumer and other factors
DOE determines are appropriate. (42 U.S.C. 6295(q)) This proposed
determination covers metal halide lamp fixtures defined as light
fixtures for general lighting application designed to be operated with
a metal halide lamp and a ballast for a metal halide lamp. 42 U.S.C.
6291(64); 10 CFR 431.322. The scope of coverage is discussed in further
detail in section IV.B.1 of this document.
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered product must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. DOE will
finalize a test procedure establishing methodologies used to evaluate
proposed energy conservation standards at least 180 days prior to
publication of a NOPR proposing new or amended energy conservation
standards. Section 8(d) of appendix A to 10 CFR part 430 subpart C
(``Process Rule''). DOE's current energy conservation standards for
MHLFs are
[[Page 47476]]
expressed in terms of the efficiency of the ballast contained within
the fixture. (10 CFR 431.326)
DOE established an active mode and standby mode power test method
in a final rule published on March 9, 2010. 75 FR 10950. The current
test procedure for MHLFs appears in 10 CFR 431.324 and specifies the
ballast efficiency calculation as lamp output power divided by the
ballast input power.
DOE has since published an RFI to initiate a data collection
process to consider whether to amend DOE's test procedure for MHLFs. 83
FR 24680 (May 30, 2018).
C. Technological Feasibility
1. General
In each energy conservation 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 are 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.
Section 7(b)(1) of the Process Rule.
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, and service; (2) adverse
impacts on equipment utility or availability; (3) adverse impacts on
health or safety, and (4) unique-pathway proprietary technologies.
Section 7(b)(2)-(5) of the Process Rule. Section IV.B.5 of this
document discusses the results of the screening analysis for MHLFs,
particularly the designs DOE considered, those it screened out, and
those that are considered in this proposed determination. For further
details on the screening analysis for this proposed determination, see
chapter 4 of the NOPD technical support document (``TSD'').
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an 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.
The max-tech levels that DOE determined for this analysis are described
in section IV.C.4 and in chapter 5 of the NOPD TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to MHLFs purchased in the 30-year
period that begins in the year of compliance with the potential
standards (2025-2054).\5\ The savings are measured over the entire
lifetime of MHLFs purchased in the previous 30-year period. DOE
quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
no-new-standards case. The no-new-standards case represents a
projection of energy consumption that reflects how the market for a
product would likely evolve in the absence of amended energy
conservation standards.
---------------------------------------------------------------------------
\5\ Each TSL is composed of specific efficiency levels for each
product class. The TSLs considered for this NOPD are described in
section V.A. DOE conducted a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its NIA spreadsheet model to estimate national energy
savings (``NES'') from potential amended or new standards for MHLFs.
The NIA spreadsheet model (described in section IV.H of this document)
calculates energy savings in terms of site energy, which is the energy
directly consumed by equipment at the location where it is used. For
electricity, DOE reports national energy savings in terms of site
energy savings and source energy savings, the latter of which is the
savings in the energy that is used to generate and transmit the site
electricity. DOE also calculates NES in terms of full-fuel-cycle
(``FFC'') energy savings. The FFC metric includes the energy consumed
in extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and thus presents a more complete
picture of the impacts of energy conservation standards.\6\ DOE's
approach is based on the calculation of an FFC multiplier for each of
the energy types used by covered products or equipment. For more
information on FFC energy savings, see section IV.H.1 of this document.
---------------------------------------------------------------------------
\6\ The FFC metric is discussed in DOE's statement of policy and
notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as amended
at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE
must determine that such action would result in significant energy
savings. (42 U.S.C. 6295(o)(3)(B)) The term ``significant'' is not
defined in EPCA. DOE has established a significance threshold for
energy savings. Section 6(b) of the Process Rule. In evaluating the
significance of energy savings, DOE conducts a two-step approach that
considers both an absolute site energy savings threshold and a
threshold that is percent reduction in the covered energy use. Id. DOE
first evaluates the projected energy savings from a potential max-tech
standard over a 30-year period against a 0.3 quads of site energy
threshold. Section 6(b)(2) of the Process Rule. If the 0.3 quad-
threshold is not met, DOE then compares the max-tech savings to the
total energy usage of the covered equipment to calculate a percentage
reduction in energy usage. Section 6(b)(3) of the Process Rule. If this
comparison does not yield a reduction in site energy use of at least 10
percent over a 30-year period, DOE proposes that no significant energy
savings would likely result from setting new or amended standards.
Section 6(b)(3) of the Process Rule. The two-step approach allows DOE
to ascertain whether a potential standard satisfies EPCA's significant
energy savings requirements in 42 U.S.C. 6295(o)(3)(B) to ensure that
DOE avoids setting a standard that ``will not result in significant
conservation of energy.''
EPCA defines ``energy efficiency'' as the ratio of the useful
output of services from a product to the energy use of such product,
measured according to the Federal test procedures. (42 U.S.C. 6291(5),
emphasis added) EPCA defines ``energy use'' as the quantity of energy
directly consumed by a consumer product at point of use, as measured by
the Federal test procedures. (42 U.S.C. 6291(4)) Further, EPCA uses a
household energy consumption metric as a threshold for setting
standards for new covered products (42 U.S.C. 6295(l)(1)). Given this
context, DOE relies on site energy as the appropriate metric for
evaluating the significance of energy savings.
[[Page 47477]]
E. Economic Justification
1. Specific Criteria
As noted previously, 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)(I)-(VII)) The
following sections discuss how DOE has addressed each of those seven
factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on
manufacturers, DOE conducts a manufacturer impact analysis (``MIA'').
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. The
industry-wide impacts analyzed include (1) industry net present value,
which values the industry on the basis of expected future cash flows,
(2) cash flows by year, (3) changes in revenue and income, and (4)
other measures of impact, as appropriate. Second, DOE analyzes and
reports the impacts on different types of manufacturers, including
impacts on small manufacturers. Third, DOE considers the impact of
standards on domestic manufacturer employment and manufacturing
capacity, as well as the potential for standards to result in plant
closures and loss of capital investment. Finally, DOE takes into
account cumulative impacts of various DOE regulations and other
regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the
changes in the LCC and PBP associated with new or amended standards.
These measures are discussed further in the following section. For
consumers in the aggregate, DOE also calculates the national net
present value of the consumer costs and benefits expected to result
from particular standards. DOE also evaluates the impacts of potential
standards on identifiable subgroups of consumers that may be affected
disproportionately by a standard.
DOE has concluded amended standards for MHLFs would not result in
significant energy savings and, as discussed further in section V.D of
this document, would not be economically justified for the potential
standard levels evaluated based on the PBP analysis. Therefore, DOE did
not conduct an MIA analysis or LCC subgroup analysis for this NOPD.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a 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 a product (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the product. The LCC analysis requires a variety of inputs, such as
product prices, product energy consumption, energy prices, maintenance
and repair costs, product lifetime, and discount rates appropriate for
consumers. To account for uncertainty and variability in specific
inputs, such as product lifetime and discount rate, DOE uses a
distribution of values, with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of a more-efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered products in the first year of compliance with new
or amended standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section III.D, DOE uses the NIA spreadsheet models to
project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) The Secretary may
not prescribe an amended or new standard if the Secretary finds (and
publishes such finding) that interested persons have established by a
preponderance of the evidence that the standard is 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 similar
in the United States at the time of the Secretary's finding. (42 U.S.C.
6295(o)(4))
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 a proposed 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 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)(ii)) Because DOE is not proposing standards for
MHLFs, DOE did not transmit a copy of its proposed determination to the
Attorney General.
f. Need for National Energy Conservation
In evaluating the need for national energy conservation, 42 U.S.C.
6295(o)(2)(B)(i)(VI), DOE expects that energy savings from amended
standards would likely 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. Energy savings from
amended standards also would likely result in environmental benefits in
the form of reduced emissions of air pollutants and greenhouse gases
primarily associated with fossil-fuel based energy production. Because
DOE has tentatively concluded amended
[[Page 47478]]
standards for MHLFs would not be economically justified, DOE did not
conduct a utility impact analysis or emissions analysis for this NOPD.
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
EPCA creates a rebuttable presumption that an energy conservation
standard is economically justified if the additional cost to the
consumer of a product 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. 42
U.S.C. 6295(o)(2)(B)(iii) DOE's LCC and PBP analyses generate values
used to calculate the effects that proposed energy conservation
standards would have on the payback period for consumers. 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 consumers, 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 V.B.2 of this document.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
proposed determination with regard to MHLFs. Separate subsections
address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential amended or new
energy conservation standards. The national impacts analysis uses a
second spreadsheet set that provides shipments projections and
calculates national energy savings and net present value of total
consumer costs and savings expected to result from potential energy
conservation standards. These spreadsheet tools are available on the
DOE website for this proposed determination (see DOCKET section at the
beginning of this proposed determination).
A. Overall
DOE received several comments from stakeholders in response to the
July 2019 RFI stating that DOE should not amend standards for MHLFs.
NEMA stated that MHLF technology has reached its practical limits in
terms of performance. NEMA noted that further investment in efficiency
for MHLF products is no longer justified given substantial market
decline and the inability for relevant manufacturers and distributors
to recover investments in relatively minor efficiency gains. NEMA
pointed out that DOE has previously declined to amend standards for a
product when it was deemed that no new investments in higher efficiency
products is likely. (NEMA, No. 3 at pp. 2, 6)
NEMA also stated that a transition to light-emitting diode
(``LED'') products is largely responsible for the declining market for
MHLF products, and as a result, there is limited opportunity to
recapture investments in new designs through sales of MHLF products.
(NEMA, No. 3 at p. 2-3) NEMA noted that the decline of the MHLF market
means relevant efficiency regulations have reached their end-states.
(NEMA, No. 3 at p. 6) According to NEMA, the most likely outcome of
strengthened efficiency standards for MHLFs is accelerated obsolescence
of products unable to meet new standards and an accelerated decline of
a market already in decline. (NEMA, No. 3 at p. 6-7) NEMA asserted that
DOE does not need to further accelerate the decline of the MHLF market
by further strengthening MHLF efficiency requirements. (NEMA, No. 3 at
p. 9)
EEI and Signify both argue that the best course of action is for
DOE to issue a ``no new standard'' determination for MHLFs. EEI and
Signify identified the significant decline in the MHLF market as a
reason DOE should not consider standards for MHLFs. (EEI, No. 2 at p.
3, Signify, No. 6 at p. 1) EEI added that the market for lighting
products has outpaced the relevant regulatory framework and market
forces alone have pushed customers away from MHLF products, so there is
no need for further regulations. EEI commented that amending standards
for MHLFs could be an inefficient and ineffective expenditure of DOE's
resources. (EEI, No. 2 at p. 3).
As discussed in section II.A, DOE is required to conduct two
rulemaking cycles to determine whether to amend standards for MHLFs.
(42 U.S.C. 6295(hh)(2)(A) and (3)(A)) DOE completed the first
rulemaking cycle by publishing a final rule amending MHLF standards on
February 10, 2014. 79 FR 7746. This determination represents the second
rulemaking cycle for MHLFs. DOE discusses the methodology used to
analyze potential standards in section IV and the results of the
analysis in section V.
Commenting on the analyses conducted by DOE to evaluate standards
for MHLFs, IPI stated that DOE should (1) continue to monetize the full
climate benefits of greenhouse gas emissions reductions, using the best
estimates, which were derived by the Interagency Working Group; (2)
continue to use the global estimate of the social cost of greenhouse
gases; and (3) rely only on the best available science and economics,
and not on any ``interim'' estimates that do not include a range of
discount rates or global climate impacts. They stated that DOE should
factor these benefits into its choice of the maximum efficiency level
that is economically justified, consistent with its statutory
requirement to assess the national need to conserve energy. (IPI, No.
4, pp. 1-5)
In response, DOE notes that it has not conducted an analysis of
emissions impacts that may result from amended standards for MHLFs. As
discussed further in the document, DOE has tentatively concluded that
imposition of a standard at any of the TSLs considered is not
economically justified because the operating costs of the covered
product are insufficient to recover the upfront cost. DOE continues to
be of the view that failure to meet one aspect of the seven factors in
EPCA's consideration of economic justification means that a revised
standard is not economically justified without considering all of the
other factors. For example, on October 17, 2016, DOE published in the
Federal Register a final determination that more stringent energy
conservation standards for direct heating equipment (``DHE'') would not
be economically justified, and based this determination solely on
manufacturer impacts, the first EPCA factor that DOE is required to
evaluate in 42 U.S.C. 6295(o)(2)(B)(i)(I). 81 FR 71325. Specifically,
due to the lack of advancement in the DHE industry in terms of product
offerings, available technology options and associated costs, and
declining shipment volumes, DOE concluded that amending the DHE energy
conservation standards would impose a substantial burden on
manufacturers of DHE, particularly to small manufacturers. Id. at 81 FR
71328. Notably, DOE received no stakeholder
[[Page 47479]]
comments in opposition to its conclusions regarding economic
justification in the DHE standards rulemaking.
In this NOPD, DOE remains consistent with its approach in the DHE
rule, and finds no economic justification for amending standards based
on one of the seven factors in 42 U.S.C. 6295(o)(2)(B)(i), namely, that
the energy savings in operating costs of the covered product are
insufficient to recover the upfront cost.
B. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the equipment
concerned, including the purpose of the equipment, the industry
structure, manufacturers, market characteristics, and technologies used
in the equipment. This activity includes both quantitative and
qualitative assessments, based primarily on publicly-available
information. The key findings of DOE's market assessment are summarized
in the following sections. See chapter 3 of the NOPD TSD for further
discussion of the market and technology assessment.
1. Scope of Coverage
MHLF is defined as a light fixture for general lighting application
designed to be operated with a metal halide lamp and a ballast for a
metal halide lamp. 42 U.S.C. 6291(64); 10 CFR 431.322. Any equipment
meeting the definition of MHLF is included in DOE's scope of coverage,
though all equipment within the scope of coverage may not be subject to
standards.
In the July 2019 RFI, DOE requested comments on whether definitions
related to MHLFs in 10 CFR 431.322 require any revisions or whether
additional definitions are necessary for DOE to clarify or otherwise
implement its regulatory requirements related to MHLFs. 84 FR 31234.
NEMA commented that the MHLF technology is mature and noted that no
relevant definitions have emerged since the last rulemaking. (NEMA, No.
3 at p. 4-5) DOE agrees with NEMA and is not proposing to add any new
definitions or update any existing definitions for MHLFs in this
determination.
In response to the July 2019 RFI, CA IOUs argued that DOE should
consider adopting a technology-agnostic approach that groups together
all products used for the same application. CA IOUs pointed out the
transition away from MHLF products and toward LED products and
suggested that DOE establish a class of products based on lumen output
that would include all technologies that serve the same application.
(CA IOUs, No. 5 at p. 1-2)
DOE agrees with CA IOUs that a technology-agnostic approach that
groups together all products used for the same application could
potentially have benefits with regards to energy savings. However, DOE
notes that this proposed determination addresses only metal halide lamp
fixtures defined as light fixtures for general lighting application
designed to be operated with a metal halide lamp and a ballast for a
metal halide lamp. 42 U.S.C. 6291(64); 10 CFR 431.322. DOE is not
authorized to consider any product not meeting this definition, such as
LED fixtures, as a part of this determination.
CA IOUs also urged DOE to consider agricultural applications when
developing an updated technology-agnostic standard for MHLFs. CA IOUs
noted that in agricultural applications, there are limitations with LED
technology for certain indoor growing operations that demand the use of
high-intensity discharge (``HID'') products, and DOE should ensure that
any new standards will not eliminate these HID products from the market
(metal halide products are a type of HID product). (CA IOUs, No. 5 at
p. 1-2)
DOE reviewed commercially available MHLFs and found about 50
products marketed for use in agricultural applications (compared to
3,521 products in DOE's compliance certification database). The
agricultural MHLFs range in wattage from 175 watts (``W'') to 1000 W.
DOE did not find any performance characteristics or features of the
agricultural MHLFs that would prevent them from being used in general
lighting applications (i.e., providing an interior or exterior area
with overall illumination). DOE reviewed available agricultural MHLFs
in light of the efficiency levels discussed in section IV.C.4 and
determined that agricultural MHLFs already meet or could meet the
efficiency levels considered in this determination.
EISA 2007 established energy conservation standards for MHLFs with
ballasts designed to operate lamps with rated wattages between 150 W
and 500 W and excluded three types of fixtures within that wattage
range from energy conservation standards: (1) MHLFs with regulated-lag
ballasts; (2) MHLFs that use electronic ballasts and operate at 480
volts; and (3) MHLFs that are rated only for 150 watt lamps, are rated
for use in wet locations as specified by the National Fire Protection
Association (``NFPA'') in NFPA 70, ``National Electrical Code 2002
Edition,'' \7\ and contain a ballast that is rated to operate at
ambient air temperatures above 50 degrees Celsius (``[deg]C'') as
specified by Underwriters Laboratory (``UL'') in UL 1029, ``Standard
for Safety High-Intensity-Discharge Lamp Ballasts.'' (42 U.S.C.
6295(hh)(1))
---------------------------------------------------------------------------
\7\ DOE notes that although the exclusion in 42 U.S.C.
6295(hh)(1)(B)(iii)(II) identifies those fixtures that are rated for
use in wet locations as specified by the National Electrical Code
2002 section 410.4(A), the NFPA is responsible for authoring the
National Electrical Code, which is identified as NFPA 70.
Accordingly, DOE's use of NFPA 70 under the MHLF-related provision
in 10 CFR 431.326(b)(3)(iii) is identical to the statutory exclusion
set out by Congress.
---------------------------------------------------------------------------
In the 2014 MHLF final rule, DOE promulgated standards for the
group of MHLFs with ballasts designed to operate lamps rated 50 W-150 W
and 501 W-1,000 W. DOE also promulgated standards for one type of
previously excluded fixture: A 150 W MHLF rated for use in wet
locations and containing a ballast that is rated to operate at ambient
air temperatures greater than 50 [deg]C--i.e., those fixtures that fall
under 42 U.S.C. 6295(hh)(1)(B)(iii). DOE continued to exclude from
standards MHLFs with regulated-lag ballasts and 480 volt (``V'')
electronic ballasts. In addition, due to a lack of applicable test
method for high-frequency electronic (``HFE'') ballasts, in the 2014
MHLF final rule, DOE did not establish standards for MHLFs with HFE
ballasts. 79 FR 7754-7756 (February 10, 2014).
In this analysis, based on a review of manufacturer catalogs DOE
again found a range of efficiencies for MHLFs with ballasts designed to
operate lamps with rated wattages >1000 W to <=2000 W. Hence, in this
determination, DOE assesses potential standards for this equipment.
In summary, this proposed determination evaluates MHLFs with
ballasts designed to operate lamps with rated wattages >=50 W to <=2000
W with the exception of MHLFs with regulated-lag ballasts and MHLFs
that use electronic ballasts that operate at 480 volts.
In response to the July 2019 RFI, EEI suggested that DOE adopt a
more accurate description of the regulatory category for which it is
issuing standards for MHLFs. EEI noted that DOE is specifically
reviewing standards for metal halide ballasts, and not for metal halide
fixtures. (EEI, No. 2 at p. 2) EEI also noted that the focus on metal
halide ballasts and not fixtures during the 2014 MHLF rulemaking
produced arguably flawed conclusions regarding the payback period for
the MHLF efficiency standard adopted. (EEI, No. 2 at p. 2) In a comment
on the previous
[[Page 47480]]
rulemaking, EEI stated that it is unclear whether manufacturers will
devote resources to make new ballasts to meet the standard and keep
producing replacement ballasts. EEI noted that replacement costs
increase substantially if the entire fixture needs to be replaced after
ballast failure rather than just the ballast. (EEI, No. 53 at pp. 3-4)
\8\
---------------------------------------------------------------------------
\8\ The full written comment in response to the Notice of
Proposed Rulemaking for MHLFs published at 78 FR 51164 (August 20,
2013) can be found in Docket No. EERE-2009-BT-STD-0018.
---------------------------------------------------------------------------
DOE prescribes efficiency standards for MHLFs but, as noted by EEI,
standards for MHLFs are applicable to the ballast contained within the
MHLF and not replacement metal halide ballasts sold separately. In this
proposed determination DOE only has the authority to evaluate amended
standards for MHLFs, not metal halide ballasts sold outside of MHLFs.
In section IV.B.2, DOE considers other metrics for MHLFs that pertain
to the performance of the fixture rather than the ballast contained
within the fixture. In section IV.F.6, DOE discusses the lifetime of
ballasts and fixtures and in section IV.F.9, DOE discusses the payback
period analysis.
2. Metric
Current energy conservation standards for MHLFs are based on
minimum allowable ballast efficiencies. The ballast efficiency for the
fixture is calculated as the measured ballast output power divided by
the measured ballast input power. The measurement of ballast output
power (approximated in the test procedure as lamp output power) and
ballast input power and the calculation of ballast efficiency for MHLFs
is included in the current test procedure at 10 CFR 431.324.
In response to the July 2019 RFI, CA IOUs recommended that DOE
adopt a new standard for MHLFs based on a lumens-per-watt metric to
align with standards for other lighting products. In addition,
regarding agricultural MHLFs, CA IOUs suggested that DOE evaluate the
metrics developed by the American National Standards Institute
(``ANSI'') and the American Society of Agricultural and Biological
Engineers for evaluating performance related to agricultural
operations. (CA IOUs, No. 5 at p. 1-2) CA IOUs noted that the current
ballast efficiency metric for MHLFs does not promote more efficient
fixture designs, more efficient lamps, or higher efficiency
technologies such as LEDs. CA IOUs also pointed out that EISA 2007
gives DOE permission to expand the scope of regulation for MHLFs and to
propose not only performance requirements, but also design
requirements. CA IOUs noted that a fixture-level metric could save up
to 50 percent more energy than the current approach that only considers
ballast efficiency and provide a standardized metric to assess and
compare the performance of a product. (CA IOUs, No. 5 at p. 2-3)
DOE agrees that a fixture metric effectively accounts for the
efficiency of a fixture in different applications, provides more
technological flexibility, and has the potential to yield overall
higher performance and energy savings. DOE notes that metrics for
agricultural MHLFs focus on performance characteristics that affect the
photosynthesis of plants and therefore are not appropriate for MHLFs
used in general lighting applications. Instead, as part of this
determination, DOE evaluated several alternative fixture performance
metrics, including lumens per watt (``lm/W''), luminaire efficacy
rating (``LER''), target efficacy rating (``TER''), and fitted target
efficacy (``FTE'').
A lumens-per-watt metric reflects the light produced and energy
consumed for a lamp-and-ballast pairing. An increase in lm/W could
reflect the use of a more efficacious lamp, a more efficient ballast,
or both. Although DOE's current test procedure does not measure lm/W,
ANSI C82.6-2015 \9\ and IES LM-51-2013 \10\ provide a test method that
could be used to determine lm/W for lamp-and-ballast pairings. The
inclusion of lumen output in the metric necessitates photometric
measurements as part of the test procedure whereas the measurement of
ballast efficiency requires only electrical measurements. Photometric
measurements are more expensive to conduct than electrical measurements
because of the equipment and time required. While a lumens-per-watt
metric is based on more than just ballast performance, lm/W still does
not account for directionality of a fixture (i.e., the fixture's
effectiveness in delivering light to a specific target). Because the
covered product is a fixture, DOE evaluated metrics that captured the
performance of the lamp, ballast, and optics of a fixture.
---------------------------------------------------------------------------
\9\ American National Standards Institute. American National
Standard for lamp ballasts--Ballasts for High-Intensity Discharge
Lamps--Methods of Measurement. Approved September 17, 2015 available
at www.ansi.org.
\10\ Illuminating Engineering Society. IES Approved Method--The
Electrical and Photometric Measurement of High-Intensity Discharge
Lamps. Approved January 7, 2013 available at https://webstore.iec.ch/home.
---------------------------------------------------------------------------
DOE next considered the LER metric, developed by NEMA in 1998. LER
is expressed in units of lm/W but in addition to the lamp-and-ballast
pairing described in the previous paragraph, LER includes a factor that
accounts for luminaire efficiency, which is the ratio of the lumens
emitted from a luminaire to the lumens emitted by the lamps alone. LER
is used to establish minimum requirements for the Federal Energy
Management Program (``FEMP'') for industrial luminaires.\11\ NEMA has
developed a test procedure for LER in NEMA LE 5B-1998.\12\ The
inclusion of lumen output and luminaire efficiency in the metric
necessitates photometric measurements. As stated previously,
photometric measurements are more expensive to conduct than electrical
measurements. NEMA has since developed a TER metric which is similar to
LER, but better accounts for directionality. DOE determined that TER
would be a more applicable alternative metric to measure the
performance of MHLFs.
---------------------------------------------------------------------------
\11\ FEMP provides guidance for purchasing Energy-Efficient
Industrial Luminaires (High/Low Bay) with specifications in LER
available here: https://www.energy.gov/eere/femp/purchasing-energy-efficient-industrial-luminaires-highlow-bay.
\12\ National Electrical Manufacturers Association. LE 5B--
Procedure for Determining Luminaire Efficacy Ratings for High-
Intensity Discharge Industrial Luminaires. Published January 1998
available at www.nema.org.
---------------------------------------------------------------------------
The TER metric was developed by NEMA's luminaire division to
succeed the LER rating. TER calculates fixture efficacy by multiplying
the lamp lumens by the coefficient of utilization (``CU''), which
factors in the percentage of rated lumens reaching a specific target
(that varies based on the type of fixture). The inclusion of lumen
output and CU in the metric necessitates photometric measurements,
which are more expensive to conduct than electrical measurements. NEMA
developed the NEMA LE-6-2014 standard \13\ to provide a test procedure
for determining the TER of commercial, industrial, and residential
luminaires. TER has 22 different types of luminaire classifications,
each with a different CU. Despite the variety of luminaire
classifications available, TER explicitly excludes fixtures intended to
be aimed, accent luminaires, rough or hazardous use luminaires, and
emergency lighting. In the 2014 MHLF final rule, DOE considered the TER
metric but ultimately chose not to adopt it out of concern that certain
fixtures could fall within multiple luminaire classifications due to
their designs. DOE
[[Page 47481]]
also determined that the exclusion of certain fixture types such as
fixtures designed to be aimed does not allow all MHLFs to be measured
using TER. 79 FR 7757. DOE has not found any new information since the
2014 MHLF final rule regarding the TER metric. Therefore, DOE considers
these reasons to still be valid and tentatively concludes that TER is
not a suitable metric for measuring the performance of MHLFs.
---------------------------------------------------------------------------
\13\ National Electrical Manufacturers Association. LE 6--
Procedure for Determining Target Efficacy Ratings for Commercial,
Industrial, and Residential Luminaires. Published June 10, 2015
available at www.nema.org.
---------------------------------------------------------------------------
The FTE metric was developed by DOE to quantify outdoor pole-
mounted fixture performance for ENERGY STAR qualification purposes.\14\
In the FTE approach, fixture performance is measured by the amount of
light hitting a specified target. The target is defined as the
rectangle enclosing the uniform ``pool'' of light produced by the
unique intensity distribution of each luminaire. FTE is calculated by
multiplying the luminous flux landing in this pool by the percent
coverage of the rectangular target, and then dividing by input power to
the fixture. The inclusion of lumen output in the metric necessitates
photometric measurements. As stated previously, photometric
measurements are more expensive to conduct than electrical
measurements. In the 2014 MHLF final rule, DOE considered the FTE
metric but ultimately chose not to adopt it because FTE is calculated
using a rectangular area. 79 FR 7757. Therefore, fixtures designed to
light non-rectangular areas, produce a large amount of unlighted area
within the rectangle, or produce specific light patterns that light
both a horizontal plane and a vertical plane, or even above the fixture
would be at a disadvantage. DOE continues to find this rationale to be
valid today. In addition, currently, there is no industry standard for
determining FTE. For these reasons, DOE determined that FTE is not
suitable for measuring the performance of MHLFs.
---------------------------------------------------------------------------
\14\ Overview of FTE metric available at: https://www.illinoislighting.org/resources/FTEoverview01Jul09.pdf.
---------------------------------------------------------------------------
In summary, DOE reviewed several alternative metrics to ballast
efficiency in this proposed determination. Changing metrics would
impose a significant burden on manufacturers. A change in metric would
require retesting all MHLFs. While industry test procedures exist for
many of the metrics, an industry-accepted test procedure does not exist
for the FTE metric. Further, all metrics would require photometric
testing in addition to the electrical measurements currently required.
Photometric measurements are more expensive to conduct than electrical
measurements. While some fixture manufacturers provide photometric
data, the information is not available for all fixtures, all lamp-and-
ballast pairings within fixtures, and all performance characteristics
required to calculate the metrics described in this section. For
example, the CU needed to calculate the TER metric is not available
publicly. Finally, because the metrics account for the performance of
both the lamp and ballast components of the fixture, adopting one of
the metrics described in this section would require manufacturers to
ship fixtures with lamps in addition to ballasts. Therefore, for the
reasons described in this paragraph, DOE has tentatively concluded to
maintain the current ballast efficiency metric for MHLFs.
In addition to a metric that represents fixture-level performance,
CA IOUs stated that DOE should consider the benefits of fixtures with
good lumen maintenance because this will enable lighting designers
avoid over-lighting spaces in anticipation of lumen depreciation. (CA
IOUs, No. 5 at p. 3) DOE notes that lumen maintenance is the ratio of
lumen output at a certain period in time during the life of a lamp to
the initial lumen output. Because lumen maintenance requires conducting
photometric testing, and because the testing must be conducted more
than once and with a potentially significant period of time between
tests, DOE tentatively concludes that lumen maintenance represents a
significant test burden for manufacturers. For this reason, DOE did not
consider adopting a metric based on lumen maintenance in this
determination.
3. Equipment Classes
When evaluating and establishing energy conservation standards, DOE
may divide covered products into product classes by the type of energy
used, or by capacity or other performance-related features that justify
a different standard. (42 U.S.C. 6295(q)) In making a determination
whether capacity or another performance-related feature justifies a
different standard, DOE must consider such factors as the utility of
the feature to the consumer and other factors DOE deems appropriate.
(Id.)
In describing which MHLFs are included in current equipment
classes, DOE incorporates by reference the 2002 version of NFPA 70 and
the 2007 version of UL 1029 in DOE's regulations. NFPA 70 is a national
safety standard for electrical design, installation, and inspection,
and is also known as the 2002 National Electrical Code. UL 1029 is a
safety standard specific to HID lamp ballasts; a metal halide lamp
ballast is a type of HID lamp ballast. Both NFPA 70 and UL 1029 are
used to describe the applicable equipment class for MHLFs that EISA
2007 excluded from the statutory standards enacted by Congress but that
were later included as part of the 2014 MHLF final rule. In the July
2019 RFI, DOE found that a 2017 version of NFPA 70 (NFPA 70-2017)
``NFPA 70 National Electrical Code 2017 Edition'' \15\ and a 2014
version of UL 1029 (UL 1029-2014) ``Standard for Safety High-Intensity-
Discharge Lamp Ballasts'' \16\ are now available.
---------------------------------------------------------------------------
\15\ Approved August 24, 2016.
\16\ Approved December 6, 2013.
---------------------------------------------------------------------------
In response to the July 2019 RFI, NEMA commented that updating the
industry standards incorporated by reference in DOE's regulations, NFPA
70 and UL 1029, to the newer versions, NFPA 70-2017 and UL 1029-2014,
is unlikely to have any impact on MHLFs included in each equipment
class. However, NEMA pointed out that any updates could impose
financial and administrative burdens on manufacturers, especially given
the general market decline of MHLF technology. (NEMA, No. 3 at p. 3-4)
DOE agrees with NEMA that there is unlikely to be any impact on
MHLFs included in each equipment class. Consequentially, DOE has not
been able to identify any additional financial or administrative burden
as testing requirements and equipment classes will remain unaffected.
However, as discussed in section V.D, because DOE is not proposing to
amend standards for MHLFs, DOE is not proposing to incorporate by
reference the updated industry standards NFPA 70-2017 and UL 1029-2014
in this determination.
In this analysis, DOE reviewed metal halide lamp fixtures and the
ballasts contained within them to identify performance-related features
that could potentially justify a separate equipment class. In the
following sections, DOE discusses the equipment classes considered in
this analysis.
a. Existing Equipment Classes
The current equipment classes are based on input voltage, rated
lamp wattage, and designation for indoor versus outdoor application.
NEMA commented in response to the July 2019 RFI that the current
equipment classes for MHLFs remain viable and do not need to be
changed. NEMA also noted that there are no new products that will
benefit from an additional equipment class. (NEMA, No. 3 at p. 3; NEMA,
No. 3 at p. 5)
[[Page 47482]]
Regarding 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 in the 2014 MHLF final rule that the input voltage at which
a MHLF is capable of operating represents a performance-related feature
that affects consumer utility as certain applications demand specific
input voltages. 79 FR 7762. In the 2014 MHLF final rule, DOE's ballast
testing did not indicate a prevailing relationship between discrete
input voltages and ballast efficiencies (e.g., higher voltages are not
always more efficient), with one exception. DOE found that ballasts
tested at 480 V were less efficient on average than ballasts tested at
120 V or 277 V. 79 FR 7781. NEMA stated that it remains appropriate to
include separate classes for 480 V products given the differences in
how those products perform in testing. (NEMA, No. 3 at p. 6) 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, DOE maintains separate
equipment classes for ballasts tested at 480 V in this determination.
See chapter 3 of the NOPD TSD for further details.
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. Medium-wattage (150 W-500 W)
lamps are commonly used in warehouse, street, and 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 represents consumer utility. The wattage operated
by a ballast is correlated with the ballast efficiency; ballast
efficiency generally increases as lamp wattage increases. Therefore,
DOE maintains separation of equipment classes by wattage. See chapter 3
of the NOPD TSD for further details.
DOE determined in the 2014 MHLF final rule that indoor and outdoor
MHLFs are subject to separate cost-efficiency relationships at
electronic ballast levels. 79 FR 7763-7764. First, as outdoor
applications can be subject to large voltage transients, MHLFs in such
applications require 10 kV voltage transient protection. Magnetic metal
halide ballasts are typically resistant to voltage variations of this
magnitude, while electronic metal halide ballasts are generally not as
resilient. Therefore, in order to address large voltage transients,
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. Second, DOE noted that indoor fixtures
can require the inclusion of a 120 V auxiliary tap. 79 FR 7763. This
output is used to operate emergency lighting after a temporary loss of
power while the metal halide 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, however, 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 IV.C.7 of this NOPD). As these incremental costs
could affect the cost-effectiveness of fixtures for indoor versus
outdoor applications, DOE maintains separate equipment classes for
indoor and outdoor fixtures. See chapter 3 of the NOPD TSD for further
details.
b. Summary
In summary, for the purpose of this proposed determination DOE
considered equipment classes using three class-setting factors: Input
voltage, rated lamp wattage, and fixture application. DOE presents the
resulting equipment classes in Table IV.1.
Table IV.1--Equipment Classes
------------------------------------------------------------------------
Designed to be operated with
lamps of the following rated Indoor/outdoor Input voltage type
lamp wattage [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.
[[Page 47483]]
>1000 W and <=2000 W......... Outdoor........ All others.
------------------------------------------------------------------------
* Includes 150 W MHLFs initially 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 initially 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] 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.
4. Technology Options
In the technology assessment, DOE identifies technology options
that would be expected to improve the efficiency of MHLFs, as measured
by the DOE test procedure. The energy conservation standard
requirements and DOE test procedure for MHLFs are based on the
efficiency of the metal halide ballast contained within the fixture.
Hence DOE identified technology options that would improve the
efficiency of metal halide ballasts. To develop a list of technology
options, DOE reviewed manufacturer catalogs, recent trade publications
and technical journals, and consulted with technical experts.
In response to the July 2019 RFI, NEMA commented that there are no
new technology options for MHLFs given the maturity of MHLF technology.
NEMA added that technology options such as ``increased stack height''
and ``increased conductor cross sections'' lead to an increase in the
size of the ballast and have been implemented in accordance with 2014
MHLF final rule to the limit of their practicality. (NEMA, No. 3 at p.
4)
DOE's review of technology options for this determination indicates
that the technology options identified in the 2014 MHLF final rule
remain valid with certain clarifications and additional detail.
Specifically, DOE is revising ``increased stack height'' to be
``improved steel laminations.'' As described for the 2014 MHLF final
rule, increased stack height is adding steel laminations to increase
the core cross-section and thereby lower the flux density and
losses.\17\ Hence the mechanism for efficiency improvement is the
addition of steel laminations. The 2014 MHLF final rule also noted that
use of thinner laminations allows for maintaining the stack height and
thereby ballast footprint.\18\ In addition thinner laminations and well
insulated will reduce eddy current losses.\19\ To more appropriately
reflect the technology in this document, DOE refers to this option as
``improved steel laminations'' and describes it as adding steel
laminations to lower core losses by using thin and insulated
laminations.
---------------------------------------------------------------------------
\17\ See chapter 3 of 2014 MHLF final rule TSD, available at
https://www.regulations.gov/docket?D=EERE-2009-BT-STD-0018.
\18\ See chapter 3 of 2014 MHLF final rule TSD, available at
https://www.regulations.gov/docket?D=EERE-2009-BT-STD-0018.
\19\ AK Steel, Selection of Electrical Steels for Magnetic
Cores.
---------------------------------------------------------------------------
In the 2014 MHLF final rule ``increased conductor cross section''
was described as reducing winding losses through use of larger wire
gauges, multiple strands of wire operating in parallel as well use of
litz wire for electronic ballasts.\20\ In this analysis, DOE notes that
improvements in windings can also be achieved by using multiple smaller
coils to increase the number of turns and thereby increase the induced
voltage. Additionally, optimizing the shape of the wires by wrapping
them close together makes transfer of power through the core more
efficient. Hence, to more appropriately reflect the technology, in this
document DOE refers to this option as ``improved windings'' and
describes it as use of optimized-gauge copper wire; multiple, smaller
coils; shape-optimized coils to reduce winding losses for magnetic and
electronic ballasts; and in addition, for electronic ballasts, the use
of litz wire.
---------------------------------------------------------------------------
\20\ See chapter 3 of 2014 MHLF final rule TSD.
---------------------------------------------------------------------------
NEMA commented that technology options such as improved core steel,
and copper winding have been implemented in accordance with the 2014
MHLF final rule and reached the limit of their practicality. (NEMA, No.
3 at p. 4) In this determination, DOE found magnetic ballasts with
varying levels of efficiency in its compliance certification database.
Therefore, DOE has tentatively determined that technology options, such
as a higher grade of steel could still be used to improve the
efficiency of magnetic ballasts. DOE's research has not indicated any
technological issues with utilizing higher-grade steel in magnetic
ballasts. In addition, based on teardowns conducted in 2019, DOE
determined that magnetic ballast manufacturers still utilize aluminum
wiring in their ballasts. DOE determined that incorporating copper
wiring in all magnetic ballasts can still be considered a technology
option to improve the efficiency of magnetic ballasts. DOE has
tentatively determined that it will continue to consider improved core
steel and copper wiring as technology options to improve the efficiency
of magnetic ballasts.
NEMA noted that the use of electronic ballasts in new metal halide
fixtures has declined significantly and at the same pace as magnetic
ballasts and provided data to illustrate this. (NEMA, No. 3 at p. 4)
DOE agrees that there has been a decline in the use of metal halide
technology as whole affecting both electronic and magnetic metal halide
ballasts. However, DOE determined that electronic ballast technology
remains a viable technology option to improve the efficiency of MHLFs
with magnetic ballasts, therefore, DOE considered electronic ballasts
as a technology option in its analysis.
DOE is removing the technology option of laminated grain-oriented
silicon steel and amorphous steel for electronic ballasts. In the
context of this determination, DOE has tentatively determined that
using laminated sheets of steel (silicon or amorphous) to create the
core of the inductor may not minimize losses in ballasts that operate
at high frequencies.\21\ Because electronic ballasts operate at high
frequencies, DOE is not considering improved steel laminations or
amorphous steel laminations as technology options for improving the
efficiency of these ballasts.
---------------------------------------------------------------------------
\21\ DOE came to the same conclusion for fluorescent lamp
ballasts. See notice of proposed determination for fluorescent lamp
ballasts at 84 FR 56540, 56552 (October 22, 2019); available at
https://www.regulations.gov/document?D=EERE-2015-BT-STD-0006-0019.
---------------------------------------------------------------------------
[[Page 47484]]
A complete list of technology options DOE considered for this
analysis appears in Table IV.2.
Table IV.2--Technology 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.
Improved Steel Laminations................................... Add steel laminations
to lower core losses
by using thin and
insulated
laminations.
Improved Windings............................................ Use of optimized-
gauge copper wire;
multiple, smaller
coils; shape-
optimized coils to
reduce winding
losses.
Electronic Ballast........................................... Replace magnetic
ballasts with
electronic ballasts.
Amorphous Steel.............................................. Create the core of
the inductor from
laminated sheets of
amorphous steel
insulated from each
other.
----------------------------------------------------------------------------------------------------------------
Electronic...................... Improved Components.... Magnetics.............. Improved Windings: Use of
optimized-gauge copper
wire; multiple, smaller
coils; shape-optimized
coils; litz wire to reduce
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 Design Integrated Circuits.... Substitute discrete
components with an
integrated circuit.
----------------------------------------------------------------------------------------------------------------
5. Screening Analysis
DOE uses the following five screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking:
(1) Technological feasibility. Technologies that are not
incorporated in commercial products or in working prototypes will not
be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production and reliable installation and servicing
of a technology in commercial products could not be achieved on the
scale necessary to serve the relevant market at the time of the
projected compliance date of the standard, then that technology will
not be considered further.
(3) Impacts on product utility or product availability. If it is
determined that a technology would have significant adverse impact on
the utility of the product to significant subgroups of consumers or
would result in the unavailability of any covered product type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as products
generally available in the United States at the time, it will not be
considered further.
(4) Adverse impacts on health or safety. If it is determined that a
technology would have significant adverse impacts on health or safety,
it will not be considered further.
(5) Unique-Pathway Proprietary Technologies. If a design option
utilizes proprietary technology that represents a unique pathway to
achieving a given efficiency level, that technology will not be
considered further.
Sections 6(c)(3) and 7(b) of the Process Rule.
In sum, if DOE determines that a technology, or a combination of
technologies, fails to meet one or more of the listed five criteria, it
will be excluded from further consideration in the engineering
analysis. DOE only considers potential efficiency levels achieved
through the use of proprietary designs in the engineering analysis if
they are not part of a unique pathway to achieve that efficiency level
(i.e., if there are other non-proprietary technologies capable of
achieving the same efficiency level).
The subsequent sections include comments from interested parties
pertinent to the screening criteria and whether DOE determined that a
technology option should be excluded (``screened out'') based on the
screening criteria.
a. Screened-Out Technologies
For magnetic ballasts, DOE is screening out the technology option
of using laminated sheets of amorphous steel. Due to the random
arrangement of molecules allowing for an easier switch from
magnetization to de-magnetization of the material, amorphous steel
results in lower core losses than the commonly-used silicon steel. In
the 2014 MHLF final rule, DOE screened out amorphous steel technology
because it failed to pass the ``practicable to manufacture, install,
and service'' criterion. Additionally, DOE determined that 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. 79 FR 7766.
In response to the July 2019 RFI, NEMA commented that amorphous
steel technology was screened out in the 2014 MHLF final rule because
it increases the size and weight of metal halide ballasts, which
remains true today. NEMA added that the current cost of amorphous steel
ribbon that is used as a raw material for making magnetic cores is 20
to 30 times higher than the cost of other higher-grade steel used in
magnetic ballasts. (NEMA, No. 3 at p. 4)
In its assessment for this analysis, DOE found that brittleness
remained an issue in using amorphous steel in metal halide
ballasts.\22\ Further amorphous steel is implemented as laminations to
ensure losses due to eddy currents do not offset efficiency gains.
Typically, amorphous steel laminations have a larger cross-sectional
area, which increases the overall size of the ballast, when compared to
silicon steel
[[Page 47485]]
laminations. Hence, in this analysis, DOE continues to screen out the
use of amorphous steel due to practicability to manufacture and adverse
impacts on equipment utility.
---------------------------------------------------------------------------
\22\ Technical Editor, ``Advantages and disadvantages of an
amorphous metal transformer.'' Polytechnic Hub, March 8, 2018,
available at https://www.polytechnichub.com/advantages-disadvantages-amorphous-metal-transformer/.
---------------------------------------------------------------------------
b. Remaining Technologies
DOE tentatively concludes that all of the other identified
technologies listed in section IV.B.4 meet all five screening criteria
to be examined further as design options. In summary, DOE did not
screen out the following technology options:
Magnetic Ballasts
[cir] Improved Core Steel
[cir] Copper Wiring
[cir] Improved Steel Laminations
[cir] Improved Windings
[cir] Electronic Ballast
Electronic Ballasts
[cir] Improved Components
[cir] Improved Circuit Design
For additional details, see chapter 4 of the NOPD TSD.
C. Engineering Analysis
In the engineering analysis, DOE develops cost-efficiency
relationships characterizing the incremental costs of achieving
increased ballast efficiency. This relationship serves as the basis for
cost-benefit calculations for individual consumers and the nation. The
methodology for the engineering analysis consists of the following
steps: (1) Selecting representative equipment classes; (2) selecting
baseline metal halide ballasts; (3) identifying more efficient
substitutes; (4) developing efficiency levels; and (5) scaling
efficiency levels to non-representative equipment classes. The details
of the engineering analysis are discussed in chapter 5 of the NOPD TSD.
1. Representative Equipment Classes
DOE selects certain equipment classes as ``representative'' to
focus its analysis. DOE chooses equipment classes as representative
primarily because of their high market volumes and/or unique
characteristics. DOE established 24 equipment classes based on input
voltage, rated lamp wattage, and indoor/outdoor designation. DOE did
not directly analyze the equipment classes containing only fixtures
with ballasts tested at 480 V due to low shipment volumes. DOE
determined that only 19 percent of fixtures in its compliance
certification database are fixtures with ballasts tested at 480 V. DOE
selected all other equipment classes as representative, resulting in a
total of 12 representative classes covering the full range of lamp
wattages, as well as indoor and outdoor designations.
In summary, DOE directly analyzed the equipment classes shown in
gray in Table IV.3 of this document. See chapter 5 of the NOPD TSD for
further discussion.
BILLING CODE 6450-01-P
[[Page 47486]]
[GRAPHIC] [TIFF OMITTED] TP05AU20.000
BILLING CODE 6450-01-C
Metal halide lamp fixtures are designed to be operated with lamps
of certain rated lamp wattages and contain ballasts that can operate
lamps at these wattages. To further focus the analysis, DOE selected a
representative rated wattage in each equipment class. Each
representative wattage was the most common wattage within each
equipment class. DOE found that common wattages within each equipment
class were the same for outdoor and indoor fixtures. Specifically, DOE
selected 70 W, 150 W, 250 W, 400 W, 1000 W and 1500 W as representative
wattages to analyze.
The >100 W and <150 W equipment class includes fixtures designed to
operate 150 W lamps that are rated for use in wet locations, as
specified by the National Electrical Code 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. These fixtures were
initially exempted by EISA 2007. (42 U.S.C. 6295(hh)(1)(B)(iii)) In the
2014 MHLF final rule, DOE included 150 W MHLFs previously exempted by
EISA 2007 in the >100 W and <150 W equipment class. 79 FR 7754-7755. In
this analysis, DOE found that 150 W was the most common wattage in this
equipment class and selected it as the representative wattage.
The representative wattages for each equipment class are summarized
in Table IV.4 of this document. See chapter 5 of the NOPD TSD for
further discussion.
Table IV.4--Representative Wattages
------------------------------------------------------------------------
Representative equipment class Representative wattage
------------------------------------------------------------------------
>=50 W and <=100 W...................... 70 W
>100 W and <150 W *..................... 150 W
>=150 W and <=250 W **.................. 250 W
>250 W and <=500 W...................... 400 W
>500 W and <=1000 W..................... 1000 W
[[Page 47487]]
>1000 W and <=2000 W.................... 1500 W
------------------------------------------------------------------------
* Includes 150 W fixtures initially 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 initially 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.
2. Baseline Ballasts
For each representative equipment class, DOE selected baseline
ballasts to serve as reference points against which DOE measured
changes from potential amended energy conservation standards.
Typically, the baseline ballast is the most common, least efficient
ballast that meets existing energy conservation standards. In this
analysis, DOE selected as baselines the least efficient ballast meeting
standards that have common attributes for ballasts in each equipment
class such as circuit type, input voltage and ballast type.
DOE used the efficiency values of ballasts contained in MHLFs
certified in DOE's compliance certification database to identify
baseline ballasts for all equipment classes except the >1000 W and
<=2000 W equipment class. Because fixtures in this equipment class are
not currently subject to standards, and therefore do not have DOE
certification data, DOE determined ballast efficiency values by using
catalog data. In summary, DOE directly analyzed the baseline ballasts
shown in Table IV.5 of this document. See chapter 5 of the NOPD TSD for
more detail.
Table IV.5--Baseline Models
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative equipment System input Ballast
class Wattage Ballast type Circuit type Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W.......... 70 Magnetic......... HX-HPF........... Pulse............ Quad............. 89.5 0.782
>100 W and <150 W *......... 150 Magnetic......... HX-HPF........... Pulse............ Quad............. 182.0 0.824
>=150 W and <=250 W **...... 250 Magnetic......... CWA.............. Pulse............ Quad............. 281.5 0.888
>250 W and <=500 W.......... 400 Magnetic......... CWA.............. Pulse............ Quad............. 443.0 0.903
>500 W and <=1000 W......... 1000 Magnetic......... CWA.............. Pulse............ Quad............. 1068.4 0.936
>1000 W and <=2000 W........ 1500 Magnetic......... CWA.............. Probe............ Quad............. 1625.0 0.923
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Includes 150 W fixtures initially 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 initially 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.
3. More-Efficient Ballasts
DOE selected more-efficient ballasts as replacements for each of
the baseline ballasts by considering commercially available ballasts.
DOE also selected more-efficient ballasts with similar attributes as
the baseline ballast when possible (e.g., circuit type, input voltage).
As with the baseline ballasts, DOE used the ballast efficiency values
from the compliance certification database to identify more efficient
ballasts for all equipment classes except the >1000 W and <=2000 W
equipment class which does not have certification data available. For
this equipment class, DOE determined ballast efficiency values by first
gathering and analyzing catalog data. DOE then tested the ballasts to
verify the ballast efficiency reported by the manufacturer. For
instances where the catalog data did not align with the tested data,
DOE selected more-efficient ballasts based on the tested ballast
efficiency.
As noted in section IV.C.1, the representative wattage for the >100
W and <150 W equipment class is 150 W. This equipment class includes
150 W MHLFs that are rated for wet-location and high-temperature. All
other 150 W MHLFs are included in the >=150 W and <=250 W equipment
class. In the 2014 MHLF final rule, based on test data of wet-location
and high-temperature 150 W ballasts, DOE identified two efficiency
levels for electronic ballasts in the >100 W and <150 W equipment
class. 79 FR 7777. In this analysis, based on its review of the
compliance certification database DOE was unable to identify 150 W
MHLFs rated for wet-location and high-temperature that contain
electronic ballasts. DOE then assessed the efficiencies of 150 W
electronic ballasts not rated for wet-location and high temperature
that are certified in the compliance certification database. DOE found
these electronic ballast efficiencies to be similar to those identified
in the 2014 MHLF final rule for the >100 W and <150 W equipment class.
Hence, for the >100 W and <150 W equipment class, DOE selected more-
efficient electronic ballasts based on compliance-certification-
database efficiencies of 150 W MHLFs not rated for wet-locations and
high temperatures.
In response to the July 2019 RFI, EEI commented that there is
minimal energy savings potential for MHLF technology. EEI also
expressed concerns about whether the metal halide ballasts reported in
the RFI to be 0.8 percent to 3.3 percent more efficient than the
maximum efficiency levels from the 2014 MHLF final rule are
commercially available for all lamp wattages. EEI also raised questions
about the possibility of these more efficient metal halide ballasts
including proprietary technology or being exclusively manufactured by
one company. (EEI, No. 2 at p. 2-3)
DOE agrees with EEI that commercially available metal halide
ballasts are not up to 0.8 percent to 3.3 percent more efficient than
the maximum efficiency levels analyzed in the 2014 MHLF final rule.
Since the July 2019 RFI, DOE updated its analysis and found that metal
halide ballasts that were more efficient than the maximum efficiency
levels analyzed in the 2014 MHLF final rule no longer appear in its
compliance certification database. (See section IV.C.4 for further
details.)
4. Efficiency Levels
Based on the more-efficient ballasts selected for analysis, DOE
developed ELs for the representative equipment classes. DOE identified
one magnetic EL in every equipment class. The more-efficient magnetic
EL represents a magnetic ballast with a higher grade of steel compared
to the baseline. DOE identified one electronic EL for the >=150 W and
<=250 W and >250 W and <=500 W equipment classes. The standard
electronic level represents a ballast with standard electronic
circuitry. DOE identified a more efficient electronic EL in the >=50 W
and <=100 W and >100 W and <150 W equipment classes. The
[[Page 47488]]
more-efficient electronic EL represents an electronic ballast with an
improved circuit design and/or more efficient components compared to
the standard electronic level.
The characteristics of the more-efficient representative units are
summarized in Table IV.6 through Table IV.11 of this document. See
chapter 5 of the NOPD TSD for more detail.
Table IV.6--70 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W............ EL1 More Efficient 70 Pulse.............. Tri............... 88.3 0.793
Magnetic.
EL2 Standard 70 Pulse.............. Quad.............. 0.814 0.860
Electronic.
EL3 Electronic Max 70 Pulse.............. Quad.............. 77.7 0.901
Tech.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV.7--150 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>100 W and <150 W *........... EL1 More Efficient 150 Pulse.............. Quad.............. 178.6 0.84
Magnetic.
EL2 Standard 150 Pulse.............. Quad.............. 166.7 0.9
Electronic.
EL3 Electronic Max 150 Pulse.............. Quad.............. 162.2 0.925
Tech.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Includes 150 W fixtures initially 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.
Table IV.8--250 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>=150 W and <=250 W *......... EL1 More Efficient 250 Pulse.............. Quad.............. 276.5 0.904
Magnetic.
EL2 Electronic Max 250 Pulse.............. Tri............... 266.2 0.939
Tech.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Excludes 150 W fixtures initially 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.
Table IV.9--400 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>250 W and <=500 W............ EL1 More Efficient 400 Pulse.............. Quad.............. 440.5 0.908
Magnetic.
EL2 Electronic Max 400 Pulse.............. Tri............... 426.0 0.939
Tech.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV.10--1000 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>500 W and <=1000 W........... EL1 More Efficient 1000 Pulse.............. Quad.............. 1063.8 0.94
Magnetic.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV.11--1500 W Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
System input Ballast
Equipment class EL Technology Rated wattage Starting method Input voltage power efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
>500 W and <=1000 W........... EL1 More Efficient 1000 Pulse.............. Quad.............. 1063.8 0.94
Magnetic.
--------------------------------------------------------------------------------------------------------------------------------------------------------
In the 2014 MHLF final rule, DOE determined that except in a few
cases where the linear form was more appropriate, a power-law equation
best captured the metal halide ballast efficiency data. 79 FR 7777. In
this analysis, DOE determined that the power-law equation and in some
cases the linear equation remain valid representations of the metal
halide ballast efficiency data. DOE ensured that equations best fit the
more-efficient representative units identified in each equipment class
while forming one continuous equation across equipment classes, where
possible.
Table IV.12 summarizes the efficiency requirements and associated
equations at each EL for the representative equipment classes. DOE
requests comment on the ELs under consideration for the representative
equipment classes, including the max-tech levels.
Table IV.12--Summary of ELs for Representative Equipment Classes
----------------------------------------------------------------------------------------------------------------
Minimum efficiency
Equipment class EL Technology equation for ballasts
not tested at 480 V *
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W.................... EL1 More Efficient Magnetic. 1/1+1.16*P[caret](-
0.345))[dagger]
EL2 Standard Electronic..... 1/(1+1*P[caret](-0.42))
EL3 Electronic Max Tech..... 1/(1+0.4*P[caret](-0.3))
[[Page 47489]]
>100 W and <150 W..................... EL1 More Efficient Magnetic. 1/(1+1.16*P[caret](-
0.345))
EL2 Standard Electronic..... 1/(1+1*P[caret](-0.42))
EL3 Electronic Max Tech..... 1/(1+0.4*P[caret](-0.3))
>=150 W and <=250 W................... EL1 More Efficient Magnetic. 1/(1+0.5017*P[caret](-
0.26))
EL2 Standard Electronic..... 1/(1+1*P[caret](-0.42))
EL3 Electronic Max Tech..... 1/(1+0.4*P[caret](-0.3))
>250 W and <=500 W.................... EL1 More Efficient Magnetic. 1/(1+0.5017*P[caret](-
0.26))
EL2 Standard Electronic..... 1/(1+1*P[caret](-0.42))
EL3 Electronic Max Tech..... 1/(1+0.4*P[caret](-0.3))
>500 W and <=1000 W................... EL1 More Efficient Magnetic. 0.000057*P+0.881
>1000 W and <=2000 W.................. EL1 More Efficient Magnetic. -0.000008*P+0.946
----------------------------------------------------------------------------------------------------------------
* P is defined as the rated wattage of the lamp the fixture is designed to operate.
CA IOUs recommended that DOE consider fixtures that include
ballasts meeting the 90-92 percent efficiency California Appliance
Efficiency Standards for fixtures between 13,050 and 43,500 lumens when
determining new efficiency levels. (CA IOUs, No. 5 at p. 2-3) CA IOUs
also commented that if DOE is unable to move toward a technology-
agnostic standard that incorporates the entire fixture, DOE should at
least adopt efficiency levels based on electronic ballast technology
and not magnetic ballast technology. (CA IOUs, No. 5 at p. 3)
Table IV.6 through Table IV.11 in this section describe the more
efficient ballasts analyzed at each EL, including the ballast
efficiency of each unit. As described in this section, some ELs can
only be met by electronic ballast technology. DOE considers the
benefits and burdens of each level in section V.D of this document.
5. Design Standard
Under 42 U.S.C. 6295(hh)(4), DOE is permitted to establish a
standard based on both design and performance requirements. Existing
design standards for MHLFs relate to fixtures that contain probe-start
ballasts. EISA 2007 required that MHLFs designed to operate lamps rated
at or above 150 W but at or less than 500 W contain magnetic probe-
start ballasts that are at least 94 percent efficient. (42 U.S.C.
6295(hh)(1)(A)(ii)) In the 2014 MHLF final rule, DOE adopted a design
standard that prohibits the sale of probe-start ballasts in newly sold
fixtures that are designed to operate rated lamp wattages from 501 W-
1000 W. 79 FR 7778; 10 CFR 431.326(d). DOE reviewed MHLFs currently
offered on the market and did not find any ballast characteristics or
other performance features of the fixtures during the analysis for this
NOPD to lead it to conclude that a new design standard would result in
significant energy savings. Therefore, in this analysis, DOE is not
proposing any new design standards for MHLFs.
6. Scaling to Other Equipment Classes
DOE did not directly analyze MHLFs with ballasts that would be
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, for each representative wattage certified to DOE, DOE compared
quad-voltage ballasts from the representative equipment classes to
their 480 V ballast counterparts using information from the compliance
certification database. Ballasts capable of operating 120 V or 277 V
are predominantly quad-voltage ballasts, therefore, DOE chose to
compare quad-voltage ballasts with 480 V ballasts to develop a scaling
factor.
Based on its review of the compliance certification database, DOE
determined that the average reduction in ballast efficiency for 480 V
ballasts compared to quad ballasts is greater for ballasts designed to
operate lamps rated less than 150 W compared to ballasts designed to
operate lamps rated greater than or equal to 150 W. Hence, using the
method described above, DOE developed two separate scaling factors, one
for the 50 W-150 W range and the second for the 150 W-1000 W range. For
non-representative equipment classes in the 50 W-150 W range, DOE found
the average reduction in ballast efficiency to be 3.0 percent, and for
those in the 150 W-1000 W range, DOE found the average reduction in
ballast efficiency to be 1.0 percent. DOE applied these scaling factors
to the representative equipment class EL equations to develop
corresponding EL equations for ballasts tested at an input voltage of
480V. Specifically, for the non-representative equipment classes in the
50 W-150 W range, DOE used a multiplier of 0.97, and for those in the
150 W-1000 W range, DOE used a multiplier of 0.99.
For ballasts greater than 1000 W, DOE determined the need for a
scaling factor based on manufacturer catalog data. DOE determined that
ballasts greater than 1000 W do not show a difference in efficiency
between 480 V and non-480 V ballasts. DOE did not apply a scaling
factor to develop efficiency levels for 480 V ballasts in this
equipment class, however, DOE continues to consider the 480 V and non-
480 V equipment classes separately for MHLFs greater than 1000 W for
the purposes of this analysis.
Additionally, for the >=150 W and <=250 W non-representative
equipment class, DOE adjusted the resulting scaled equations to ensure
all ELs were equal to or more stringent than the EISA 2007 minimum
ballast efficiency standard. See chapter 5 of the NOPD TSD for
additional details.
Table IV.13 summarizes the efficiency requirements at each EL for
the non-representative equipment classes. DOE requests comment on the
ELs under consideration for the non-representative equipment classes,
including the max-tech levels.
Table IV.13--Summary of ELs for Non-Representative Equipment Classes
----------------------------------------------------------------------------------------------------------------
Minimum efficiency
Equipment class EL Technology equation for ballasts
tested at 480 V
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W.................... EL1 Improved magnetic....... 0.97/(1+1.16*P[caret](-
0.345))
[[Page 47490]]
EL2 Standard Electronic..... 0.97/(1+1*P[caret](-
0.42))
EL3 Electronic Max Tech..... 0.97/(1+0.4*P[caret](-
0.3))
>100 W and <150 W *................... EL1 Improved magnetic....... 0.97*(0.0006*P+0.748)
EL2 Standard Electronic..... 0.97/(1+1*P[caret](-
0.42))
EL3 Electronic Max Tech..... 0.97/(1+0.4*P[caret](-
0.3))
>=150 W and <=250 W **................ EL1 Improved magnetic....... >=150 W and <210 W: 0.88
>=210 W and <=250 W:
0.99/
(1+0.5017*P[caret](-
0.26))
EL2 Standard Electronic..... 0.99/(1+1*P[caret](-
0.42))
EL3 Electronic Max Tech..... 0.99/(1+0.4*P[caret](-
0.3))
>250 W and <=500 W.................... EL1 Improved magnetic....... 0.99/(1+0.5017*P[caret](-
0.26))
EL2 Standard Electronic..... 0.99/(1+1*P[caret](-
0.42))
EL3 Electronic Max Tech..... 0.99/(1+0.4*P[caret](-
0.3))
>500 W and <=1000W.................... EL1 Improved magnetic....... 0.99*(0.0001*P+0.881)
>1000 W and <=2000 W.................. EL1 Improved magnetic....... 0.99*(-0.000008*P+0.946)
----------------------------------------------------------------------------------------------------------------
* P is defined as the rated wattage of the lamp the fixture is designed to operate.
7. Manufacturer Selling Price
DOE develops manufacturer selling prices (``MSPs'') for covered
equipment and applies markups to create end-user prices to use as
inputs to the LCC analysis and NIA. The MSP of a MHLF comprises of the
MSP of the fixture components including any necessary additional
features and the MSP of the metal halide ballast contained in the
fixture. For this analysis, DOE conducted teardown analyses on 31
commercially available MHLFs and the ballasts included in these
fixtures. Using the information from these teardowns, DOE summed the
direct material, labor, and overhead costs used to manufacture a MHLF
or metal halide ballast, to calculate the manufacturing production cost
(``MPC'').\23\ The following sections describe the development of MSPs
of fixture components and more-efficient MH ballasts identified for
each efficiency level considered in this analysis.
---------------------------------------------------------------------------
\23\ 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.
---------------------------------------------------------------------------
a. Fixtures
To determine the fixture components MSPs, DOE conducted fixture
teardowns to derive MPCs of empty fixtures (i.e., lamp enclosure and
optics). The empty fixture does not include the ballast or lamp. DOE
then added the other components required by the system (including
ballast and any cost adders associated with electronically ballasted
systems) and applied appropriate markups to obtain a final MSP for the
entire fixture.
To calculate an empty fixture price, DOE identified the
applications commonly served by the representative wattage in each
equipment class. DOE recognizes that technological changes in the
ballast, specifically moving from magnetic ballasts to electronic
ballasts, can necessitate alterations to the fixture. These changes
often incur additional costs that are dependent on the price of the
baseline fixture that is altered. DOE estimates a baseline empty
fixture cost as well as incremental costs at ELs that require
electronic ballasts. The cost adders to the fixtures are discussed
later in this section.
DOE selected one to four representative fixture types for each
rated wattage range based on the most common application(s) within that
range. DOE determined the common application(s) by reviewing all
fixtures in DOE's compliance certification database, identifying the
type of fixture for each basic model, and then using a product count to
determine the most popular fixture types in each equipment class. DOE
selected representative fixture types separately for indoor and outdoor
applications. The representative fixture types for each equipment
class, are shown in Table IV.14 below. See chapter 5 of the NOPD TSD
for further discussion.
Table IV.14--Representative Fixture Types
----------------------------------------------------------------------------------------------------------------
Representative fixture types
Representative equipment class Representative wattage -----------------------------------------------
Indoor Outdoor
----------------------------------------------------------------------------------------------------------------
>=50 W and <=100 W................. 70 W....................... Downlight............. Bollard, Flood, Post
Top, Wallpack.
>100 W and <150 W *................ 150 W...................... Downlight............. Area, Flood, Post Top,
Wallpack.
>=150 W and <=250 W **............. 250 W...................... High-Bay.............. Area, Flood, Post Top,
Cobrahead.
>250 W and <=500 W................. 400 W...................... High-Bay.............. Area, Flood, Post Top,
Cobrahead.
>500 W and <=1000 W................ 1000 W..................... High-Bay.............. Area, Flood, Sports.
>1000 W and <=2000 W............... 1500 W..................... Sports................ Sports.
----------------------------------------------------------------------------------------------------------------
* Includes 150 W fixtures initially 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 initially 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.
[[Page 47491]]
The MPCs of empty fixtures were determined using teardowns.
Teardowns were conducted for 31 fixtures that spanned the
representative wattages and the applications identified for each
representative wattage. The MPC of the empty fixture for each
representative wattage was calculated by weighting the empty fixture
cost for each application by the popularity of each application. DOE
determined the weightings based on the number of fixtures for each
application at each representative wattage in DOE's certification
database. See chapter 5 of the NOPD TSD for further details.
While the empty fixture MPCs remain the same at each magnetic
efficiency level, incremental costs are added when the fixture contains
an electronic ballast. In the 2014 MHLF final rule DOE applied cost
adders to fixtures that use electronic ballasts for (1) transient
protection, (2) thermal management, and (3) 120 V auxiliary power
functionality. 79 FR 7781. These costs varied based on whether the
fixture application was indoor, indoor industrial, or outdoor.
Fixtures with electronic ballasts that are used in outdoor or
indoor industrial applications must be able to withstand 10 kilovolt
voltage transients. Therefore, in the 2014 MHLF final rule, DOE
included the high-volume cost of a voltage transient protection device
which it determined to be $10.31. 79 FR 7781. In this analysis, based
on market research, DOE determined the price of voltage transient
protection to be $9.03. DOE added $9.03 to the empty fixture MPC for
outdoor and indoor industrial fixtures at efficiency levels requiring
an electronic ballast.
Compared to magnetic ballasts, electronic ballasts are more
vulnerable to high ambient temperatures, which can cause premature
ballast failure. Hence, in the 2014 MHLF final rule, DOE included the
cost of thermal management and determined it to be a 20 percent
increase in MPC based on manufacturer feedback and teardown analysis.
79 FR 7782. In this analysis, DOE determined that the 20 percent
increase in the empty fixture cost for thermal management in mental
halide fixtures containing electronic ballasts remains valid.
Therefore, DOE applied a 20 percent increase to the empty fixture MPC
at efficiency levels requiring an electronic ballast.
As discussed in the 2014 MHLF final rule, indoor applications may
require a 120 V auxiliary tap used to operate emergency lighting, which
can be easily incorporated into a magnetic ballast but requires
additional design for an electronic ballast. 79 FR 7782. In the 2014
MHLF final rule, DOE included the cost of an auxiliary tap, determining
that auxiliary taps cost about $7.50 but because the tap is needed in
only 10 percent of the ballasts in indoor fixtures DOE applied a cost
of $0.75. Id. In this determination, DOE conducted market research and
found the average market price of the 120 V auxiliary tap to be $7.38.
Similarly, because the auxiliary tap is needed in only 10 percent of
the ballasts in indoor fixtures, DOE added $0.74 to the indoor empty
fixture MPC for efficiency levels requiring an electronic ballast.
The manufacturer markup converts MPC to MSP. For this analysis, DOE
maintained the manufacturer markup developed in the 2014 MHLF final
rule. In that rule, DOE determined the fixture manufacturer markup to
be 1.58 based on financial information from manufacturers' SEC 10-K
reports, as well as feedback from manufacturer interviews. 79 FR 7783.
Hence, in this analysis, DOE applied the fixture manufacturer markup of
1.58 to the empty fixture MPC to determine the MSP of the fixture at
each efficiency level.
b. Ballasts
To determine the MPCs of the metal halide ballasts identified in
this analysis, DOE used data from the teardown analysis which included
cost data for magnetic ballasts at the baseline in each equipment
class. To determine the ballast MPC at the higher efficiency levels,
DOE developed a ratio between the average retail price of ballasts at
the efficiency level under consideration and ballasts at the baseline.
DOE collected retail prices from electrical distributors (e.g.,
Grainger, Graybar) as well as internet retailers to determine average
retail prices for ballasts. For efficiency levels without retail prices
available, DOE used a ratio between the same efficiency levels in a
different wattage class or interpolated based on efficiency and ballast
MPC.
The manufacturer markup converts MPC to MSP. For this analysis, DOE
maintained the manufacturer markup developed in the 2014 MHLF final
rule. In that rule, DOE determined the ballast manufacturer markup to
be 1.47 based on financial information from manufacturers' SEC 10-K
reports, as well as feedback from manufacturer interviews. 79 FR 7783.
Hence, in this analysis, DOE applied the ballast manufacturer markup of
1.47 to the ballast MPC to determine the MSP of replacement ballasts at
each efficiency level. If the ballast was sold within a new fixture,
DOE applied the ballast manufacturer markup of 1.47 and the fixture
manufacturer markup of 1.58 to the ballast MPC.
The total empty fixture MSPs, replacement ballast MSPs, and fixture
with ballast MSPs are detailed the NOPD TSD. DOE requests comment on
the methodology and resulting MSPs developed for all equipment classes.
D. Markups Analysis
The markups analysis develops appropriate markups (e.g., retailer
markups, distributor markups, contractor markups) in the distribution
chain and sales taxes to convert the MSP estimates derived in the
engineering analysis to customer prices, which are then used in the LCC
and PBP analysis. At each step in the distribution channel, companies
mark up the price of the product to cover business costs and profit
margin. DOE used the same distribution channels and markups as in the
2014 MHLF final rule.
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). Indoor fixtures
are all assumed to go through the electrical wholesaler distribution
channel. Outdoor fixtures are assumed to go through all three
distribution channels as follows: 60 percent electrical wholesaler, 20
percent contractor, and 20 percent utility.
2. Estimation of Markups
To estimate wholesaler and utility markups, DOE used financial data
from 10-K reports of 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
[[Page 47492]]
conditions with new and amended energy conservation standards.
In the 2014 MHLF final rule, DOE assumed a wholesaler baseline
markup of 1.23 and a contractor markup of 1.13, yielding a total
wholesaler distribution channel baseline markup of 1.49. The lower
wholesaler incremental markup of 1.05 yields a lower total incremental
markup through this distribution channel of 1.27. DOE also assumed a
utility markup of 1.00 for the utility distribution channel in which
the manufacturer sells a fixture directly to the end-user. DOE again
assumed a contractor markup of 1.13 for the utility distribution
channel in which a manufacturer sells a fixture to a contractor who in
turn sells it to the end-user yielding an overall markup of 1.21 for
this channel. 79 FR 7783. DOE used these same markups for this NOPD
analysis.
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.\24\ 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 this NOPD, this approach provided a national average tax
rate of 7.2 percent.
---------------------------------------------------------------------------
\24\ Sales Tax Clearinghouse, Inc. The Sales Tax Clearinghouse.
(Last accessed December 5, 2019.) https://thestc.com/STRates.stm.
---------------------------------------------------------------------------
3. Summary of Markups
Table IV.15 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 IV.15--Summary of Fixture Distribution Channel Markups
--------------------------------------------------------------------------------------------------------------------------------------------------------
Wholesaler distribution Utility distribution
-----------------------------------------------------------------------------------------------
Via wholesaler and contractor Direct to end user
Baseline Incremental ---------------------------------------------------------------
Baseline Incremental Baseline Incremental
--------------------------------------------------------------------------------------------------------------------------------------------------------
Electrical Wholesaler (Distributor)..................... 1.23 1.05 N/A N/A N/A N/A
Utility................................................. N/A N/A 1.00 1.00 1.00 1.00
Contractor or Installer................................. 1.13 1.13 1.13 1.13 N/A N/A
-----------------------------------------------------------------------------------------------
Sales Tax............................................... 1.07
1.07
1.07
-----------------------------------------------------------------------------------------------
Overall................................................. 1.49 1.27 1.21 1.21 1.07 1.07
--------------------------------------------------------------------------------------------------------------------------------------------------------
Using these markups, DOE generated fixture end-user prices for each
EL it considered, assuming that each level represents a new minimum
efficiency standard. Chapter 6 of the NOPD TSD provides details on
DOE's development of markups for MHLFs. DOE welcomes any relevant data
and comments on the markups analysis methodology.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of MHLFs at different efficiencies in the
commercial, industrial, and outdoor stationary sectors, and to assess
the energy savings potential of increased MHLF efficiency. The energy
use analysis estimates the range of energy use of MHLFs in the field
(i.e., as they are actually used by customers). The energy use analysis
provides the basis for other analyses DOE performed, particularly
assessments of the energy savings and the savings in operating costs
that could result from adoption of amended or new standards.
To develop annual energy use estimates, DOE multiplied the lamp-
and-ballast system input power (in watts) by annual usage (in hours per
year). DOE characterized representative lamp-and-ballast systems in the
engineering analysis, which provided measured input power ratings. To
characterize the country's average usage of fixtures for a typical
year, DOE developed annual operating hour distributions by sector,
using data published in the 2015 U.S. Lighting Market Characterization
(``LMC'').\25\ For the >=50 W and <=100 W to >500 W and <=1000 W
equipment classes, DOE obtained weighted-average annual operating hours
for the commercial, industrial, and outdoor stationary sectors of
approximately 2,300 hours, 5,100 hours, and 5,000 hours, respectively.
For the 1,500 W equipment class, DOE assigned annual operating hours of
approximately 770 hours for all lamps according to the 2015 LMC
estimate of 2.1 hours per day for sports field lighting, consistent
with the methodology from the 2014 MHLF final rule.\26\
---------------------------------------------------------------------------
\25\ Navigant Consulting, Inc. 2015 U.S. Lighting Market
Characterization. 2017. U.S. Department of Energy: Washington, DC
Report No. DOE/EE-1719. (Last accessed December 5, 2019.) https://energy.gov/eere/ssl/downloads/2015-us-lighting-market-characterization.
\26\ U.S. Department of Energy--Office of Energy Efficiency and
Renewable Energy. Technical Support Document: Energy Conservation
Program for Consumer Products and Certain Commercial and Industrial
Equipment: Metal Halide Lamp Fixtures. January 2014. Washington, DC
(Last accessed December 5, 2019.) https://www.regulations.gov/document?D=EERE-2009-BT-STD-0018-0069.
---------------------------------------------------------------------------
All comments received in response to the July 2019 RFI regarding
the methodology to develop annual operating hours and energy use from
the 2014 MHLF final rule were supportive, and DOE has continued to use
the same methodology in this NOPD (with updated inputs as appropriate).
(NEMA, No. 3 at pp. 7-8) Chapter 7 of the NOPD TSD provides details on
DOE's energy use analysis for MHLFs. DOE welcomes any relevant data and
comments on the energy use analysis methodology.
F. Life-Cycle Cost and Payback Period Analysis
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual customers of potential energy conservation standards for
MHLFs. The effect of new or amended energy conservation standards on
individual customers usually involves a reduction in operating cost and
an increase in purchase cost. DOE used the following two metrics to
measure customer impacts:
The LCC is the total customer expense of equipment over
the life of that equipment, consisting of total installed cost
(manufacturer selling price, distribution chain markups, sales tax, and
installation costs) plus operating costs (expenses for energy use,
maintenance, and repair). To compute the operating costs, DOE discounts
[[Page 47493]]
future operating costs to the time of purchase and sums 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 a more-efficient equipment through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
at higher efficiency levels by the change in annual operating cost for
the year that amended or new standards are assumed to take effect.
For any given efficiency level, DOE measured the change in LCC
relative to the LCC in the no-new-standards case, which reflects the
estimated efficiency distribution of MHLFs in the absence of new or
amended energy conservation standards. In contrast, the PBP for a given
efficiency level is measured relative to the baseline equipment.
For each considered efficiency level in each equipment class, DOE
calculated the LCC and PBP for a nationally representative set of
building types. As stated previously, DOE developed customer samples
from the 2015 LMC. For each sample customer, DOE determined the energy
consumption for the MHLF and the appropriate electricity price. By
developing a representative sample of building types, the analysis
captured the variability in energy consumption and energy prices
associated with the use of MHLFs.
Inputs to the calculation of total installed cost include the cost
of the equipment--which includes MPCs, manufacturer markups, retailer
and distributor 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, and discount rates. DOE created
distributions of values for operating hours, equipment lifetime,
discount rates, electricity prices, and sales taxes, with probabilities
attached to each value, to account for their uncertainty and
variability. 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\TM\ (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 MHLF user
samples. The model calculated the LCC and PBP for equipment at each
efficiency level for 10,000 customers per simulation run. The
analytical results include a distribution of 10,000 data points showing
the range of LCC savings for a given efficiency level relative to the
no-new-standards case efficiency distribution. In performing an
iteration of the Monte Carlo simulation for a given consumer, product
efficiency is chosen based on its probability. If the chosen product
efficiency is greater than or equal to the efficiency of the standard
level under consideration, the LCC and PBP calculation reveals that a
consumer is not impacted by the standard level. By accounting for
consumers who already purchase more-efficient products, DOE avoids
overstating the potential benefits from increasing product efficiency.
DOE calculated the LCC and PBP for all customers of MHLFs as if
each were to purchase new equipment in the expected year of required
compliance with new or amended standards. Any amended standards would
apply to MHLFs manufactured three years after the date on which any new
or amended standard is published. (42 U.S.C. 6295(hh)(3)(B)) At this
time, DOE estimates publication of a final rule in the latter half of
2021. Therefore, for purposes of its analysis, DOE used 2025 as the
first year of compliance with any amended standards for MHLFs.
Table IV.16 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. Details of the spreadsheet model, and of
all the inputs to the LCC and PBP analyses, are contained in chapter 8
of the NOPD TSD and its appendices.
Table IV.16--Summary of Inputs and Methods for the LCC and PBP Analysis*
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Equipment Cost............... Derived by multiplying MSPs by
distribution channel markups (taken from
the 2014 MHLF final rule) and sales tax.
Installation Costs........... Used the same installation costs as in
the 2014 MHLF final rule, but inflated
to 2018$. The 2014 MHLF final rule costs
were calculated using estimated labor
times and applicable labor rates from
``RS Means Electrical Cost Data''
(2013), Sweets Electrical Cost Guide
2013, and the U.S. Bureau of Labor
Statistics.
Annual Energy Use............ The total annual energy use multiplied by
the operating hours per year, which were
determined separately for indoor and
outdoor fixtures. Average number of
hours based on the 2015 LMC.
Energy Prices................ Electricity: Based on Edison Electric
Institute data for 2018.
Variability: Regional energy prices
determined for 13 census divisions and
large states.
Energy Price Trends.......... Based on AEO 2019 price projections.
Replacement Costs............ Used the same labor and material costs
for lamp and ballast replacements as in
the 2014 MHLF final rule, but inflated
to 2018$.
Equipment Lifetime........... Used the same lifetimes as in the 2014
MHLF final rule.
Ballasts: Assumed an average of 50,000
hours for magnetic ballasts and 40,000
hours for electronic ballasts.
Fixtures: Assumed an average of 20 years
for indoor fixtures and 25 years for
outdoor fixtures.
Discount Rates............... Developed a distribution of discount
rates for the commercial, industrial,
and outdoor stationary sectors.
Compliance Date.............. 2025.
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table or in chapter 8 of the NOPD TSD.
[[Page 47494]]
1. Equipment Cost
To calculate customer equipment costs, DOE multiplied the MSPs
developed in the engineering analysis by the markups described
previously (along with sales taxes). DOE used different markups for
baseline equipment and higher-efficiency equipment, because DOE applies
an incremental markup to the increase in MSP associated with higher-
efficiency equipment. See section IV.D for further details.
2. Installation Cost
Installation cost is the cost to install the fixture such as the
labor, overhead, and any miscellaneous materials and parts needed. DOE
used the installation costs from the 2014 MHLF final rule but inflated
to 2018$.
3. Annual Energy Consumption
For each sampled customer, DOE determined the energy consumption
for an MHLF at different efficiency levels using the approach described
previously in section IV.E of this document. For this NOPD, 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 (approximately 770 hours per year) for
the 1,500 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
DOE derived average and marginal annual commercial and industrial
electricity prices for 13 regions (9 Census Divisions and 4 large
states) using 2018 data from Edison Electric Institute.\27\
---------------------------------------------------------------------------
\27\ Edison Electric Institute. Typical Bills and Average Rates
Report. Winter 2017, Summer 2017: Washington, DC.
---------------------------------------------------------------------------
To estimate energy prices in future years, DOE multiplied the
average regional energy prices by a projection of annual change in
national-average commercial and industrial energy prices in the
Reference case of Annual Energy Outlook 2019 (AEO 2019).\28\ AEO 2019
has an end year of 2050. To estimate price trends after 2050, DOE used
the compound annual growth rate of change in prices between 2035 and
2050.
---------------------------------------------------------------------------
\28\ U.S. Energy Information Administration. Annual Energy
Outlook 2019 with Projections to 2050. 2019. Washington, DC Report
No. AEO2019. (Last accessed May 13, 2019.) https://www.eia.gov/outlooks/aeo/pdf/aeo2019.pdf.
---------------------------------------------------------------------------
5. Replacement Costs
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. The costs are taken from the 2014 MHLF
final rule but inflated to 2018$. 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 associated with lamp or
ballast replacements are included in the calculation of operating
costs.
6. Equipment Lifetime
DOE defined equipment lifetime as the age when a fixture, ballast,
or lamp is retired from service. For fixtures in all equipment classes,
DOE assumed average lifetimes for indoor and outdoor fixtures of 20 and
25 years, respectively. DOE also assumed that magnetic ballasts had a
rated lifetime of 50,000 hours and electronic ballasts had a rated
lifetime of 40,000 hours. DOE used manufacturer catalog data to obtain
rated lifetime estimates (in hours) for lamps in each equipment class.
DOE accounted for uncertainty in the fixture, ballast, and lamp
lifetimes by applying Weibull survival distributions to the components'
rated lifetimes. Furthermore, DOE included a residual value calculation
for lamps and ballasts to account for the residual monetary value
associated with the remaining life in the lamp and ballast at the end
of the fixture lifetime. All assumptions for estimating equipment
lifetime are taken from the 2014 MHLF final rule. 79 FR 7787.
7. Discount Rates
The discount rate is the rate at which future expenditures are
discounted to estimate their present value. In this NOPD, DOE estimated
separate discount rates for commercial, industrial, and outdoor
stationary applications. DOE used discount rate data from a 2019
Lawrence Berkeley National Laboratory report.\29\ The average discount
rates, weighted by the shares of each rate value in the sectoral
distributions, are 8.3 percent for commercial end-users, 8.8 percent
for industrial end-users, and 3.2 percent for outdoor stationary end-
users. For more information regarding discount rates, see chapter 8 of
the NOPD TSD.
---------------------------------------------------------------------------
\29\ Fujita, K.S. Commercial, Industrial, and Institutional
Discount Rate Estimation for Efficiency Standards Analysis: Sector-
Level Data 1998-2018. 2019. Lawrence Berkeley National Laboratory:
Berkeley, CA. (Last accessed January 15, 2020.) https://eta.lbl.gov/publications/commercial-industrial-institutional.
---------------------------------------------------------------------------
8. Energy Efficiency Distribution in the No-New-Standards Case
DOE developed a no-new-standards case efficiency distribution using
model count data from the compliance certification database collected
on October 10, 2019. The compliance certification database does not
contain models in the >1000 W and <=2000 W equipment class; therefore,
DOE assumed 56 percent of the market is at the baseline and 44 percent
of the market is at EL 1, based on MHLF catalog data. The complete
efficiency distribution for 2025 is shown in Table IV.17.
Table IV.17--MHLF Efficiency Distribution by Equipment Class for 2025
--------------------------------------------------------------------------------------------------------------------------------------------------------
Equipment class *
-----------------------------------------------------------------------------------------------
Efficiency level >=50 W and >100 W and >=150 W and >250 W and >500 W and >1000 W and
<=100 W (%) <150 W (%) <=250 W (%) <=500 W (%) <=1000 W (%) <=2000 W (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 83.1 88.1 73.6 87.6 99.5 56.0
1....................................................... 0.3 6.0 18.9 0.3 0.5 44.0
2....................................................... 9.2 0.0 7.5 12.2 .............. ..............
3....................................................... 7.4 5.9 .............. .............. .............. ..............
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Columns may not sum to 100% due to rounding.
[[Page 47495]]
9. Payback Period Analysis
The payback period is the amount of time it takes the customer to
recover the additional installed cost of more-efficient equipment,
compared to baseline equipment, through energy cost savings. Payback
periods are expressed in years. Payback periods that exceed the life of
the equipment mean that the increased total installed cost is not
recovered in reduced operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the equipment and the change in the
first-year annual operating expenditures relative to the baseline. The
PBP calculation uses the same inputs as the LCC analysis, except that
discount rates are not needed.
As noted previously, EPCA 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 first year's energy savings resulting from the standard,
as calculated under the applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test
procedure, and multiplying those savings by the average energy price
projection for the year in which compliance with the amended standards
would be required.
DOE welcomes any relevant data and comments on the life-cycle cost
and payback period analysis methodology.
G. Shipments Analysis
DOE uses projections of annual equipment shipments to calculate the
national impacts of potential amended or new energy conservation
standards on energy use and NPV.\30\ The shipments model takes an
accounting approach, tracking market shares of each equipment class and
the vintage of units in the stock. Stock accounting uses equipment
shipments as inputs to estimate the age distribution of in-service
equipment stocks for all years. The age distribution of in-service
equipment stocks is a key input to calculations of both the NES and
NPV, because operating costs for any year depend on the age
distribution of the stock.
---------------------------------------------------------------------------
\30\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
The stock turnover model calculates demand for new MHLFs based on
the expected demand for replacement MHLFs and the decrease in MHLF
demand due to the adoption of out-of-scope LED alternatives. The model
is initialized using a time series of historical shipments data
compiled from the 2014 MHLF final rule and data from NEMA. The
historical shipments for 2008 from the 2014 MHLF final rule were
projected to 2018 using NEMA sales indices from 2008 to 2018. 79 FR
7788-7789.
NEMA commented in response to the July 2019 RFI that out-of-scope
LED alternatives are now the preferred technology for traditional MHLF
customers. (NEMA, No. 3 at pp. 2-3) DOE assumed an increasing fraction
of the MHLF market will move to out-of-scope LED alternatives over the
course of the shipments analysis period. DOE modelled the incursion of
LED equipment in the form of a Bass diffusion curve.\31\ The parameters
for the Bass diffusion curve are based on fitting a Bass diffusion
curve to market share data for general service LED lamps based on data
published by NEMA. This same approach was used in the final
determination for general service incandescent lamps; see chapter 9 of
the final determination TSD.\32\ 84 FR 71626, 71658 (December 27,
2019).
---------------------------------------------------------------------------
\31\ Bass, F.M. A New Product Growth Model for Consumer
Durables. Management Science. 1969. 15(5): pp. 215-227.
\32\ Chapter 9 of the GSIL final determination TSD is available
at https://www.regulations.gov/document?D=EERE-2019-BT-STD-0022-0116
---------------------------------------------------------------------------
DOE apportioned the total shipments of MHLFs to each EL in the no-
new-standards case using data downloaded from the compliance
certification database \33\ and data provided by NEMA in comments to
the July 2019 RFI. (NEMA, No. 3 at pp.11-14). Equipment listed in the
CCMS database were categorized by equipment class, efficiency level,
and ballast type. The counts for each category were scaled based on
ballast type by the NEMA market shares for magnetic and electronic
ballasts reported in 2018.
---------------------------------------------------------------------------
\33\ See https://www.regulations.doe.gov/certification-data/products.html (Last accessed on January 21, 2020).
---------------------------------------------------------------------------
For the standards cases, DOE used a ``roll-up'' approach to
estimate market share for each EL for the year that standards are
assumed to become effective (2025). For each standards case, the market
shares of ELs in the no-new-standards case that do not meet the
standard under consideration ``roll up'' to meet the new standard
level, and the market share of equipment above the standard remains
unchanged.
For both the no-new-standards and standards cases, DOE assumed no
efficiency trend over the analysis period. For a given case, market
shares were held fixed to their 2025 distribution.
DOE typically includes the impact of price learning in its
analysis. In a standard price learning model,\34\ the price of a given
technology is related to its cumulative production, as represented by
total cumulative shipments. In response to the July 2019 RFI, NEMA
indicated that MHLFs are a mature technology and are no longer a
preferred technology. (NEMA, No. 3 at p. 2) DOE assumed MHLFs have
reached a stable price point due to the high volume of total cumulative
shipments and would not undergo price learning in this NOPD analysis.
DOE welcomes any relevant data and comments on the shipments analysis
methodology.
---------------------------------------------------------------------------
\34\ Taylor, M. and S.K. Fujita. Accounting for Technological
Change in Regulatory Impact Analyses: The Learning Curve Technique.
2013. Lawrence Berkeley National Laboratory: Berkeley, CA. Report
No. LBNL-6195E. (Last accessed January 7, 2020.) https://eta.lbl.gov/publications/accounting-technological-change.
---------------------------------------------------------------------------
H. National Impact Analysis
The NIA assesses the NES and the NPV from a national perspective of
total customer costs and savings that would be expected to result from
new or amended standards at specific efficiency levels.\35\ DOE
calculates the NES and NPV for the potential standard levels considered
based on projections of annual equipment shipments, along with the
annual energy consumption and total installed cost data from the energy
use and LCC analyses. For the present analysis, DOE projected the
energy savings, operating cost savings, equipment costs, and NPV of
customer benefits over the lifetime of MHLFs sold from 2025 through
2054.
---------------------------------------------------------------------------
\35\ The NIA accounts for impacts in the 50 states and U.S.
territories.
---------------------------------------------------------------------------
DOE evaluates the impacts of new or amended standards by comparing
a case without such standards with standards-case projections. The no-
new-standards case characterizes energy use and customer costs for each
equipment class in the absence of new or amended energy conservation
standards. DOE compares the no-new-standards case 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. For the standards cases, DOE
considers
[[Page 47496]]
how a given standard would likely affect the market shares of equipment
with efficiencies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national customer costs and savings from each TSL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table IV.18 summarizes the inputs and methods DOE used for the NIA
analysis for this NOPD. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPD TSD for further details.
Table IV.18--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments.................... Annual shipments from shipments model for
each considered TSL.
First Full Year of Standard 2025.
Compliance.
No-new-standards Case No trend assumed.
Efficiency Trend.
Standards Case Efficiency No trend assumed.
Trend.
Annual Energy Consumption per Calculated for each efficiency level
Unit. based on inputs from the energy use
analysis.
Total Installed Cost per Unit MHLF prices and installation costs from
the LCC analysis.
Repair and Maintenance Cost Cost to replace lamp and ballast over the
per Unit. lifetime of the fixture.
Residual Value per Unit...... The monetary value of remaining lamp and
ballast lifetime at the end of the
fixture lifetime.
Electricity Prices........... Estimated marginal electricity prices
from the LCC analysis.
Electricity Price Trends..... AEO 2019 forecasts (to 2050) and
extrapolation thereafter.
Energy Site-to-Primary and A time-series conversion factor based on
FFC Conversion. AEO 2019.
Discount Rate................ 3 percent and 7 percent.
Present Year................. 2020.
------------------------------------------------------------------------
1. National Energy Savings
The NES analysis involves a comparison of national energy
consumption of the considered equipment between each potential TSL and
the case with no new or amended energy conservation standards. DOE
calculated the national energy consumption by multiplying the number of
units (stock) of each equipment type (by vintage or age) by the unit
energy consumption (also by vintage). DOE calculated annual NES based
on the difference in national energy consumption for the no-new
standards case and for each higher efficiency standard case. DOE
estimated energy consumption and savings based on site energy and
converted the electricity consumption and savings to primary energy
(i.e., the energy consumed by power plants to generate site
electricity) using annual conversion factors derived from AEO 2019.
Cumulative energy savings are the sum of the NES for each year over the
timeframe of the analysis.
DOE generally accounts for the direct rebound effect in its NES
analyses. Direct rebound reflects the idea that as appliances become
more efficient, customers use more of their service because their
operating cost is reduced. In the case of lighting, the rebound effect
could be manifested in increased hours of use or in increased lighting
density (lumens per square foot). In response to the July 2019 RFI,
NEMA commented that a rebound rate of 0 is appropriate. (NEMA, No. 3 at
p. 9) DOE assumed no rebound effect for MHLFs in this NOPD.
In 2011, 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 Sciences,
DOE announced its intention to use FFC measures of energy use and
greenhouse gas and other emissions to the extent that emissions
analyses are conducted. 76 FR 51281 (Aug. 18, 2011). After evaluating
the approaches discussed in the August 18, 2011 proposal, DOE published
a statement of amended policy in which DOE explained its determination
that Energy Information Administration's (EIA's) National Energy
Modeling System (``NEMS'') is the most appropriate tool for its FFC
analysis and its intention to use NEMS for that purpose. 77 FR 49701
(Aug. 17, 2012). NEMS is a public domain, multi-sector, partial
equilibrium model of the U.S. energy sector \36\ that EIA uses to
prepare its Annual Energy Outlook. The FFC factors incorporate losses
in production and delivery in the case of natural gas (including
fugitive emissions) and additional energy used to produce and deliver
the various fuels used by power plants. The approach used for deriving
FFC measures of energy use and emissions is described in appendix 10B
of the NOPD TSD.
---------------------------------------------------------------------------
\36\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2009, DOE/EIA-0581(2009), October 2009.
Available at https://www.eia.gov/forecasts/aeo/index.cfm.
---------------------------------------------------------------------------
2. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by customers are (1) total annual installed cost, (2) total
annual operating costs (energy costs and repair and maintenance costs),
and (3) a discount factor to calculate the present value of costs and
savings. DOE calculates net savings each year as the difference between
the no-new-standards case and each standards case in terms of total
savings in operating costs versus total increases in installed costs.
DOE calculates operating cost savings over the lifetime of equipment
shipped during the analysis period.
Energy cost savings, which are part of operating cost savings, are
calculated using the estimated energy savings in each year and the
projected price of the appropriate form of energy. To estimate energy
prices in future years, DOE multiplied the average national marginal
electricity prices by the forecast of annual national-average
commercial or industrial electricity price changes in the Reference
case from AEO 2019, which has an end year of 2050. To estimate price
trends after 2050, DOE used the average annual rate of change in prices
from 2041 to 2050.
DOE includes the cost of replacing failed lamps and ballasts over
the course of the lifetime of the fixture. DOE assumed that lamps and
ballasts were replaced at their rated lifetime. When replacing a
ballast, DOE assumed the lamp was also replaced at the same time,
independent of the timing of the previous lamp replacement. For more
details see chapter 10 of the NOPD TSD.
DOE also estimates the residual monetary value remaining in the
lamp and ballast at the end of the fixture lifetime and applies it as a
credit to
[[Page 47497]]
operating costs (i.e., the residual value is deducted from operating
costs). See chapter 10 of the NOPD TSD for more details on DOE's
calculation of the residual value.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPD, DOE estimated the NPV of customer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (``OMB'') to Federal agencies on the development of regulatory
analysis.\37\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a customer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
---------------------------------------------------------------------------
\37\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis. September 17, 2003. Section E. Available at
https://www.whitehouse.gov/omb/memoranda/m03-21.html.
---------------------------------------------------------------------------
V. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for MHLFs.
It addresses the ELs examined by DOE and the projected impacts of each
of these levels. Additional details regarding DOE's analyses are
contained in the NOPD TSD.
A. Trial Standard Levels
DOE analyzed the benefits and burdens of three TSLs for MHLFs. TSL
1 is composed of EL 1 for all equipment classes. TSL 2 is composed of
the efficiency levels corresponding to the least efficient electronic
ballast level for each equipment class, if any efficiency levels
corresponding to an electronic ballast exist. TSL 3 is composed of the
max-tech level for each equipment class. Table V.1 presents the TSLs
and the corresponding efficiency levels that DOE has identified for
potential amended energy conservation standards for MHLFs.
Table V.1--Trial Standard Levels for MHLFs
--------------------------------------------------------------------------------------------------------------------------------------------------------
>=50 W and >100 W and >=150 W and >250 W and >500 W and >1000 W and
<=100 W <150 W <=250 W <=500 W <=1000 W <=2000 W
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 0................................................... 0 0 0 0 0 0
TSL 1................................................... 1 1 1 1 1 1
TSL 2................................................... 2 2 2 2 1 1
TSL 3................................................... 3 3 2 2 1 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
B. Economic Impacts on Individual Customers
DOE analyzed the cost effectiveness (i.e., any savings in operating
costs compared to any increase in purchase price likely to result from
the imposition of a standard) by considering the LCC and PBP. These
analyses are discussed in the following sections.
1. Life-Cycle Cost and Payback Period
In general, higher efficiency equipment affects consumers in two
ways: (1) Purchase price increases and (2) annual operating costs
decrease.\38\ Inputs used for calculating the LCC and PBP include total
installed costs (i.e., product price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, and replacement costs). The LCC calculation also uses product
lifetime and a discount rate. Chapter 8 of the NOPD TSD provides
detailed information on the LCC and PBP analyses.
---------------------------------------------------------------------------
\38\ While it is generally true that higher-efficiency equipment
has lower operating costs, MHLF operating costs in this analysis
also incorporate the costs of lamp and ballast replacements. Due to
these replacement costs, higher operating costs can be experienced
at efficiency levels above the baseline.
---------------------------------------------------------------------------
Table V.2 through Table V.13 show the LCC and PBP results for the
ELs and TSLs considered for each equipment class, with indoor and
outdoor installations aggregated together using equipment shipments in
the analysis period start year (2025). Results for each equipment class
are shown in two tables. In the first table, the simple payback is
measured relative to the baseline product. For ELs having a higher
first year's operating cost than that of the baseline, the payback
period is ``Never,'' because the additional installed cost relative to
the baseline is not recouped. In the second table, impacts are measured
relative to the efficiency distribution in the no-new-standards case in
the compliance year (see section IV.F.8 of this document). Because some
customers purchase products with higher efficiency in the no-new-
standards case, the average savings are less than the difference
between the average LCC of the baseline product and the average LCC at
each TSL. The savings refer only to customers who are affected by a
standard at a given TSL. Those who already purchase equipment with
efficiency at or above a given TSL are not affected. Customers for whom
the LCC increases at a given TSL experience a net cost.
Table V.2--Average LCC and PBP Results for the >=50 W and <=100 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$) Average
---------------------------------------------------------------- Simple payback fixture
Efficiency level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 835.94 123.58 1,534.59 2,370.53 .............. 24.1
1....................................................... 848.48 123.51 1,532.13 2,380.61 182.0 24.1
2....................................................... 878.81 124.20 1,549.40 2,428.21 Never 24.1
[[Page 47498]]
3....................................................... 895.39 123.51 1,538.46 2,433.85 893.2 24.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V.3--Average LCC Savings Relative to the No-New-Standards Case for the >=50 W and <=100 W Equipment Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (10.09) 83.2
2......................................................... 2 (57.39) 62.7
3......................................................... 3 (57.38) 72.1
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V.4--Average LCC and PBP Results for the >100 W and <150 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$) Average
---------------------------------------------------------------- Simple payback fixture
Efficiency level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 803.46 146.31 1,702.74 2,506.20 .............. 23.5
1....................................................... 817.04 145.35 1,690.07 2,507.11 14.2 23.5
2....................................................... 853.41 143.65 1,678.31 2,531.72 18.8 23.5
3....................................................... 970.98 147.00 1,706.26 2,677.25 Never 23.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V.5--Average LCC Savings Relative to the No-New-Standards Case for the >100 W and <150 W Equipment Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (0.87) 57.4
2......................................................... 2 (25.22) 50.4
3......................................................... 3 (170.66) 90.7
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V.6--Average LCC and PBP Results for the >=150 W and <=250 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$) Average
---------------------------------------------------------------- Simple payback fixture
Efficiency level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 963.46 181.07 2,089.02 3,052.48 .............. 23.5
1....................................................... 988.66 180.75 2,082.57 3,071.23 79.4 23.5
2....................................................... 1,149.72 184.26 2,123.00 3,272.71 Never 23.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
[[Page 47499]]
Table V.7--Average LCC Savings Relative to the No-New-Standards Case for the >=150 W and <=250 W Equipment Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (18.70) 73.4
2......................................................... 2 (216.24) 90.9
3......................................................... 2 (216.24) 90.9
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V.8--Average LCC and PBP Results for the >250 W and <=500 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$) Average
---------------------------------------------------------------- Simple payback fixture
Efficiency level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 1,098.78 237.28 2,713.41 3,812.19 .............. 23.5
1....................................................... 1,122.58 237.08 2,708.49 3,831.07 121.8 23.5
2....................................................... 1,376.47 245.60 2,800.48 4,176.95 Never 23.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V.9--Average LCC Savings Relative to the No-New-Standards Case for the >250 W and <=500 W Equipment Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (18.87) 86.9
2......................................................... 2 (364.30) 87.2
3......................................................... 2 (364.30) 87.2
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V.10--Average LCC and PBP Results for the >500 W and <=1000 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$) Average
---------------------------------------------------------------- Simple payback fixture
Efficiency level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 1,305.39 555.06 6,526.50 7,831.89 .............. 23.7
1....................................................... 1,336.23 554.15 6,512.29 7,848.52 33.6 23.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V.11--Average LCC Savings Relative to the No-New-Standards Case for the >500 W and <=1000 W Equipment
Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (16.64) 93.3
2......................................................... 1 (16.64) 93.3
3......................................................... 1 (16.64) 93.3
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
[[Page 47500]]
Table V.12--Average LCC and PBP Results for the >1000 W and <=2000 W Equipment Class
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2018$)
---------------------------------------------------------------- Simple payback Average
Efficiency level First year's Lifetime years fixture
Installed cost operating cost operating cost LCC lifetime years
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 1,392.61 179.13 2,145.92 3,538.52 0.0 23.7
1....................................................... 1,423.31 177.41 2,124.97 3,548.28 17.9 23.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL are calculated assuming that all customers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V.13--Average LCC Savings Relative to the No-New-Standards Case for the >1000 W and <=2000 W Equipment
Class
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------------
Efficiency Percent of
TSL level Average LCC consumers that
savings * (2018$) experience net
cost
----------------------------------------------------------------------------------------------------------------
1......................................................... 1 (9.80) 48.0
2......................................................... 1 (9.80) 48.0
3......................................................... 1 (9.80) 48.0
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
2. Rebuttable Presumption Payback
As discussed in section IV.F.9 of this document, EPCA establishes a
rebuttable presumption that an energy conservation standard is
economically justified if the increased purchase cost for equipment
that meets the standard is less than three times the value of the
first-year energy savings resulting from the standard. In calculating a
rebuttable presumption payback period for each of the considered ELs,
DOE used discrete values, and, as required by EPCA, based the energy
use calculation on the DOE test procedure for MHLFs. In contrast, the
PBPs presented in section V.B.1 of this document were calculated using
distributions that reflect the range of energy use in the field. See
chapter 8 of the NOPD TSD for more information on the rebuttable
presumption payback analysis.
C. National Impact Analysis
This section presents DOE's estimates of NES and the NPV of
customer benefits that would result from each of the TSLs considered as
potential amended standards.
1. Significance of Energy Savings
To estimate the energy savings attributable to potential amended
standards for MHLFs, DOE compared the energy consumption under the no-
new-standards case to the anticipated energy consumption under each
TSL. The savings are measured over the entire lifetime of equipment
purchased in the 30-year period that begins in the year of anticipated
compliance with amended standards (2025-2054). Table V.14 presents
DOE's projections of the national energy savings for each TSL
considered for MHLFs. The savings were calculated using the approach
described in section IV.H.1 of this document.
Table V.14--Cumulative National Energy Savings for MHLFs; 30 Years of Shipments
[2025-2054]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Site Energy Savings (quads)........... >=50 W and <=100 W...... 0.000006 0.00004 0.00006
>100 W and <150 W....... 0.000005 0.00002 0.00003
>=150 W and <=250 W..... 0.00001 0.00007 0.00007
>250 W and <=500 W...... 0.00001 0.0001 0.0001
>500 W and <=1000 W..... 0.00001 0.00001 0.00001
>1000 W and <=2000 W.... 0.0000003 0.0000003 0.0000003
-----------------------------------------------
Total *.............. 0.00005 0.0002 0.0003
Primary Energy Savings (quads)........ >=50 W and <=100 W...... 0.00002 0.0001 0.0002
>100 W and <150 W....... 0.00001 0.00007 0.00008
>=150 W and <=250 W..... 0.00003 0.0002 0.0002
>250 W and <=500 W...... 0.00004 0.0003 0.0003
>500 W and <=1000 W..... 0.00003 0.00003 0.00003
>1000 W and <=2000 W.... 0.0000007 0.0000007 0.0000007
-----------------------------------------------
Total *.............. 0.0001 0.0007 0.0007
FFC Energy Savings (quads)............ >=50 W and <=100 W...... 0.00002 0.0001 0.0002
>100 W and <150 W....... 0.00001 0.00007 0.00009
>=150 W and <=250 W..... 0.00003 0.0002 0.0002
[[Page 47501]]
>250 W and <=500 W...... 0.00004 0.0003 0.0003
>500 W and <=1000 W..... 0.00003 0.00003 0.00003
>1000 W and <=2000 W.... 0.0000008 0.0000008 0.0000008
-----------------------------------------------
Total *.............. 0.0001 0.0007 0.0008
----------------------------------------------------------------------------------------------------------------
* Total may not equal sum due to rounding.
OMB Circular A-4 \39\ 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 9 years, rather than 30
years, of equipment 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.\40\ The review timeframe established in EPCA is generally
not synchronized with the equipment lifetime, equipment manufacturing
cycles, or other factors specific to MHLFs. Thus, such results are
presented for informational purposes only and are not indicative of any
change in DOE's analytical methodology. The NES sensitivity analysis
results based on a 9-year analytical period are presented in Table V.15
of this document. The impacts are counted over the lifetime of MHLFs
purchased in 2025-2033.
---------------------------------------------------------------------------
\39\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. https://www.whitehouse.gov/omb/circulars_a004_a-4/.
\40\ Section 325(m) of 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. A 9-year analysis period may
not be appropriate given the variability that occurs in the timing
of standards reviews and the fact that for some products, the
compliance period is 5 years rather than 3 years.
Table V.15--Cumulative National Energy Savings for MHLFs; 9 Years of Shipments
[2025-2033]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Site Energy Savings (quads)........... >=50 W and <=100 W...... 0.000006 0.00004 0.00006
>100 W and <150 W....... 0.000005 0.00002 0.00003
>=150 W and <=250 W..... 0.00001 0.00007 0.00007
>250 W and <=500 W...... 0.00001 0.0001 0.0001
>500 W and <=1000 W..... 0.00001 0.00001 0.00001
>1000 W and <=2000 W.... 0.0000003 0.0000003 0.0000003
-----------------------------------------------
Total *.............. 0.00005 0.0002 0.0003
Primary Energy Savings (quads)........ >=50 W and <=100 W...... 0.00002 0.0001 0.0002
>100 W and <150 W....... 0.00001 0.00007 0.00008
>=150 W and <=250 W..... 0.00003 0.0002 0.0002
>250 W and <=500 W...... 0.00004 0.0003 0.0003
>500 W and <=1000 W..... 0.00003 0.00003 0.00003
>1000 W and <=2000 W.... 0.0000007 0.0000007 0.0000007
-----------------------------------------------
Total *.............. 0.0001 0.0007 0.0007
FFC Energy Savings (quads)............ >=50 W and <=100 W...... 0.00002 0.0001 0.0002
>100 W and <150 W....... 0.00001 0.00007 0.00009
>=150 W and <=250 W..... 0.00003 0.0002 0.0002
>250 W and <=500 W...... 0.00004 0.0003 0.0003
>500 W and <=1000 W..... 0.00003 0.00003 0.00003
>1000 W and <=2000 W.... 0.0000008 0.0000008 0.0000008
-----------------------------------------------
Total *.............. 0.0001 0.0007 0.0008
----------------------------------------------------------------------------------------------------------------
* Total may not equal sum due to rounding.
The NES results for the 30-years and 9-years of shipments presented
in Table V.15 and Table V.16, respectively, are nearly identical due to
the significant shift to out-of-scope LED equipment that occurs over
the course of the analysis period. DOE projects that MHLF shipments
drop by more than 99 percent in 2030 relative to shipments in 2019 due
to the incursion of out-of-scope LED equipment.
[[Page 47502]]
2. 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 MHLFs. In
accordance with OMB's guidelines on regulatory analysis,\41\ DOE
calculated NPV using both a 7-percent and a 3-percent real discount
rate. Table V.16 shows the customer NPV results with impacts counted
over the lifetime of equipment purchased in 2025-2054.
---------------------------------------------------------------------------
\41\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. https://www.whitehouse.gov/omb/circulars_a004_a-4/.
Table V.16--Cumulative Net Present Value of Customer Benefits for MHLFs; 30 Years of Shipments
[2025-2054]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
3 percent (millions 2018$)............ >=50 W and <=100 W...... -0.13 -2.08 -2.11
>100 W and <150 W....... 0.012 -0.49 -1.19
>=150 W and <=250 W..... -0.19 -4.57 -4.57
>250 W and <=500 W...... -0.29 -3.33 -3.33
>500 W and <=1000 W..... -0.077 -0.077 -0.077
>1000 W and <=2000 W.... 0.00026 0.00026 0.00026
-----------------------------------------------
Total *.............. -0.68 -10.54 -11.29
7 percent (millions 2018$)............ >=50 W and <=100 W...... -0.10 -1.14 -1.20
>100 W and <150 W....... -0.0022 -0.28 -0.76
>=150 W and <=250 W..... -0.15 -2.83 -2.83
>250 W and <=500 W...... -0.22 -2.83 -2.83
>500 W and <=1000 W..... -0.071 -0.071 -0.071
>1000 W and <=2000 W.... -0.0010 -0.0010 -0.0010
-----------------------------------------------
Total *.............. -0.54 -7.16 -7.70
----------------------------------------------------------------------------------------------------------------
* Total may not equal sum due to rounding.
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V.17 of this document. The impacts are
counted over the lifetime of equipment purchased in 2025-2033. As
mentioned previously, such results are presented for informational
purposes only and are not indicative of any change in DOE's analytical
methodology or decision criteria.
Table V.17--Cumulative Net Present Value of Customer Benefits for MHLFs; 9 Years of Shipments
[2025-2033]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
3 percent (millions 2018$)............ >=50 W and <=100 W...... -0.13 -2.07 -2.11
>100 W and <150 W....... 0.012 -0.48 -1.19
>=150 W and <=250 W..... -0.19 -4.56 -4.56
>250 W and <=500 W...... -0.29 -3.32 -3.32
>500 W and <=1000 W..... -0.077 -0.077 -0.077
>1000 W and <=2000 W.... 0.00026 0.00026 0.00026
-----------------------------------------------
Total *.............. -0.68 -10.52 -11.26
7 percent (millions 2018$)............ >=50 W and <=100 W...... -0.10 -1.14 -1.20
>100 W and <150 W....... 0.00 -0.28 -0.76
>=150 W and <=250 W..... -0.15 -2.83 -2.83
>250 W and <=500 W...... -0.22 -2.83 -2.83
>500 W and <=1000 W..... -0.071 -0.071 -0.071
>1000 W and <=2000 W.... -0.00095 -0.00095 -0.00095
-----------------------------------------------
Total *.............. -0.54 -7.15 -7.68
----------------------------------------------------------------------------------------------------------------
* Total may not equal sum due to rounding.
The NPV results for the 30-years and 9-years of shipments presented
in Table V.16 and Table V.17, respectively, are nearly identical due to
the significant shift to out-of-scope LED equipment that occurs over
the course of the analysis period. The previous results reflect DOE's
assumption of no price trend over the analysis period (see section
IV.G).
D. Proposed Determination
When considering amended energy conservation standards, the
standards that DOE adopts for any type (or class) of covered equipment
must be designed to achieve the maximum improvement in energy
efficiency that the Secretary determines is technologically feasible
and economically justified. (42 U.S.C.
[[Page 47503]]
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 by, to the greatest extent practicable,
considering the seven statutory factors discussed previously. (42
U.S.C. 6295(o)(2)(B)(i)) The new or amended standard must also result
in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B))
For this NOPD, DOE considered the impacts of amended standards for
MHLFs at analyzed TSLs, beginning with the maximum technologically
feasible level, to determine whether that level would result in a
significant conservation of energy. DOE also considered whether that
level was economically justified. Where the max-tech level was not
economically justified, DOE then considered the next most efficient
level and undertook the same evaluation.
Because an analysis of potential energy savings and economic
justification first requires an evaluation of the relevant technology,
in the following sections DOE first discusses the technological
feasibility of amended standards. DOE then addresses the energy savings
and economic justification associated with potential amended standards.
1. Technological Feasibility
EPCA mandates that DOE consider whether amended energy conservation
standards for MHLFs would be technologically feasible. (42 U.S.C.
6295(o)(2)(A) and (3)(B)) DOE has tentatively determined that there are
technology options that would improve the efficiency of ballasts
contained within MHLFs. These technology options are being used in
commercially available MHLFs and therefore are technologically
feasible. (See section IV.B.4 for further information.) Hence, DOE has
tentatively determined that amended energy conservation standards for
MHLFs are technologically feasible.
2. Significant Conservation of Energy
EPCA also mandates that DOE consider whether amended energy
conservation standards for MHLF would result in significant energy
savings. (42 U.S.C. 6295(o)(3)(B)) On February 14, 2020 DOE issued a
final rule that defined a significant energy savings threshold
(``Process Rule''). 85 FR 8626. The Process Rule establishes a two-step
process for determining the significance of energy savings using an
absolute and percentage threshold. Section 6 of the Process Rule. DOE
first evaluates whether standards at the max-tech level would result in
a minimum site-energy savings of 0.3 quads over a 30-year period.
Section 6(b)(2) of the Process Rule. If the 0.3 quad threshold is not
met, DOE then evaluates whether energy savings at the max-tech level
represent at least 10 percent of the total energy usage of the covered
equipment over a 30-year period. Section 6(b)(3) of the Process Rule.
If the percentage threshold is not met, DOE proposes to determine that
no significant energy savings would likely result from setting amended
standards. Section 6(b)(4) of the Process Rule.
In this analysis, DOE estimates that amended standards for MHLFs
would result in site energy savings of 0.0003 quads at max-tech levels
over a 30-year analysis period (2025-2054). (See results in Table
V.14.) Because the site energy savings do not meet the 0.3 quads
threshold set forth in Section 6(b)(2) of the Process Rule, DOE
compared the max-tech savings to the total energy usage to calculate a
percentage reduction in energy usage. This comparison yielded a
reduction in site energy use of 3.6 percent over a 30-year period.
Because the reduction in site energy use is less than 10 percent as set
forth in Section 6(b)(3) and (4) of the Process Rule, DOE determined
that amended standards for metal halide lamp fixtures would not result
in significant energy savings.
3. Economic Justification
In determining whether a standard is economically justified, the
Secretary must determine whether the benefits of the standard exceed
its burdens, considering to the greatest extent practicable the seven
statutory factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i))
One of those seven factors is 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 standard. This factor is assessed using the life cycle
cost and payback period analysis, discussed in section IV.F, and the
national net present value, discussed in section IV.H.2 of this
document.
At TSL 3, TSL 2, and TSL 1 the average LCC savings are negative for
all equipment classes (see section V.B.1 of this document). The NPV
benefits at these TSLs are also negative for all equipment classes at
the 3-percent and 7-percent discount rates except for the >1000 W and
<=2000 W equipment class which has positive NPV of $0.00026 million at
the 3-percent discount rate (see section V.C.2 of this document).
Additionally, the simple payback periods are much higher than the
average fixture lifetime with the exception of the >100 W and <150 W
equipment class at EL 1 and EL 2 and for the >1000 W and <=2000 W
equipment class at EL 1.
Based on these negative LCC and predominantly negative NPV (i.e.,
the second EPCA factor of savings in operating costs), DOE has
tentatively determined that any potential positive impact of the other
statutory factors would not outweigh the increased costs to consumers.
Hence DOE has tentatively determined that amended standards at the TSLs
under consideration are not economically justified.
4. Summary
In this proposed determination, DOE has tentatively determined that
amended standards for MHLF would not result in significant conservation
of energy or be economically justified. Hence, DOE's initial
determination is to not amend standards for MHLFs. DOE requests
comments on its initial determination that energy conservation
standards should not be amended for MHLFs.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
This proposed determination has been determined to be not
significant for purposes of Executive Order (E.O.) 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993). As a result, OMB did
not review this proposed determination.
B. Review Under Executive Orders 13771 and 13777
On January 30, 2017, the President issued E.O. 13771, ``Reducing
Regulation and Controlling Regulatory Costs.'' 82 FR 9339 (Feb. 3,
2017). E.O. 13771 stated the policy of the executive branch is to be
prudent and financially responsible in the expenditure of funds, from
both public and private sources. E.O. 13771 stated it is essential to
manage the costs associated with the governmental imposition of private
expenditures required to comply with Federal regulations.
Additionally, on February 24, 2017, the President issued E.O.
13777, ``Enforcing the Regulatory Reform Agenda.'' 82 FR 12285 (March
1, 2017). E.O. 13777 required the head of each agency to designate an
agency official as its Regulatory Reform Officer (``RRO''). Each RRO
oversees the implementation of regulatory reform initiatives and
policies to ensure that agencies
[[Page 47504]]
effectively carry out regulatory reforms, consistent with applicable
law. Further, E.O. 13777 requires the establishment of a regulatory
task force at each agency. The regulatory task force is required to
make recommendations to the agency head regarding the repeal,
replacement, or modification of existing regulations, consistent with
applicable law. At a minimum, each regulatory reform task force must
attempt to identify regulations that:
(i) Eliminate jobs, or inhibit job creation;
(ii) Are outdated, unnecessary, or ineffective;
(iii) Impose costs that exceed benefits;
(iv) Create a serious inconsistency or otherwise interfere with
regulatory reform initiatives and policies;
(v) Are inconsistent with the requirements of Information Quality
Act, or the guidance issued pursuant to that Act, in particular those
regulations that rely in whole or in part on data, information, or
methods that are not publicly available or that are insufficiently
transparent to meet the standard for reproducibility; or
(vi) Derive from or implement Executive Orders or other
Presidential directives that have been subsequently rescinded or
substantially modified.
DOE initially concludes that this proposed determination is
consistent with the directives set forth in these executive orders.
As discussed in this document, DOE is proposing to not amend energy
conservation standards for MHLFs. Therefore, if finalized as proposed,
this determination is expected to be an E.O. 13771 other action.
C. 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, unless
the agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by E.O. 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (Aug. 16, 2002), DOE published
procedures and policies on February 19, 2003, to ensure that the
potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's website (https://energy.gov/gc/office-general-counsel).
DOE reviewed this proposed determination under the provisions of
the Regulatory Flexibility Act and the policies and procedures
published on February 19, 2003. Because DOE is not proposing to amend
standards for MHLFs, if finalized, the determination would not amend
any energy conservation standards. On the basis of the foregoing, DOE
certifies that the proposed determination, if finalized, would have no
significant economic impact on a substantial number of small entities.
Accordingly, DOE has not prepared an IRFA for this proposed
determination. DOE will transmit this certification and supporting
statement of factual basis to the Chief Counsel for Advocacy of the
Small Business Administration for review under 5 U.S.C. 605(b).
D. Review Under the National Environmental Policy Act
DOE is analyzing this proposed action in accordance with the
National Environmental Policy Act (``NEPA'') and DOE's NEPA
implementing regulations (10 CFR part 1021). DOE's regulations include
a categorical exclusion for actions which are interpretations or
rulings with respect to existing regulations. 10 CFR part 1021, subpart
D, appendix A4. DOE anticipates that this action qualifies for
categorical exclusion A4 because it is an interpretation or ruling in
regards to an existing regulation and otherwise meets the requirements
for application of a categorical exclusion. See 10 CFR 1021.410. DOE
will complete its NEPA review before issuing the final action.
E. Review Under Executive Order 13132
E.O. 13132, ``Federalism,'' 64 FR 43255 (Aug. 10, 1999), imposes
certain requirements on Federal agencies formulating and implementing
policies or regulations that preempt State law or that have federalism
implications. The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive Order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed determination
and has tentatively determined that it would not have a substantial
direct effect on the States, on the relationship between the national
government and the States, or on the distribution of power and
responsibilities among the various levels of government. EPCA governs
and prescribes Federal preemption of State regulations as to energy
conservation for the products that are the subject of this proposed
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)
Therefore, no further action is required by E.O. 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 E.O. 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, (3) provide a
clear legal standard for affected conduct rather than a general
standard, and (4) promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Regarding the review required by section 3(a),
section 3(b) of E.O. 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 proposed determination meets
the relevant standards of E.O. 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 proposed regulatory action likely to
[[Page 47505]]
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 proposed ``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 them. 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 https://energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
This proposed determination does not contain a Federal
intergovernmental mandate, nor is it expected to require expenditures
of $100 million or more in any one year by the private sector. As a
result, the analytical requirements of UMRA do not apply.
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 proposed determination 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
Pursuant to E.O. 12630, ``Governmental Actions and Interference
with Constitutionally Protected Property Rights,'' 53 FR 8859 (Mar. 15,
1988), DOE has determined that this proposed determination 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 information
quality 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 this NOPD 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
E.O. 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 proposed 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 Executive 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 proposed
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.
Because this proposed determination does not propose amended energy
conservation standards for MHLFs, it is not a significant energy
action, nor has it been designated as such by the Administrator at
OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects.
L. Information Quality
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.'' Id. at 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal peer reviews of
the energy conservation standards development process and the analyses
that are typically used and has prepared a report describing that peer
review.\42\ 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.
DOE has determined that the peer-reviewed analytical process continues
to reflect current practice, and the Department followed that process
for developing energy conservation standards in the case of the present
action.
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\42\ ``Energy Conservation Standards Rulemaking Peer Review
Report.'' 2007. Available at https://energy.gov/eere/buildings/downloads/energy-conservation-standards-rulemaking-peer-review-report-0.
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VII. Public Participation
A. Participation in the Webinar
The time and date of the webinar are listed in the DATES section at
the beginning of this document. If no participants register for the
webinar then it will be cancelled. Webinar registration information,
participant instructions, and information about the capabilities
available to webinar participants will be published on DOE's website:
https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=14. Participants are responsible for ensuring
their systems are compatible with the webinar software.
Additionally, you may request an in-person meeting to be held prior
to the close of the request period provided in the DATES section of
this document. Requests for an in-person meeting may be made by
contacting Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
B. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed determination no later than the date provided in the DATES
section at the
[[Page 47506]]
beginning of this proposed determination. Interested parties may submit
comments, data, and other information using any of the methods
described in the ADDRESSES section at the beginning of this document.
Submitting comments via https://www.regulations.gov. The https://www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to https://www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through https://www.regulations.gov cannot be claimed as CBI. Comments
received through the website will waive any CBI claims for the
information submitted. For information on submitting CBI, see the
Confidential Business Information section.
DOE processes submissions made through https://www.regulations.gov
before posting. Normally, comments will be posted within a few days of
being submitted. However, if large volumes of comments are being
processed simultaneously, your comment may not be viewable for up to
several weeks. Please keep the comment tracking number that https://www.regulations.gov provides after you have successfully uploaded your
comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to https://www.regulations.gov. If you do not want your personal contact
information to be publicly viewable, do not include it in your comment
or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. With this
instruction followed, the cover letter will not be publicly viewable as
long as it does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible, in which case it is not necessary to submit printed copies.
No faxes will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
one copy of the document marked ``confidential'' including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
C. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposed
determination, DOE is particularly interested in receiving comments and
views of interested parties concerning the following issues:
(1) DOE requests comment on the ELs under consideration for the
equipment classes, including the max-tech levels. See section IV.C.4
and IV.C.6 of this document.
(2) DOE requests comment on the methodology and resulting MSPs
developed for all equipment classes. See section IV.C.7 of this
document.
(3) DOE welcomes any relevant data and comments on the markups
analysis methodology. See section IV.D.3 of this document.
(4) DOE welcomes any relevant data and comments on the life-cycle
cost and payback period analysis methodology. See section IV.F of this
document.
(5) DOE welcomes any relevant data and comments on the shipments
analysis methodology. See section IV.G of this document.
(6) DOE requests comments on its initial determination that energy
conservation standards should not be adopted for MHLFs. See section
V.D.4 of this document.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this document
of proposed determination.
Signing Authority
This document of the Department of Energy was signed on June 30,
2020, by Daniel R Simmons, Assistant Secretary, Office Energy
Efficiency and Renewable Energy, pursuant to delegated authority from
the Secretary of Energy. That document with the original signature and
date is maintained by DOE. For administrative purposes only, and in
compliance with requirements of the Office of the Federal Register, the
undersigned DOE Federal Register Liaison Officer has been authorized to
sign and submit the document in electronic format for publication, as
an official document of the Department of Energy. This administrative
process in no way alters the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on July 1, 2020.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
[FR Doc. 2020-14540 Filed 8-4-20; 8:45 am]
BILLING CODE 6450-01-P
