Energy Conservation Program: Energy Conservation Standards for Metal Halide Lamp Fixtures
Federal RegisterFeb 10, 2014
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DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE-2009-BT-STD-0018]
RIN 1904-AC00
Energy Conservation Program: Energy Conservation Standards for Metal Halide Lamp Fixtures
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including metal halide lamp fixtures (MHLFs). EPCA also requires the U.S. Department of Energy (DOE) to determine whether more-stringent standards would be technologically feasible and economically justified, and would save a significant amount of energy. In this final rule, DOE is adopting more-stringent energy conservation standards for MHLFs. It has determined that the new and amended energy conservation standards for this equipment would result in significant conservation of energy, and are technologically feasible and economically justified.
DATES:
The effective date of this rule is April 11, 2014. Compliance with the new and amended standards established for MHLFs in today's final rule is required by February 10, 2017.
The incorporation by reference of certain publications listed in this rule is approved by the Director of the Federal Register on April 11, 2014.
ADDRESSES:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the regulations.gov index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16
. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 287-1604. Email:
metal_halide_lamp_fixtures@ee.doe.gov
.
Mr. Ari Altman, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 287-6307. Email:
ari.altman@hq.doe.gov
.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Final Rule and Its Benefits
A. Benefits and Costs to Customers
B. Impact on Manufacturers
C. National Benefits
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for MHLFs
3. Compliance Date
III. Issues Affecting the Scope of This Rulemaking
A. Additional MHLFs for Which DOE Is Setting Standards
1. EISA 2007 Exempted MHLFs
a. MHLFs With Regulated-Lag Ballasts
b. MHLFs With 480 V Electronic Ballasts
c. Exempted 150 W MHLFs
2. Additional Wattages
3. General Lighting
4. High-Frequency Electronic Ballasts
5. Outdoor Fixtures
6. Hazardous Locations
7. Summary of MHLFs for Which DOE Is Setting Standards
B. Alternative Approaches to Energy Conservation Standards: System Approaches
C. Standby Mode and Off Mode Energy Consumption
IV. General Discussion
A. Test Procedures
1. Current Test Procedures
2. Test Input Voltage
a. Average of Tested Efficiency at All Possible Voltages
b. Posting the Highest and Lowest Efficiencies
c. Test at Single Manufacturer-Declared Voltage
d. Test at Highest Rated Voltage
e. Test on Input Voltage Based on Wattage and Available Voltages
3. Testing High-Frequency Electronic Ballasts
4. Rounding Requirements
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Customers
b. Savings in Operating Costs Compared to Increase in Price
c. Energy Savings
d. Lessening of Utility or Performance of Equipment
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
V. Methodology and Discussion
A. Market and Technology Assessment
1. General
2. Equipment Classes
a. Input Voltage
b. Lamp Wattage
c. Fixture Application
d. Electronic Configuration
e. Circuit Type
f. Summary
B. Screening Analysis
C. Engineering Analysis
1. Approach
2. Representative Equipment Classes
3. Representative Wattages
4. Representative Fixture Types
5. Ballast Efficiency Testing
6. Input Power Representations
7. Baseline Ballast Models
a. 70 W Baseline Ballast
b. 1000 W Baseline Ballast
c. 1500 W Baseline Ballast
d. Summary of Baseline Ballasts
8. Selection of More-Efficient Units
a. Higher-Efficiency Magnetic Ballasts
b. Electronic Ballasts
9. Efficiency Levels
10. Design Standard
11. Scaling to Equipment Classes Not Analyzed
12. Manufacturer Selling Prices
a. Manufacturer Production Costs
b. Empty Fixture Costs
c. Incremental Costs for Electronically Ballasted MHLFs
d. Costs Associated With the Design Standard
e. Manufacturer Markups
D. Markups to Determine Equipment Price
1. Distribution Channels
2. Estimation of Markups
3. Summary of Markups
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Use
4. Energy Prices
5. Energy Price Projections
6. Replacement Costs
7. Equipment Lifetime
8. Discount Rates
9. Analysis Period Fixture Purchasing Events
G. National Impact Analysis—National Energy Savings and Net Present Value Analysis
1. Shipments
a. Historical Shipments
b. Fixture Stock Projections
c. Base Case Shipment Scenarios
d. Standards-Case Efficiency Scenarios
2. Site-to-Source Energy Conversion
H. Customer Subgroup Analysis
I. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipment Projections
3. Markup Scenarios
4. Production and Capital Conversion Costs
5. Other Comments From Interested Parties
a. Compliance Period
b. Alternative Technologies
c. Opportunity Cost of Investments
d. Replacement Ballast Market
e. Potential Impact on Metal Halide Lamp Manufacturers
6. Manufacturer Interviews
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
VI. Other Issues for Discussion
A. Proposed Standard Levels in August 2013 NOPR
B. Reported Value
C. Three-Year Compliance Date
VII. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Customers
a. Life-Cycle Cost and Payback Period
b. Customer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Customer Costs and Benefits
c. Impacts on Employment
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
C. Conclusions
1. Trial Standard Level 5
2. Trial Standard Level 4
3. Trial Standard Level 3
4. Trial Standard Level 2
D. Final Standard Equations
E. Backsliding
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. Metal Halide Ballast and Fixture Industry Structure
d. Comparison Between Large and Small Entities
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
M. Congressional Notification
IX. Approval of the Office of the Secretary
I. Summary of the Final Rule and Its Benefits
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy Conservation Program for Consumer Products Other Than Automobiles.
2
Pursuant to EPCA, any new or amended energy conservation standard that DOE prescribes for certain equipment, such as metal halide lamp fixtures (MHLFs or “fixtures”
3
), shall be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other statutory provisions discussed in this notice, DOE is adopting new and amended energy conservation standards for MHLFs. The new and amended standards, which are the minimum allowable ballast efficiencies
4
based on fixture location, ballast type, and rated lamp wattage, are shown in Table I.1. These new and amended standards apply to all equipment listed in Table I.1 and manufactured in, or imported into, the United States on or after the compliance date in the
DATES
section of this notice (additionally, see section II.B.3 of this notice for more information on the compliance date determination).
1
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
2
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18, 2012).
3
The scope of this rulemaking encompasses entire MHLFs, including the metal halide lamps and metal halide ballasts the fixtures contain. Therefore, the ratings of individual components are often discussed at a system level. For example, when referring to the rated wattages or available input voltages of the lamps and ballasts a fixture is designed to operate with, this final rule frequently uses shorthand such as “100 W ballast” for a ballast operating a lamp rated at 100 watts or “480 V fixture” for a fixture housing a ballast with a dedicated input voltage of 480 volts.
4
DOE is proposing to continue using a ballast efficiency metric for regulation of MHLFs, rather than a system or other approach. See section 0 for further discussion.
Table I.1—Energy Conservation Standards for MHLFs
Designed to be operated with lamps of the following rated lamp wattage
Indoor/outdoor
Test input voltage †
Minimum standard equation ‡
%
≥50 W and ≤100 W
Indoor
480 V
(1/(1+1.24×P^(−0.351))) − 0.0200.
≥50 W and ≤100 W
Indoor
All others
1/(1+1.24×P^(−0.351)).
≥50 W and ≤100 W
Outdoor
480 V
(1/(1+1.24×P^(−0.351))) − 0.0200.
≥50 W and ≤100 W
Outdoor
All others
1/(1+1.24×P(−0.351)).
>100 W and <150 W *
Indoor
480 V
(1/(1+1.24×P^(−0.351))) − 0.0200.
>100 W and <150 W *
Indoor
All others
1/(1+1.24×P^(−0.351)).
>100 W and <150 W *
Outdoor
480 V
(1/(1+1.24×P^(−0.351))) − 0.0200.
>100 W and <150 W *
Outdoor
All others
1/(1+1.24×P^(−0.351)).
≥150 W ** and ≤250 W
Indoor
480 V
0.880.
≥150 W ** and ≤250 W
Indoor
All others
For ≥150 W and ≤200 W: 0.880.
For >200 W and ≤250 W:
1/(1+0.876×P^(−0.351)).
≥150 W ** and ≤250 W
Outdoor
480 V
0.880.
≥150 W ** and ≤250 W
Outdoor
All others
For ≥150 W and ≤200 W: 0.88.
For >200 W and ≤250 W:
1/(1+0.876×P^(−0.351)).
>250 W and ≤500 W
Indoor
480 V
For >250 W and <265 W: 0.880.
For ≥265 W and ≤500 W: (1/(1+0.876×P^(−0.351))) − 0.0100.
>250 W and ≤500 W
Indoor
All others
1/(1+0.876×P^(−0.351)).
>250 W and ≤500 W
Outdoor
480 V
For >250 W and <265 W: 0.880.
For ≥265 W and ≤500 W: (1/(1+0.876×P^(−0.351))) − 0.0100.
>250 W and ≤500 W
Outdoor
All others
1/(1+0.876×P^(−0.351)).
>500 W and ≤1000 W
Indoor
480 V
>500 W and ≤750 W: 0.900.
>750 W and ≤1000 W:
0.000104×P + 0.822.
For >500 W and ≤1000 W: may not utilize a probe-start ballast.
>500 W and ≤1000 W
Indoor
All others
For >500 W and ≤750 W: 0.910.
For >750 W and ≤1000 W: 0.000104×P+0.832.
For >500 W and ≤1000 W: may not utilize a probe-start ballast.
>500 W and ≤1000 W
Outdoor
480 V
>500 W and ≤750 W: 0.900.
>750 W and ≤1000 W:
0.000104×P + 0.822.
For >500 W and ≤1000 W: may not utilize a probe-start ballast.
>500 W and ≤1000 W
Outdoor
All others
For >500 W and ≤750 W: 0.910.
For >750 W and ≤1000 W: 0.000104×P+0.832.
For >500 W and ≤1000 W: may not utilize a probe-start ballast.
* Includes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
** Excludes 150 W fixtures specified in paragraph (b)(3) of this section, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
† Tested input voltage is specified in 10 CFR 431.324.
‡ P is defined as the rated wattage of the lamp the fixture is designed to operate.
A. Benefits and Costs to Customers
Table I.2 presents DOE's evaluation of the economic impacts of today's standards on customers of MHLFs, as measured by the average life-cycle cost (LCC) savings and the median payback period. The average LCC savings are positive for a majority of users for all equipment classes.
Table I.2—Impacts of Today's Standards on Customers of MHLFs
*
Representative equipment class
Representative
wattage
Average LCC savings
2012$
Median
payback
period
years
≥50 W and ≤100 W (indoor, magnetic baseline)
70 W
27.00
4.5
≥50 W and ≤100 W (outdoor, magnetic baseline)
70 W
34.88
4.5
>100 W and <150 W ** (indoor)
150 W
24.63
7.3
>100 W and <150 W ** (outdoor)
150 W
30.70
8.1
≥150 W † and ≤250 W (indoor)
250 W
4.51
14.2
≥150 W † and ≤250 W (outdoor)
250 W
6.74
17.4
>250 W and ≤500 W (indoor)
400 W
7.95
15.0
>250 W and ≤500 W (outdoor)
400 W
13.15
18.4
>500 W and ≤1000 W (indoor)
1000 W
1221.54
0.8
>500 W and ≤1000 W (outdoor)
1000 W
1631.94
0.8
* On average, indoor and outdoor fixtures have 20- and 25-year lifetimes, respectively.
** Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2001.
† Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2001.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2014 to 2046). Using a real discount rate of 8.9 percent, DOE estimates that the base case INPV for manufacturers of MH ballasts ranges from $67 million in the low-shipment scenario to $74 million in the high-shipment scenario in 2012$. Under today's standards, DOE expects that ballast manufacturers may lose up to 26.7 percent of their INPV, which is approximately $17.9 million, in the low-shipment, preservation of operating profit markup scenario.
For MHLF, using a real discount rate of 9.5 percent, DOE estimates that the base case INPV for manufacturers of MHLFs ranges from $346 million in the low-shipment
scenario to $379 million in the high-shipment scenario in 2012$. Under today's standards, DOE expects that MHLF manufacturers may lose up to 1.0 percent of their INPV, which is approximately $3.6 million, in the low-shipment, preservation of operating profit markup scenario.
When adding these two MH industries together (MHLF and MH ballast), DOE estimates that the combined base case INPV for manufacturers of MHLFs and MH ballasts ranges from $413 million in the low-shipment scenario to $453 million in the high-shipment scenario in 2012$. Under today's standards, DOE expects that all MH manufacturers (MHLF and MH ballast manufacturers) may lose up to 5.2 percent of their INPV, which is approximately $21.5 million, in the low-shipment, preservation of operating profit markup scenario.
Additionally, based on DOE's interviews with manufacturers of MHLFs and ballasts, DOE does not expect any plant closings or significant loss of employment.
C. National Benefits
5
5
All monetary values in this section are expressed in 2012 dollars and are discounted to 2013. Value ranges correspond with estimates for the low and high shipment scenarios.
DOE's analyses indicate that today's standards would save a significant amount of energy. The lifetime savings for MHLFs purchased in the 30-year period that begins in the year of compliance with new and amended standards (2017-2046) amount to 0.39-0.49 quads.
The cumulative net present value (NPV) of total customer costs and savings of today's standards for MHLFs ranges from $0.29 billion (at a 7-percent discount rate, low shipments scenario) to $1.1 billion (at a 3-percent discount rate, high shipments scenario). This NPV expresses the estimated total value of future operating cost savings minus the estimated increased equipment costs for equipment purchased in 2017-2046.
In addition, today's standards would have significant environmental benefits. The energy savings would result in cumulative greenhouse gas emission reductions of approximately 22.5-27.8 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 105.9-132.4 thousand tons of methane, 0.5-0.6 thousand tons of nitrous oxide (N
2
O), 37.5-47.2 thousand tons of sulfur dioxide (SO
2
), 28.2-35.0 tons of nitrogen oxides (NO
X
) and 0.05-0.06 tons of mercury (Hg).
3
Through 2030, the estimated energy savings would result in cumulative emissions reductions of 6.3-6.8 Mt of CO
2
.
6
A metric ton is equivalent to 1.1 short tons. Results for NO
X
and Hg are presented in short tons.
3
DOE calculated emissions reductions relative to the
Annual Energy Outlook
(
AEO
) 2013 Reference case, which generally represents current legislation and environmental regulations for which implementing regulations were available as of December 31, 2012.
The value of the CO
2
reductions is calculated using a range of values per metric ton of CO
2
(otherwise known as the Social Cost of Carbon or SCC) developed by a recent interagency process.
7
The derivation of the SCC values is discussed in section V.M. Using discount rates appropriate for each set of SCC values, DOE estimates that the net present monetary value of the CO
2
emissions reductions is between $0.15 billion and $2.55 billion. DOE also estimates that the net present monetary value of the NO
X
emissions reductions is $17.34 million at a 7-percent discount rate, and $44.20 million at a 3-percent discount rate.
8
7
Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency Working Group on Social Cost of Carbon, United States Government. May 2013 (Revised November 2013).
www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf
.
8
DOE is currently investigating valuation of avoided Hg and SO
2
emissions.
Table I.3 summarizes the national economic costs and benefits expected to result from today's standards for MHLFs.
Table I.3—Summary of National Economic Benefits and Costs of MHLF Energy Conservation Standards *
Category
Present value
million 2012$
Discount rate
(%)
Benefits
Operating Cost Savings
754
7
1,636
3
CO
2
Reduction Monetized Value ($11.8/t case) **
146
5
CO
2
Reduction Monetized Value ($39.7/t case) **
682
3
CO
2
Reduction Monetized Value ($61.2/t case) **
1,088
2.5
CO
2
Reduction Monetized Value ($117/t case) **
2,106
3
NO
X
Reduction Monetized Value (at $2639/ton) **
17
7
37
3
Total Benefits †
1,453
7
2,355
3
Costs
Incremental Installed Costs
465
7
721
3
Net Benefits
Including CO
2
and NO
X
† Reduction Monetized Value
988
7
1,634
3
* This table presents the primary (low shipments scenario) estimate of costs and benefits associated with fixtures shipped in 2017-2046. These results include benefits to customers which accrue after 2047 from the equipment purchased in 2017-2046. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The value for NO
X
is the average of the low and high values used in DOE's analysis.
† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with a 3-percent discount rate.
The benefits and costs of today's standards, for equipment sold in 2017-2046, can also be expressed in terms of annualized values. The annualized monetary values are the sum of (1) the annualized national economic value of the benefits from operating the equipment (consisting primarily of operating cost savings from using less energy, minus increases in equipment purchase and
installation costs, which is another way of representing customer NPV), plus (2) the annualized monetary value of the benefits of emission reductions, including CO
2
emission reductions.
9
9
DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total customer costs and savings, for the time-series of costs and benefits using discount rates of 3 and 7 percent for all costs and benefits except for the value of CO
2
reductions. For the latter, DOE used a range of discount rates, as shown in Table I.3. From the present value, DOE then calculated the fixed annual payment over a 30-year period (2017 through 2046) that yields the same present value. The fixed annual payment is the annualized value. Although DOE calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized values were determined is a steady stream of payments.
Although adding the value of customer savings to the values of emission reductions provides a valuable perspective, two issues should be considered. First, the national operating cost savings are domestic U.S. customer monetary savings that occur as a result of market transactions, while the value of CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
savings are performed with different methods that use different time frames for analysis. The national operating cost savings is measured for the lifetime of MHLFs shipped in 2017-2046. The SCC values, on the other hand, reflect the present value of all future climate-related impacts resulting from the emission of one metric ton of carbon dioxide in each year. These impacts continue well beyond 2100.
Estimates of annualized benefits and costs of today's standards are shown in Table I.4. The results under the primary estimate are as follows. Using a 7-percent discount rate for benefits and costs other than CO
2
reduction, for which DOE used a 3-percent discount rate along with the average SCC series that uses a 3-percent discount rate, the cost of the standards in today's rule is $46 million per year in increased equipment costs, while the benefits are $74 million per year in reduced equipment operating costs, $38 million in CO
2
reductions, and $1.71 million in reduced NO
X
emissions. In this case, the net benefit amounts to $68 million per year. Using a 3-percent discount rate for all benefits and costs and the average SCC series, the cost of the standards in today's rule is $40 million per year in increased equipment costs, while the benefits are $91 million per year in reduced operating costs, $38 million in CO
2
reductions, and $2.07 million in reduced NO
X
emissions. In this case, the net benefit amounts to $91 million per year.
Table I.4—Annualized Benefits and Costs of New and Amended Standards for MHLFs
Discount rate
Primary (low) net
benefits estimate *
Million 2012$/year
High net benefits
estimate *
Million 2012$/year
Benefits
Operating Cost Savings
7%
74
92
3%
91
119
CO
2
Reduction at ($11.8 case) **
5%
11
13
CO
2
Reduction at ($39.7/t case) **
3%
38
46
CO
2
Reduction at ($61.2/t case) **
2.5%
56
68
CO
2
Reduction at ($117.0/t case) **
3%
117
142
NO
X
Reduction at ($2639/ton) **
7%
1.71
1.95
3%
2.07
2.46
Total Benefits†
7% plus CO
2
range
87 to 194
107 to 236
7%
114
140
3%
131
168
3% plus CO
2
range
104 to 211
135 to 264
Costs
Incremental Product Costs
7%
46
52
3%
40
48
Net Benefits
Total †
7% plus CO
2
range
41 to 148
54 to 184
7%
68
87
3%
91
120
3% plus CO
2
range
64 to 171
87 to 216
* This table presents the annualized costs and benefits associated with fixtures shipped in 2017-2046. These results include benefits to consumers which accrue after 2046 from the fixtures purchased from 2017-2046. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary (Low) and High Benefits Estimates utilize projections of energy prices from the
AEO2013
Reference case and High Estimate, respectively. The Primary (Low) and High Benefits Estimates are also based on projected fixture shipments in the Low Shipments, Roll-up and High Shipments, Roll-up scenarios, respectively. In addition, the Primary (Low) estimate uses incremental equipment costs that assume fixed equipment prices throughout the analysis period. The High estimate uses incremental equipment costs that reflect a declining trend for equipment prices, using
AEO
price trends (deflators). The methods used to derive projected price trends are explained in section V.F.1.
** The CO
2
values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series used by DOE incorporate an escalation factor. The value for NO
X
is the average of the low and high values used in DOE's analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount rate. In the rows labeled “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
D. Conclusion
Based on the analyses culminating in this final rule, DOE found the benefits to the nation of the standards (energy savings, customer LCC savings, positive NPV of customer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some users of this equipment). DOE has concluded that the standards in
today's final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy.
II. Introduction
The following section briefly discusses the statutory authority underlying today's final rule, as well as some of the relevant historical background related to the establishment of standards for MHLFs.
A. Authority
Title III, Part B
10
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy Conservation Program for Consumer Products Other Than Automobiles, a program covering most major household appliances (collectively referred to as “covered equipment”),
11
which includes the types of MHLFs that are the subject of this rulemaking. (42 U.S.C. 6292(a)(19)) EPCA, as amended by the Energy Independence and Security Act of 2007 (EISA 2007) prescribes energy conservation standards for this equipment (42 U.S.C. 6295(hh)(1)), and directs DOE to conduct a rulemaking to determine whether to amend these standards. (42 U.S.C. 6295(hh)(2)(A)) DOE notes that under 42 U.S.C. 6295(hh)(3)(A), the agency must conduct a second review of energy conservation standards for MHLFs and publish a final rule no later than January 1, 2019.
10
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
11
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18, 2012).
Pursuant to EPCA, DOE's energy conservation program for covered equipment consists essentially of four parts: (1) Testing; (2) labeling; (3) the establishment of federal energy conservation standards; and (4) certification and enforcement procedures. The Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of the program. Subject to certain criteria and conditions, DOE is required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of covered equipment. (42 U.S.C. 6293) Manufacturers of covered equipment must use the prescribed DOE test procedure as the basis for certifying to DOE that their equipment complies with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of that equipment. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures to determine whether the equipment complies with standards adopted pursuant to EPCA.
Id.
DOE test procedures for MHLFs currently appear at title 10 of the Code of Federal Regulations (CFR) section 431.324.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered equipment. As indicated above, any new or amended standard for covered equipment must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) For certain equipment, including MHLFs, if no test procedure has been established for the equipment, or (2) if DOE determines by rule that the new or amended standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a new or amended standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven factors:
1. The economic impact of the standard on manufacturers and customers of the equipment subject to the standard;
2. The savings in operating costs throughout the estimated average life of the covered equipment in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered equipment that are likely to result from the imposition of the standard;
3. The total projected amount of energy, or as applicable, water, savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered equipment likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any new or amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of covered equipment. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States of any covered equipment type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the customer of purchasing equipment complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the customer will receive as a result of the standard, as calculated under the applicable test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii).
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a standard for a type or class of covered equipment that has two or more subcategories. DOE must specify a different standard level than that which applies generally to such type or class of equipment for any group of covered equipment that has the same function or intended use if DOE determines that equipment within such group (A) consumes a different kind of energy from that consumed by other covered equipment within such type (or class); or (B) has a capacity or other performance-related feature that other equipment within such type (or class) does not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of equipment, DOE must consider such factors as the utility to the customer of such a feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede state laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of federal preemption for particular state laws or regulations, in accordance with the procedures and other provisions set forth under 42 U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in section 310(3) of EISA 2007, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, are required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for covered equipment after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into the standard, or, if that is not feasible, adopt a separate standard for such energy use for that equipment. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE's current test procedures and standards for MHLFs address standby mode and off mode energy use. However, in this rulemaking, DOE only addresses active mode energy consumption as the equipment included in the scope of coverage only consumes energy in active mode.
B. Background
1. Current Standards
EISA 2007 prescribed the current energy conservation standards for MHLFs manufactured on or after January 1, 2009. (42 U.S.C. 6295(hh)(1)) The current standards are set forth in Table II.1. EISA 2007 excludes from the standards: MHLFs with regulated-lag ballasts, MHLFs with electronic ballasts that operate at 480 volts (V); and MHLFs that (1) are rated only for 150 watt (W) lamps; (2) are rated for use in wet locations; and (3) contain a ballast that is rated to operate at ambient air temperatures higher than 50 °C.
Table II.1—Federal Energy Efficiency Standards for MHLFs *
Ballast type
Operated lamp rated wattage range
Minimum ballast efficiency
%
Pulse-start
≥150 and ≤500 W
88
Magnetic Probe-start
≥150 and ≤500 W
94
Nonpulse-start Electronic
≥150 and ≤250 W
90
Nonpulse-start Electronic
≥250 and ≤500 W
92
* (42 U.S.C. 6295(hh)(1)).
2. History of Standards Rulemaking for MHLFs
DOE is conducting this rulemaking to review and consider amendments to the energy conservation standards in effect for MHLFs, as required under 42 U.S.C. 6295(hh)(2) and (4). On December 30, 2009, DOE published a notice announcing the availability of the framework document, “Energy Conservation Standards Rulemaking Framework Document for Metal Halide Lamp Fixtures,” and a public meeting to discuss the proposed analytical framework for the rulemaking. 74 FR 69036. DOE also posted the framework document on its Web site; this document is available at
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16
. The framework document described the procedural and analytical approaches that DOE anticipated using to evaluate energy conservation standards for MHLFs, and identified various issues to be resolved in conducting this rulemaking.
DOE held a public meeting on January 26, 2010, during which it presented the contents of the framework document, described the analyses it planned to conduct during the rulemaking, sought comments from interested parties on these subjects, and in general, sought to inform interested parties about, and facilitate their involvement in, the rulemaking. At the meeting and during the period for commenting on the framework document, DOE received comments that helped identify and resolve issues involved in this rulemaking.
DOE then gathered additional information and performed preliminary analyses to help develop potential energy conservation standards for MHLFs. On April 1, 2011, DOE published in the
Federal Register
an announcement (the preliminary analysis notice) of the availability of the preliminary technical support document (the preliminary TSD) and of another public meeting to discuss and receive comments on the following matters: (1) The equipment classes DOE planned to analyze; (2) the analytical framework, models, and tools that DOE was using to evaluate standards; (3) the results of the preliminary analyses performed by DOE; and (4) potential standard levels that DOE could consider. 76 FR 1812 (April 1, 2011). In the preliminary analysis notice, DOE requested comment on these issues. The preliminary TSD is available at
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16
.
The preliminary TSD summarized the activities DOE undertook in developing standards for MHLFs, and discussed the comments DOE received in response to the framework document. It also described the analytical framework that DOE uses in this rulemaking, including a description of the methodology, the analytical tools, and the relationships among the various analyses that are part of the rulemaking. The preliminary TSD presented and described in detail each analysis DOE performed up to that point, including descriptions of inputs, sources, methodologies, and results.
The public meeting announced in the preliminary analysis notice took place on April 18, 2011. At this meeting, DOE presented the methodologies and results of the analyses set forth in the preliminary TSD. Interested parties discussed the following major issues at the public meeting: (1) Alternative approaches to performance requirements and the various related efficiency metrics; (2) the possibility of including design standards; (3) amendments to the test procedures for metal halide (MH) ballasts to account for multiple input voltages; (4) the cost and feasibility of utilizing electronic ballasts in MHLFs; (5) equipment class divisions; (6) overall pricing methodology; (7) lamp lifetimes; (8) cumulative regulatory burden; (9) shipments; and (10) the possibility of merging the MHLF and the high-intensity discharge (HID) lamp rulemakings.
In August 2013, DOE published a notice of proposed rulemaking (NOPR) in the
Federal Register
proposing new and amended energy conservation standards for MHLFs. In conjunction with the NOPR, DOE also published on its Web site the complete TSD for the proposed rule, which incorporated the analyses DOE conducted and technical documentation for each analysis. The NOPR TSD was accompanied by the LCC spreadsheet, the national impact analysis spreadsheet, and the manufacturer impact analysis (MIA) spreadsheet—all of which are available on DOE's Web site.
12
The proposed standards were as shown in Table II.2.78 FR 51463 (August 20, 2013).
12
All the spreadsheets models developed for this rulemaking proceeding are available at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16
.
Table II.2—Energy Conservation Standards Proposed in the NOPR
Designed to be operated with lamps of the following rated lamp wattage
Indoor/outdoor †
Test input voltage
††
Minimum standard equation ‡
%
≥50 W and ≤100 W
Indoor
480 V
99.4/(1+2.5×P^(−0.55)).‡
≥50 W and ≤100 W
Indoor
All others
100/(1+2.5×P^(−0.55)).
≥50 W and ≤100 W
Outdoor
480 V
99.4/(1+2.5×P^(−0.55)).
≥50 W and ≤100 W
Outdoor
All others
100/(1+2.5×P^(−0.55)).
>100 W and <150 W
*
Indoor
480 V
99.4/(1+0.36×P^(−0.30)).
>100 W and <150 W
*
Indoor
All others
100/(1+0.36×P^(−0.30)).
>100 W and <150 W
*
Outdoor
480 V
99.4/(1+0.36×P^(−0.30)).
>100 W and <150 W
*
Outdoor
All others
100/(1+0.36×P^(−0.30)).
≥150 W
**
and ≤250 W
Indoor
480 V
For ≥150 W and ≤200 W: 88.0.
For >200 W and ≤250 W: 0.06×P + 76.0.
≥150 W
**
and ≤250 W
Indoor
All others
For ≥150 W and ≤200 W: 88.0.
For >200 W and ≤250 W: 0.07×P + 74.0.
≥150 W
**
and ≤250 W
Outdoor
480 V
For ≥150 W and ≤200 W: 88.0
For >200 W and ≤250 W: 0.06×P + 76.0.
≥150 W
**
and ≤250 W
Outdoor
All others
For ≥150 W and ≤200 W: 88.0.
For >200 W and ≤250 W: 0.07×P + 74.0.
>250 W and ≤500 W
Indoor
480 V
91.0.
>250 W and ≤500 W
Indoor
All others
91.5.
>250 W and ≤500 W
Outdoor
480 V
91.0.
>250 W and ≤500 W
Outdoor
All others
91.5.
>500 W and ≤2000 W
Indoor
480 V
For >500 W to <1000 W: 0.994×(0.0032×P + 89.9).
For ≥1000 W to ≤2000 W: 92.5 and may not utilize a probe-start ballast.
>500 W and ≤2000 W
Indoor
All others
For >500 W to <1000 W: 0.0032×P + 89.9.
For ≥1000 W to ≤2000 W: 93.1 and may not utilize a probe-start ballast.
>500 W and ≤2000 W
Outdoor
480 V
For >500 W to <1000 W: 0.994×(0.0032×P + 89.9).
For ≥1000 W to ≤2000 W: 92.5 and may not utilize a probe-start ballast.
>500 W and ≤2000 W
Outdoor
All others
For >500 W to <1000 W: 0.0032×P + 89.9.
For ≥1000 W to ≤2000 W: 93.1 and may not utilize a probe-start ballast.
*
Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
**
Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
† DOE's proposed definitions for “indoor” and “outdoor” MHLFs are described in section V.A.2.
††
Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these voltages would be tested at the highest voltage for which the ballast is designed to operate.
‡ P is defined as the rated wattage of the lamp that the MHLF is designed to operate.
In the NOPR DOE invited comment, particularly on the following issues: (1) The expanded scope of coverage, (2) the proposed amendments to the test procedure, (3) equipment class divisions, (4) the efficiency levels (ELs) analyzed, (5) the method of estimating magnetically ballasted system input power, (6) the determination to include a design standard that would prohibit the sale of probe-start ballasts in newly sold MHLFs for certain wattages, (7) the derived manufacturer selling prices (MSPs), (8) the equipment class scaling factor for tested input voltage, and (9) the proposed trial standard level (TSL 3). 78 FR 51463 (August 20, 2013).
DOE held a NOPR public meeting on September 27, 2013, to hear oral comments on and solicit information relevant to the proposed rule (hereafter the NOPR public meeting). Interested parties in attendance discussed the following major issues: (1) The compliance date, (2) amendments to the test procedure, (3) scope of the rulemaking, (4) equipment class divisions, (5) impacts on the magnetic ballast footprint, (6) impacts on fixture design, (7) testing and manufacturing variation, and (8) impacts of solid-state lighting market penetration on MHLF shipments.
DOE considered the comments received in response to the NOPR after its publication and at the NOPR public meeting when developing this final rule, and responds to these comments in this notice.
3. Compliance Date
EPCA, as amended by EISA 2007, contains guidelines for the compliance date of the standards amended by this rulemaking. EPCA requires DOE to determine whether to amend the standards in effect for MHLFs and whether any amended standards should apply to additional MHLFs. The Secretary was directed to publish a final rule no later than January 1, 2012 to determine whether the energy conservation standards established by EISA 2007 for MHLFs should be amended, with any amendment applicable to equipment manufactured after January 1, 2015. (42 U.S.C. 6295(hh)(2)(B)) As discussed in section VI.C, DOE has determined it will maintain the three-year interval between the publication date of the final rule in the
Federal Register
and the compliance date.
III. Issues Affecting the Scope of This Rulemaking
A. Additional MHLFs for Which DOE Is Setting Standards
The existing energy conservation standards for MHLFs are established in EPCA through amendments made by EISA 2007. (42 U.S.C. 6295(hh)(1)(A)) The statute excludes from coverage MHLFs with regulated-lag ballasts; electronic ballasts that operate at 480 V; and ballasts that are rated only for (1) use with 150 W lamps, (2) use in wet locations, and (3) operation in ambient air temperatures higher than 50 °C.
13
DOE considered expanding the coverage of its energy conservation standards to include these exempted MHLF types and additional rated lamp wattages. For each previously exempted MHLF type and for all expansions of the covered wattage range, DOE considered potential energy savings, technological feasibility, and economic justification when determining whether to include them in the scope of coverage.
13
As a point of reference, 50 °C is equivalent to 122 °F.
Some stakeholders expressed confusion at the NOPR public meeting, stating that they interpreted this rulemaking as establishing efficiency standards for all metal halide ballasts rather than just ballasts in new metal halide lamp fixtures. The Edison Electric Institute (EEI) contended that the rule is misleading because the title indicates it is a rule for metal halide lamp fixtures when it actually establishes standards for all metal halide ballasts, including replacement ballasts. (EEI, Public Meeting Transcript, No. 48 at pp. 14-15, 67-69)
14
DOE clarifies that the scope of this rulemaking affects all new MHLFs. Ballasts sold with new fixtures after the compliance date must meet or exceed the standards promulgated by this rulemaking. Any ballasts sold on the replacement market do not need to comply with these standards.
14
A notation in the form “EEI, Public Meeting Transcript, No. 48 at pp. 14-15, 67-69” identifies a comment that DOE has received and included in the docket of this rulemaking. This particular notation refers to a comment: (1) Submitted by EEI; (2) in the transcript of the MHLF NOPR public meeting, document number 48 in the docket of this rulemaking; and (3) appearing on pages 14-15 and 67-69 of that transcript.
Regarding the additional fixtures that DOE proposed including in the scope of coverage, the California Energy Commission (CEC) generally supported the expanded scope for MHLFs DOE proposed in the NOPR. (CEC, No. 52 at p. 3) DOE received no other comment regarding the general approach to expand the scope of coverage and considers specific scope comments in the following sections.
1. EISA 2007 Exempted MHLFs
a. MHLFs With Regulated-Lag Ballasts
Regulated-lag ballasts are mainly used for specialty applications where line voltage variation is large. Regulated-lag ballasts are designed to withstand significant line voltage variation with minimum wattage variation to the lamp, which results in an efficiency penalty compared to ballasts whose output changes more significantly with line voltage variation. The power regulation provided by regulated-lag ballasts is higher than any other magnetic ballast. To be able to withstand large variations, regulated-lag ballasts are designed to be significantly larger than standard ballasts. Through manufacturer interviews and market research, DOE determined that the size and weight of regulated-lag ballasts limit their use as substitutes in traditional applications. Manufacturers and market research confirmed that their exemption did not lead to a significant market shift to regulated-lag ballasts. Furthermore, DOE's market research found none of this equipment available in major manufacturers' catalogs. The absence of regulated-lag ballasts from catalogs indicates a very small market share and therefore limited potential for significant energy savings. Thus, in the NOPR DOE proposed continuing to exempt MHLFs with regulated-lag ballasts from energy conservation standards.
Universal Lighting Technologies (ULT) and the National Electrical Manufacturers Association (NEMA) agreed with DOE's proposal to continue exempting regulated-lag ballasts from the scope of this rulemaking. NEMA further added that this higher cost technology is used in limited and specific applications, such as heavy industrial, security, and street and tunnel lighting, in order to avoid lamp failures caused by severe voltage dips. (ULT, No. 50 at p. 2; NEMA, No. 56 at p. 5; NEMA, Public Meeting Transcript, No. 48 at p. 48) Agreeing with this description of a limited, niche market and receiving no comments to the contrary, in this final rule DOE exempts regulated-lag ballasts from energy conservation standards.
b. MHLFs With 480 V Electronic Ballasts
In the NOPR, DOE concluded that 480 V electronic ballasts have a very small market share as they are only manufactured by one company and have limited availability from distributors. As a result, DOE determined that there is limited potential for significant energy savings, and in the NOPR proposed continuing to exempt MHLFs with 480 V electronic ballasts from energy conservation standards.
Philips Lighting (Philips), ULT, and NEMA agreed with DOE's decision to exclude 480 V electronic ballasts in the scope of this rulemaking. ULT noted that very few 480 V electronic ballasts are in the market, while Philips commented that 480 V electronic ballasts do not exist at any wattage. (Philips, Public Meeting Transcript, No. 48 at p. 130; ULT, No. 50 at p. 2; NEMA, No. 56 at p. 5) Having received no comments in disagreement, DOE continues to exempt 480 V electronic ballasts from energy conservation standards in this final rule.
c. Exempted 150 W MHLFs
After receiving exemption from energy conservation standards in EISA 2007, shipments of 150 W outdoor MHLFs rated for wet and high-temperature locations increased. Further, some indoor applications use the exempted outdoor MHLFs, negating possible energy savings for indoor 150 W MHLFs. Therefore, in the NOPR DOE concluded that including the currently exempt 150 W MHLFs in the scope of coverage has the potential for significant energy savings. Additionally, as a range of ballast efficiencies exists in commercially available ballasts, DOE found that improving the efficiencies of the ballasts included in these fixtures is technologically feasible and economically justified. Accordingly, in the NOPR DOE proposed including 150 W MHLFs in wet locations and ambient temperatures greater than 50 °C in the scope of this rulemaking.
NEMA, ULT, CEC, and the Southern Company disagreed with DOE's decision to include all 150 W ballasts in the scope of this rulemaking. (NEMA, No. 56 at pp. 5, 12; ULT, No. 50 at pp. 2-3; CEC, No. 52 at p. 3; Southern Company, No. 64 at p. 2; No. 64 at p. 2) NEMA commented that while DOE does have the authority to include this equipment, it must be done in a technologically and economically feasible manner. NEMA stated that the efficiencies adopted in the final rule must be substantially lowered from those proposed in the NOPR to be technologically feasible. (NEMA, No. 56 at pp. 5, 24) In support of this point, ULT and NEMA noted that the industry has not yet been able to create a 150 W MHLF with a magnetic ballast that achieves 88 percent efficiency, which is the minimum efficiency requirement proposed in the NOPR for previously exempt 150 W MHLFs. (ULT, Public Meeting Transcript, No. 48 at pp. 108-109; ULT, No. 50 at pp. 5-6, 23-24; NEMA, No. 56 at p. 13)
In contrast, in a joint comment the Pacific Gas and Electric Company, Southern California Gas Company, San Diego Gas and Electric, and Southern California Edison (hereafter referred to as the California investor-owned utilities or the “CA IOUs”) supported DOE's proposal to include previously exempt 150 W MHLFs in the scope of coverage. CA IOUs were unaware of any specific attributes that limit 150 W ballasts from reaching greater efficiency, and believe the lower efficiencies of these ballasts are more likely due to their prior exemption from standards, as there is significant room for improvement. Therefore, CA IOUs supported the inclusion of these ballasts. (CA IOUs, No. 54 at pp. 1-2) Also, in a joint comment the Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, National Consumer Law Center, Natural Resources Defense Council, Northwest Energy Efficiency Alliance, and Northwest Power and Conservation Council (hereafter referred to as the “Joint Comment”) supported including 150 W MHLFs previously exempted by EISA 2007 in the scope of this final rule. (Joint Comment, No. 62 at p. 9)
DOE agrees that commercially available magnetic ballasts cannot meet the EISA 2007 specified 88 percent efficiency. However, the 150 W fixtures exempted by EISA 2007 have a range of magnetic ballast efficiencies available below 88 percent and therefore energy conservation standards are technologically feasible. These fixtures can be considered separately from those 150 W fixtures covered by EISA 2007 by separating them into different equipment classes and DOE therefore finds no reason the previously exempt 150 W fixtures should not be covered by this rulemaking. Therefore in this final rule, DOE has included 150 W fixtures rated for use in wet locations and ambient temperatures greater than 50 °C in the scope of coverage.
NEMA, ULT, and Southern Company commented that the inclusion of 150 W ballast efficiency requirements would practically prohibit usage of 150 W magnetic ballasts, thereby forcing the usage of electronic ballasts in new fixtures. (NEMA, No. 56 at p. 6; ULT, No. 50 at pp. 2-3; Southern Company, No. 64 at p. 2) ULT and Southern Company expressed concerns that electronic ballasts for MH lamps are not proven in outdoor applications and are vulnerable to failures due to moisture, temperatures higher than 50 °C, and voltage variations and surges caused by lightning and other natural events. (ULT, No. 50 at pp. 2-3; Southern Company, No. 64 at p. 2)
DOE considered both more efficient magnetic and more efficient electronic ballasts as replacements for ballasts in the previously exempt 150 W fixtures. DOE has determined that, with the proper fixture adjustments, electronic ballasts can be used in the same applications as magnetic ballasts. For detailed discussion of this decision, see section V.A. DOE has concluded that the standard levels adopted in this final rule are economically justified.
General Electric (GE) commented that energy conservation standards for previously exempt 150 W MHLFs could actually increase rather than decrease national energy consumption. GE noted that the purpose of the 150 W exemption from EISA 2007 was to shift the market from 175 W fixtures to 150 W fixtures, thereby saving energy. Thus, GE disagreed with the way DOE analyzed 150 W fixtures and noted that the previously exempt fixtures should not be subject to standards higher than max tech. (GE, Public Meeting Transcript, No. 48 at pp. 135-136)
CA IOUs acknowledged that 150 W ballasts can be a low-wattage replacement for 175 W applications. Accordingly, CA IOUs encouraged increasing efficiency standards for both wattage levels equally, so as not to inadvertently push customers to the higher-wattage alternatives. (CA IOUs, No. 54 at pp. 1-2) CEC agreed, stating that by incentivizing 150 W fixtures through minimal efficiency standards, the market would be driven toward purchasing these lower-wattage fixtures instead of 175 W or 200 W fixtures. (CEC, No. 52 at p. 3)
The Joint Comment noted that while customers may choose to shift between different wattage MHLFs, continuing to exempt 150 W MHLFs is not the best solution. For example, a continued exemption might create market distortions and hinder the transitions to more efficient light-emitting diode (LED) lamps in this
wattage category. (Joint Comment, No. 62 at p. 9) The Joint Comment also stated that even if the inclusion of 150 W fixtures leads to the use of more 175 W or 200 W fixtures, it might not result in more energy consumption as switching to higher-wattage fixtures could also reduce the number of fixtures installed. In situations where the number of fixtures installed is not reduced, additional energy use could be offset by increased ballast efficiency in this wattage bin. In addition, the increased price of the 175 W fixtures provides more disincentive to purchase them over 150 W fixtures. Finally, the Joint Comment argued that if the standards apply to all wattage ranges from 50 W to 500 W, switching from 150 W to a higher-wattage fixture would not be a concern because all fixtures would be subject to the same standards. (Joint Comment, No. 62 at p. 9)
DOE notes that the exemption of certain 150 W fixtures from EISA 2007 resulted in a shift from 175 W to the exempted 150 W fixtures, which resulted in energy savings. In the shipments analysis, DOE considers how different standards for 150 W and 175 W MHLFs may impact customer choices. For example, when the initial first cost for 150 W fixtures exceeds that of 175 W fixtures, the shipments analysis models a shift to 175 W MHLFs. Even with some customers shifting to higher wattage MHLFs, energy conservation standards for 150 W fixtures still result in energy savings due to increased ballast efficiency. In this final rule, DOE has determined that standards for previously exempt 150 W MHLFs are technologically feasible, economically justified, and would result in significant energy savings (see section VII.C for details). Therefore, DOE has included previously exempt 150 W fixtures in the scope of coverage of this rulemaking.
2. Additional Wattages
Based on equipment testing and market research, DOE found in the NOPR that energy conservation standards for MHLFs rated for wattages greater than 50 W and less than 150 W, and MHLFs rated for wattages greater than 500 W, are technologically feasible, economically justified, and would result in significant energy savings. DOE determined that MHLFs rated for wattages greater than 2000 W only served small-market-share applications like graphic arts, ultraviolet (UV) curing, and scanners. Therefore, in the NOPR DOE proposed to include in the scope of coverage 50 W-150 W MHLFs and 501 W-2000 W MHLFs, in addition to the 150 W-500 W MHLFs
15
covered by EISA 2007.
15
DOE uses this shorthand to refer to MHLFs with ballasts designed to operate lamps rated greater than or equal to 50 W and less than 150 W, MHLFs with ballasts designed to operate lamps rated greater than 500 W and less than or equal to 2000 W, and MHLFs with ballasts designed to operate lamps rated greater than or equal to 150 W and less than or equal to 500 W, respectively.
NEMA and ULT opposed the expansion of coverage of this rulemaking to include 50 W-150 W MHLFs. They further commented that coverage of 50 W-100 W MHLFs would require redesign of all magnetic ballasts in that range, which would be nearly equivalent to banning magnetic ballasts. (NEMA, No. 56 at p. 6; ULT, No. 50 at pp. 2-3)
DOE has found MHLFs with a variety of ballast efficiencies in the 50 W-150 W range, including the 50 W-100 W range specifically cited by NEMA and ULT. Therefore, DOE believes energy conservation standards for 50 W-150 W MHLFs are technologically feasible. DOE considered both more efficient magnetic and more efficient electronic ballasts as replacements for ballasts in this rulemaking. DOE has determined that, with the proper fixture adjustments, electronic ballasts can be used in the same applications as magnetic ballasts. For detailed discussion of this decision, see section V.A. Economic impacts of standard levels on individual customers, manufacturers, and the nation are discussed in section VII.B. DOE has concluded that the standard levels adopted in this final rule for 50 W-150 W MHLFs are economically justified and would result in significant energy savings. Therefore, DOE has included 50 W-150 W MHLFs in the scope of coverage for this final rule.
DOE received several comments regarding the inclusion of MHLFs greater than 500 W in the scope of coverage. CA IOUs and Earthjustice supported the expansion of the scope of coverage to include 50 W-2000 W fixtures. (CA IOUs, No. 54 at pp. 1-2; Earthjustice, Public Meeting Transcript, No. 48 at p. 171) CA IOUs commented that because 18 percent of MH ballasts are designed to operate lamps greater than 500 W, there exists an opportunity for significant energy savings. (CA IOUs, No. 54 at pp. 1-2)
In contrast, NEMA and ULT disagreed with the inclusion of MHLFs greater than 500 W, noting that coverage of the 501 W-2000 W range would require redesign of the 750 W fixture family and this would come with significant cost increase. (NEMA, No. 56 at pp. 6-7; ULT, No. 50 at pp. 2-3)
DOE believes that standards for 500 W-1000 W MHLFs are technologically feasible because MHLFs in this wattage range contain ballasts that exhibit a range of efficiencies, indicating it is possible for a standard to improve the efficiency of ballasts already on the market. Specifically, DOE has found 750 W MHLFs with ballasts at multiple efficiencies that span both EL1 and EL2. Furthermore, DOE has analyzed MHLFs in this wattage range and concluded that standards for these MHLFs are economically justified and result in significant energy savings (see section VII.B of this notice for more details). Therefore, DOE includes 500 W-1000 W MHLFs in the scope of coverage for this rulemaking.
NEMA, GE, ULT, Musco Sports Lighting, LLC (Musco Lighting), Venture Lighting International, Inc. (Venture), and OSRAM SYLVANIA Inc. (OSI) all asserted that fixtures greater than 1000 W should not be covered by this rulemaking, as they are only operated in “specialty lighting” applications. They stated that the lamps' limited applications and low hours of operation do not result in appreciable savings opportunities, provide little energy gains at a significant cost, and pose an unjustified burden on manufacturers. (NEMA, Public Meeting Transcript, No. 48 at p. 114; NEMA, No. 56 at pp. 6-7; GE, Public Meeting Transcript, No. 48 at pp. 115, 172; ULT, No. 50 at pp. 2-3; Musco Lighting, Public Meeting Transcript, No. 48 at pp. 118, 180; Musco Lighting, No. 55 at pp. 3-4; Venture, Public Meeting Transcript, No. 48 at p. 170; OSI, Public Meeting Transcript, No. 48 at p. 172) Further, NEMA cited the 2010 U.S. Lighting Market Characterization (2010 LMC),
16
as evidence that stadium and sports lighting, the most common application for fixtures greater than 1000 W, is a niche market, unsuitable for energy savings exploration. Specifically, NEMA noted that in the 2010 LMC, the 839,000 MH lamps in stadium applications represent 2.8 percent of outdoor MH lamps (0.4 percent of all outdoor lamps) and only 1.2 percent of all installed MH lamps (see Table 4.1 in the 2010 LMC). For MH lamps in stadium applications, the average wattage is 1554 W (see Table 4.28 in the 2010 LMC) with an average usage of just 1 hour per day (see Table 4.29 in the 2010 LMC). NEMA agreed with the 2010 LMC that this is a reasonable average usage profile for MH lamps greater than 1000 W. In contrast, typical outdoor MH lamps average 12.1 hours per day ranging from 8.8 hours on building exteriors to 15 hours in parking areas. (NEMA, No. 56 at pp. 6-7)
16
U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. 2010
U.S. Lighting Market Characterization.
2010. Available at
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf
.
Musco Lighting pointed out that DOE's decision to not directly analyze 480 V magnetic ballasts due to low shipment volume supported their assertion that 1500 W fixtures should be exempt from energy conservation standards. Musco Lighting specified that as more than 50 percent of their shipments of 1500 W MHLFs contained a 480 V ballast, both MHLF types should be exempt. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 129)
DOE determined that sports lighting, which is the predominant application for lamps above 1000 W, fits the definition of general lighting and is therefore included in the scope of this rulemaking (see the following section III.A.3 for additional discussion). Although these higher wattage MHLFs do not comprise a large percentage of the market, their high wattage could potentially result in significant energy savings. DOE notes that MHLFs greater than 1000 W exist in a variety of efficiencies and therefore standards for these MHLFs are technologically feasible. DOE acknowledges, however, that MHLFs greater than 1000 W have a different cost-efficiency relationship than 501 W to 1000 W MHLFs. Therefore, in this final rule, DOE created a separate equipment class to analyze these MHLFs. See section V.A.2 for additional detail. After considering the economic impacts of standards for MHLFs greater than 1000 W on individual customers, manufacturers, and the nation, DOE has concluded that standards for these MHLFs are not economically justified. Therefore, in this final rule, DOE has not included MHLFs greater than 1000 W in the scope of coverage and has not adopted energy conservation standards for these MHLFs. See section VII for a discussion of the economic impacts.
3. General Lighting
EISA 2007 defines the scope of this rulemaking as applying to MHLFs used in general lighting applications. (42 U.S.C. 6291(64)) In section 2 of 10 CFR Part 430, Subpart A, a general lighting application is defined as lighting that provides an interior or exterior area with overall illumination. In the NOPR, DOE proposed to add this definition to 10 CFR Part 431.2,
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the section of the CFR that relates to commercial and industrial equipment, such as MHLFs. DOE's research indicated that there are a number of applications, such as outdoor sports lighting and airfield lighting, which commonly use MH ballasts of 1000 W to 2000 W and provide general illumination to an exterior area. In the NOPR, DOE proposed that such applications are general lighting applications and are covered by this rulemaking.
17
The general lighting application definition prescribed by EISA 2007 was previously incorporated into the consumer products section (10 CFR Part 430), but has not yet been added to the commercial and industrial equipment section (10 CFR Part 431).
ULT, NEMA, GE, Musco Lighting stated that all MHLFs above 1000 W have limited operating hours and are for specialty applications, not general lighting. (ULT, No. 50 at pp. 2-3; NEMA, No. 56 at pp. 6-7; GE, Public Meeting Transcript, No. 48 at p. 115; Musco Lighting, Public Meeting Transcript, No. 48 at p. 118) Earthjustice commented that the definition of “general lighting” refers to overall illumination of an interior or exterior area, not to the hours of use of an application. Therefore, Earthjustice stated that these higher-wattage lamps that serve applications such as sports lighting, parks, and airfields that provide overall illumination to exterior areas should not be considered niche equipment. (Earthjustice, Public Meeting Transcript, No. 48 at pp. 171, 174)
DOE agrees that the higher wattages fall under the CFR definition of general lighting. As mentioned previously, DOE also acknowledges that these lamps have limited operating hours and used these hours of use to calculate their energy savings potential. However, DOE does not believe that low operating hours impacts whether high wattage MHLFs are used in general lighting applications. DOE has determined that sports lighting is a general lighting application because it is “lighting that provides an interior or exterior area with overall illumination.” In this final rule, DOE adopts this definition for general lighting application in 10 CFR 431.2.
4. High-Frequency Electronic Ballasts
Electronic ballasts can be separated into two main types, low-frequency electronic (LFE) and high-frequency electronic (HFE). HFE ballasts are electronic ballasts with frequencies greater than or equal to 1000 hertz (Hz). DOE received comment that HFE ballasts should not be included in the scope of coverage based on compatibility issues and the lack of test procedure (DOE's proposed test procedure is discussed in section IV.A).
Venture and NEMA commented that there are no ANSI standards for the HFE ballasts that may be required to meet the analyzed standard levels, and therefore there will be limited MH lamps for use with these ballasts for a substantial period of time. (Venture, Public Meeting Transcript, No. 48 at p. 29; NEMA, No. 56 at p. 9) NEMA elaborated that many MH lamps are not compatible with existing HFE ballasts because of variation in arc tube size and shape. Due to this variation, HFE acoustic resonances can cause arc instability or even lamp failure. (NEMA, No. 44 at p. 6) NEMA specifically noted that high-frequency electronic ballasts are incompatible with the most efficacious lamps (ceramic metal halide). A standard that requires high frequency electronic ballasts could reduce overall energy savings because these ballasts are not compatible with the most efficacious MH lamps. (NEMA, No. 56 at p. 9) Furthermore, a standard that eliminates ballasts capable of operating ceramic metal halide lamps would be a violation of EPCA section 325(o)(4) which prohibits DOE from adopting a standard that interested parties have demonstrated results in the elimination of product features from the market. (NEMA, No. 44 at pp. 6-7) NEMA stated that industry standards for high frequency ballasts and lamps have only just begun to be developed and without these standards there will continue to be limited compatibility between high frequency ballasts and lamps (NEMA, No. 44 at p. 7). Even when acceptable frequency ranges are found, NEMA commented that HFE ballasts can also cause electrode back arcing, leading to shortened lamp life. (NEMA, No. 44 at p. 6)
As in the NOPR, DOE recognizes there are compatibility issues associated with HFE ballasts and some MH lamps, in particular ceramic metal halide (CMH) lamps. A standard that requires HFE ballasts could result in a full or partial elimination of CMH lamps from the market due to these compatibility issues. The elimination of CMH lamps could increase energy usage, as CMH lamps are some of the most efficacious MH lamps on the market. In the NOPR, DOE indicated it would take compatibility issues with HFE ballasts into account when selecting the eventual adopted standard of today's final rule. However, as detailed in section IV.A of this notice, DOE has not adopted a test procedure for HFE ballast, based on the lack of an industry consensus test method for this ballast type. DOE has found that in the absence of an applicable test method for these lamps, HFE ballasts cannot be subject to energy conservation standards. Therefore, DOE has not included HFE ballasts in the scope of coverage of this rulemaking.
5. Outdoor Fixtures
In the NOPR, DOE included both indoor and outdoor MHLFs in the scope of coverage because DOE determined that standards for both types of fixtures were technologically feasible, economically justified, and would result in significant energy savings. Because DOE concluded that indoor and outdoor fixtures had different cost-efficiency relationships, DOE analyzed them in separate equipment classes.
The American Public Power Association (APPA) noted that separating the outdoor and indoor lamps or exempting outdoor lamps is necessary because the usage patterns of outdoor lamps differ immensely from indoor. As the circumstances are different when considering both classes, APPA furthered, it is difficult to understand the effects of proposed efficiency standards on each group. APPA also noted that it may make sense to exempt outdoor fixtures from energy conservation standards because the electronic ballasts will have difficulty in extreme weather conditions. APPA, No. 51 at p. 4; APPA, Public Meeting Transcript, No. 48 at p. 103)
As mentioned previously, in the NOPR DOE determined that standards for both types of fixtures were technologically feasible, economically justified, and would result in significant energy savings. This conclusion is reaffirmed by the analysis in the final rule and DOE therefore includes both indoor and outdoor fixtures in the scope of coverage for this rulemaking. DOE agrees with analyzing outdoor and indoor fixtures separately by placing indoor and outdoor MHLFs into separate equipment classes. While the efficiencies achievable by indoor and outdoor fixtures are the same, the different costs affect the resultant cost-efficiency curves. See section V.A.2 of this notice for details on the equipment classes.
6. Hazardous Locations
Although DOE did not consider exempting fixtures designed for use in hazardous locations in the NOPR, NEMA commented that these fixtures need to be exempt from energy conservation standards. As these fixtures are used in potentially explosive atmospheres and listed to Underwriters Laboratories Inc. standard (UL) 844, any change in ballast size would require the fixture to be redesigned and re-tested, creating a tremendous burden on manufacturers. This is because the redesign, retesting, and relisting of these MHLFs would take significantly longer than three years, and leave this equipment type unavailable for an extended period of time. This would result in serious safety concerns until these fixture types were available again. NEMA also finds it would be very difficult for manufacturers to recoup the investment in standards-induced efficiency improvement for these types of MHLFs due to their limited market. Therefore, NEMA suggested that hazardous location fixtures should be granted an exemption from the rulemaking. (NEMA, No. 56 at p. 14)
As discussed in section V.C.8, the standard levels analyzed in this rulemaking do not require an increase in ballast size. Therefore, DOE does not believe hazardous location fixtures would need to be modified due to a change in ballast size. DOE notes that the vast majority of hazardous location fixtures are specified for use with magnetic ballasts. Therefore, DOE investigated existing fixtures, and the requirements of UL 844, to determine whether higher standards for ballasts, specifically those that require electronic ballast technology, would cause existing hazardous location fixtures to be redesigned and/or retested. After reviewing the UL 844 requirements, DOE found no constraints that would specifically or effectively preclude the use of electronic ballasts. Instead, UL 844 contains explosion protection requirements
for a luminaire, including requirements that no part of the fixture reach the thermal ignition temperature of a particulate or gas in the environment. DOE's survey of existing hazardous location fixtures found that these fixtures are commonly rated for use with a type of MH ballast and specific wattage. For example, a hazardous location fixture may be rated for use with a magnetic MH ballast of a given wattage (e.g., a 750 W magnetic MH ballast). Most hazardous location fixtures that are currently available are certified for use with magnetic ballasts, with offerings at a variety of wattages.
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DOE only identified one hazardous location fixture that was rated for use with electronic ballasts (in this case, a 150 W electronic ballast). DOE was unable to confirm that hazardous location fixtures compatible with electronic ballasts were available at the same wattages as hazardous location fixtures compatible with magnetic ballasts that are currently offered on the market. However, as discussed in section VII.C, DOE is not adopting standards that are expected to require the use of electronic ballast technology. Therefore, DOE does not believe the adopted standards in this rulemaking will require hazardous location fixtures to be redesigned and retested and does not exempt them from the standards adopted in this final rule.
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While not comprehensive, DOE identified hazardous location fixtures certified for use with magnetic ballasts that operate lamps with rated wattages between 150 W and 750 W.
7. Summary of MHLFs for Which DOE Is Setting Standards
EISA 2007 established energy conservation standards for MHLFs with ballasts designed to operate lamps with rated wattages between 150 W and 500 W. As previously discussed, EISA 2007 also exempted three types of fixtures within the covered wattage range from energy conservation standards. In this final rule, DOE extends coverage to MHLFs with ballasts designed to operate lamps rated 50 W-150 W and 501 W-1000 W. DOE also includes one type of previously exempt fixture in the scope of coverage: 150 W MHLFs rated for use in wet locations and containing a ballast that is rated to operate at ambient air temperatures greater than 50 °C. DOE continues to exempt regulated-lag ballasts and 480 V electronic ballasts. For all ballasts included in the scope of coverage, DOE has determined that energy conservation standards are technologically feasible, economically justified, and would result in significant energy savings. As such, DOE adopts standards for these MHLFs in this final rule.
B. Alternative Approaches to Energy Conservation Standards: System Approaches
As discussed in the NOPR, DOE considered several alternatives to establishing energy conservation standards for MHLFs by regulating the efficiency of the ballast contained within the fixture. Specifically, DOE considered a lamp-and-ballast system metric, fixture-level metrics, and the compliance paths specified in California's Title 20 regulations (which are now preempted by federal energy conservation standards in 10 CFR 431.326, 74 FR 12058; March 23, 2009). DOE concluded that, after considering all of these alternate approaches, maintaining the EISA 2007 approach of regulating MHLFs by specifying a minimum ballast efficiency was the most widely accepted, least burdensome approach that would ensure energy conservation standards resulted in energy savings. Therefore, in the NOPR DOE proposed standards for MHLFs by requiring that MHLFs contain ballasts that comply with minimum specified efficiencies. NEMA agreed, citing the increased testing burden associated with testing every combination of lamp and ballast sold in a fixture, and recognizing that the majority of MHLFs are not shipped with a lamp. (NEMA, No. 56 at p. 8) Receiving no comment to the contrary, DOE maintains this approach in this final rule.
C. Standby Mode and Off Mode Energy Consumption
EPCA requires energy conservation standards adopted for covered equipment after July 1, 2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) The requirement to incorporate standby mode and off mode energy use into the energy conservation standards analysis is therefore applicable in this rulemaking.
DOE determined that it is not possible for MHLFs to meet off mode criteria because there is no condition in which the components of an MHLF are connected to the main power source and are not already in a mode accounted for in either active or standby mode. DOE recognizes that MHLFs could be designed with auxiliary control devices that could consume energy in standby mode. However, DOE has yet to encounter such a control device design, or other type of MHLF that uses energy in standby mode, on the market. Therefore, in the NOPR DOE concluded that it cannot establish a standard that incorporates standby mode or off mode energy consumption. Receiving no comment to the contrary, DOE maintains this conclusion in the final rule and does not include standby mode or off mode energy consumption in the standards adopted in this final rule.
IV. General Discussion
A. Test Procedures
1. Current Test Procedures
The current test procedures for MH ballasts and MHLFs are outlined in Subpart S of 10 CFR Part 431. The test conditions, setup, and methodology generally follow the guidance of ANSI C82.6-2005. Testing requires the use of a reference lamp, which is to be driven by the ballast under test conditions until the ballast reaches operational stability. Ballast efficiency for the fixture is then calculated as the measured ballast output power divided by the ballast input power. In the NOPR, DOE considered changes to the test procedure regarding input voltage, the testing of HFE ballasts, and rounding requirements.
2. Test Input Voltage
MH ballasts can be operated at a variety of voltages. The most common voltages are 120 V, 208 V, 240 V, 277 V, and 480 V. Ballasts will also commonly be rated for more than one voltage, such as dual-input-voltage ballasts that can be operated at 120 V or 277 V, or quad-input-voltage ballasts that can be operated at 120 V, 208 V, 240 V, or 277 V. Through manufacturer feedback and testing, DOE found that the specific design of a ballast and the voltage of the lamp operated by the ballast can affect the trend between input voltage and efficiency.
The existing test procedures do not specify the voltage at which a ballast is to be tested, and the majority of ballasts sold are capable of operating at multiple input voltages. Therefore, to ensure consistency among testing and reported efficiencies, DOE considered methods of standardizing this aspect of testing in the NOPR.
a. Average of Tested Efficiency at All Possible Voltages
One method analyzed in the NOPR was testing ballasts at each input voltage at which they are able to operate, and then having a standard for the average of these efficiencies. As averaging the efficiencies could misrepresent the performance of the ballast in its common uses and could increase the testing burden, in the NOPR, DOE did not propose this method. Having received no comments to the contrary, DOE continues to reject using the average of tested efficiency at all possible voltages in this final rule.
b. Posting the Highest and Lowest Efficiencies
A second approach considered in the NOPR was requiring testing at each input voltage and listing the best and worst efficiencies on the MHLF label. DOE found that, similar to averaging efficiencies, this approach would increase the compliance testing burden for manufacturers compared to a requirement to test ballasts only at a single voltage. Therefore, DOE did not propose this method. Having received no comments to the contrary, DOE continues to reject the posting of the highest and lowest efficiencies on an MHLF label in this final rule.
c. Test at Single Manufacturer-Declared Voltage
A third approach considered in the NOPR was that the test procedures should allow testing at a single voltage determined by the manufacturer and declared in the test report. DOE concluded that this approach would not be favorable as the efficiency at the manufacturer-declared voltage and the efficiency at the more commonly used voltages may not be the same, and as such could potentially reduce the energy savings of this rulemaking. Thus, DOE did not propose to test ballast efficiency at a single manufacturer-declared voltage.
GE agreed that a multi-tap ballast should be tested at just one input voltage. Rather than testing at the designated highest voltage, GE stated that it should be up to the manufacturer to choose the voltage at which the ballast was optimally designed for purposes of reporting efficiencies. (GE, Public Meeting Transcript, No. 48 at p. 83)
DOE agrees with testing multi-tap ballasts at a single voltage. DOE's position against allowing manufacturers to declare their testing input voltage stems from concerns
that manufacturers could optimize efficiency at a voltage that is most convenient or least expensive, rather than the voltage most commonly used by customers. If optimal efficiency is achieved at a less commonly used voltage, the reported ballast efficiency would not be representative of the ballast efficiency in the ballast's more common applications. If the efficiency at the tested voltage and at the most commonly used voltage are not directly correlated, energy savings could potentially be reduced. For these reasons, DOE rejects the proposal to allow manufacturers to select the voltage at which ballasts are tested in this final rule.
d. Test at Highest Rated Voltage
Another input voltage specification that DOE considered was testing the ballast at the highest voltage possible. However, DOE concluded that a ballast's highest rated voltage is not always its most common input voltage, and therefore testing and enforcing standards at the highest voltage could reduce the potential energy savings of this rulemaking. Accordingly, in the NOPR DOE did not propose to test ballast efficiency at the highest rated voltage. Having received no comments to the contrary, DOE continues to reject testing at the highest rated voltage in this final rule.
e. Test on Input Voltage Based on Wattage and Available Voltages
The final approach analyzed was testing the most common input voltages for each wattage range. This meant, when possible, ballasts less than 150 W are tested at 120 V, ballasts greater than or equal to 150 W are tested at 277 V, and if those specified voltages are unavailable, the ballast is tested at the highest available voltage. DOE concluded that because this proposal only requires testing at one input voltage, it minimizes testing burden. In addition, because the input voltage specification matches the most commonly used voltage, the requirement encourages optimization of efficiency around an input voltage commonly used in practice.
NEMA and ULT agreed with DOE's NOPR proposals regarding the input voltage for testing. (NEMA, No. 56 at p. 8; ULT, No. 50 at p. 4) Having received no comments to the contrary, in this final rule, DOE amends the test procedure to require that ballasts be tested at the following input voltages:
• For ballasts less than 150 W with an available voltage of 120 V, ballasts will be tested at 120 V.
• For ballasts less than 150 W that lack 120 V as an available voltage, ballasts will be tested at the highest available input voltage.
• For ballasts operated at 150 W-2000 W that also have 277 V as an available input voltage, ballasts will be tested at 277 V.
• For ballasts operated at 150 W-2000 W that lack 277 V as an available input voltage, ballasts will be tested at the highest available input voltage.
3. Testing High-frequency Electronic Ballasts
MHLF test procedures reference the 2005 version of ANSI C82.6 for testing both electronic and magnetic MH ballasts. However, ANSI C82.6-2005 does not provide a method for testing HFE ballasts. In the NOPR, DOE found that the instrumentation commonly used for HFE MH ballast testing is the same instrumentation used for electronic fluorescent lamp ballast testing. Therefore, DOE proposed the same instrumentation used in electronic fluorescent lamp ballast testing be used for testing HFE MH ballasts. These proposed requirements specified that once the output frequency of a MH ballast is determined to be greater than or equal to 1000 Hz (the frequency at which DOE defines HFE ballasts) the test procedure instrumentation would be required to include a power analyzer that conforms to ANSI C82.6-2005 with a maximum of 100 picofarads (pF) capacitance to ground and a frequency response between 40 Hz and 1 MHz. The test procedures would also require a current probe compliant with ANSI C82.6-2005 that is galvanically isolated and has a frequency response between 40 Hz and 20 MHz, and lamp current measurement where the full transducer ratio is set in the power analyzer to match the current to the analyzer. The full transducer ratio would be required to satisfy the following equation:
ER10FE14.000
Where:
I
in
is current through the current transducer;
V
out
is the voltage out of the transducer;
R
in
is the power analyzer impedance; and
R
s
is the current probe output impedance.
DOE received comment on the lack of compatibility standards between HFE ballasts and MH lamps. NEMA commented that no work has begun on the ANSI C82.6 test procedure standard for HFE ballasts. (NEMA, No. 44 at p. 7) Philips noted that as HFE ballasts do not have testing standards, measurement errors and testing differences could lead to false efficiency values. (Philips, Public Meeting Transcript, No. 48 at p. 70) Similarly, NEMA stated that lack of industry testing standard meant efficiencies are computed using internal test procedures. Therefore, using catalog data gathered from more than one manufacturer combines different test procedures. (NEMA, Public Meeting Transcript, No. 48 at p. 31; NEMA, No. 44 at p. 8) NEMA also noted that labs cannot be accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) to submit HFE ballast testing to DOE without a test procedure to accredit to. (NEMA, No. 56 at p. 9) Further, NEMA noted that it is difficult to precisely measure the power of these HFE ballasts at frequencies over 100 kHz, which experience a 2-5 percent measurement uncertainty. With a tenth of a percentage precision on ballast efficiency, it will be very difficult to attain these levels of measurement. (NEMA, Public Meeting Transcript, No. 48 at p. 30; NEMA, No. 44 at p. 8)
DOE agrees that there are no industry test procedures for HFE ballasts. While the addition of instrumentation requirements addresses some concerns, specifications for lamps to be paired with the ballast during testing and a complete test method specific to HFE ballasts (an equivalent document to ANSI C82.6—which covers magnetic ballasts and LFE ballasts, but not HFE ballasts) are not currently available. Therefore, in this final rule, DOE is not adopting any changes to the test procedure for HFE ballasts. As discussed in section III.A.4 of this notice, DOE is not considering standards for HFE ballasts because a test procedure for HFE ballasts does not exist.
4. Rounding Requirements
Through testing, DOE found that testing multiple samples of the same ballast yielded a range of ballast efficiencies typically differing by less than one percent. Because this data introduces both test measurement and sample to sample variation, the test measurement itself should be at least this accurate. Therefore, DOE came to the conclusion that test procedures can resolve differences of less than one percent and rounding to the tenths of a percent would be reasonable. In the NOPR, DOE proposed amending the MH ballast test procedure for measuring and recording input wattage and output wattage to require rounding to the nearest tenth of a watt, and the resulting calculation of efficiency to the nearest tenth of a percent.
ULT, EEI, and NEMA commented that most test equipment for MHLFs is not calibrated to the proposed level of precision. ANSI standards require wattmeters to have 0.5 percent accuracy. (ULT, Public Meeting Transcript, No. 48 at p. 82; EEI, Public Meeting Transcript, No. 48 at p. 85; NEMA, No. 44 at p. 13). Further, NEMA noted that white paper NEMA LSD-63-2012 on variability estimated the tolerance for a sample of four magnetic ballasts to be 4.7 percent when 99 percent confidence factor is required. (NEMA, No. 56 at p. 8) On the contrary, CA IOUs commented that efficiency measurement equipment accurate to plus or minus 0.5 percent is already capable of measuring efficiency to the nearest watt for lamps of 100 W and above, and the nearest tenth of a watt for lamps below 100 W. CA IOUs argued this supports tenths place rounding of an efficiency figure and setting of standards to the tenth of a percent. (CA IOUs, No. 54 at pp. 2-3). Finally, EEI commented that if the difference between EL1 and EL2 is 0.6 percent, and there is a testing tolerance
of plus or minus 1 percent, there could be a classing issue. (EEI, Public Meeting Transcript, No. 48 at p. 159).
DOE reviewed ANSI C82.6-2005 and found that the instrumentation requirements stipulate that watts be measured with 3.5 digits of resolution, with basic accuracy of 0.5 percent. For an efficiency calculation that involves output power divided by input power, 3.5 digits of resolution allows for rounding efficiency to three significant figures (e.g., 0.895 or 89.5 percent) using only three digits. DOE also notes that some manufacturers have submitted compliance data to DOE's certification, compliance, and enforcement (CCE) database rounded to three significant figures and, in response to the NOPR, manufacturers had responded to certain issues using efficiency data rounded to three significant figures. Both of these suggest that manufacturers already have the capability to accomplish these measurements. DOE also considered LSD-63, as suggested by NEMA, but found that it details the population distribution from all sources of variation and did not find that it provides any information regarding the ability to measure the efficiency of an individual ballast to three significant figures. For these reasons, this final rule amends the test procedure to require measuring and calculating ballast efficiency to three significant figures. DOE also adopts energy conservation standards that are specified to three significant figures.
B. Technological Feasibility
1. General
In each standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the equipment that is the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available equipment or in working prototypes to be technologically feasible. 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i).
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) Practicability to manufacture, install, or service; (2) adverse impacts on equipment utility or availability; and (3) adverse impacts on health or safety. Section V.B of this notice discusses the results of the screening analysis for MHLFs, particularly the designs DOE considered, those it screened out, and those that are the basis for the TSLs in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the final rule TSD.
2. Maximum Technologically Feasible Levels
When DOE adopts a new or amended standard for a type or class of covered equipment, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such equipment. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for MHLFs, using the design parameters for the most efficient equipment available on the market or in working prototypes. For MHLFs from 50-500 W, the max-tech fixtures use high-grade electronic ballasts. For MHLFs from 501-2000 W, the max-tech fixtures use magnetic ballasts that incorporate high-grade, grain-oriented steel (M6
19
). (See chapter 5 of the final rule TSD for additional detail.) The max-tech levels that DOE determined for this rulemaking are listed in Table IV.1.
19
The American Iron and Steel Institute type numbers and AK Steel designations for electrical steel grades consist of the letter M followed by a number. The M stands for magnetic material; the number is representative of the core loss of that grade.
Table IV.1—Max-Tech Levels
Equipment class wattage range
Efficiency level *
Efficiency-level equation †
%
≥50 and ≤100
EL4
1/(1+0.360×P^(−0.297))
>100 and <150 *
EL4
1/(1+0.360×P^(−0.297))
≥150 ** and ≤250
EL4
1/(1+0.360×P^(−0.297))
>250 and ≤500
EL4
1/(1+0.360×P^(−0.297))
>500 and ≤1000
EL2
For >500 W and ≤750 W: 0.910
For >750 W and ≤1000 W: 0.000104×P+0.832
>1000 and ≤2000
EL2
0.936
* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
** Excludes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 watt lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
† P is defined as the rated wattage of the lamp that the fixture is designed to operate.
C. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that are the subject of this rulemaking purchased in the 30-year period that begins in the year of compliance with new and amended standards (2017-2046). The savings are measured over the entire lifetime of equipment purchased in the 30-year period.
20
DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the base case. The base case represents a projection of energy consumption in the absence of new or amended mandatory efficiency standards, and considers
market forces and policies that affect demand for more efficient equipment. For example, in the base case, DOE models a migration from covered metal halide lamp fixtures to higher efficiency technologies such as high-intensity fluorescent (HIF), induction lights, and LEDs. DOE also models a move to other HID fixtures such as high-pressure sodium, based on data given by manufacturers during the 2010 Framework public meeting. (Philips, Public Meeting Transcript, No. 8 at p. 91)
20
In the past DOE presented energy savings results for only the 30-year period that begins in the year of compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured over the entire lifetime of equipment purchased in the 30-year period. DOE has chosen to modify its presentation of national energy savings to be consistent with the approach used for its national economic analysis.
DOE used its NIA spreadsheet model to estimate energy savings from new and amended standards for the metal halide lamp fixtures that are the subject of this rulemaking. The NIA spreadsheet model (described in section V.G of this notice) calculates energy savings in site energy, which is the energy directly consumed by products at the locations where they are used. For electricity, DOE reports national energy savings in terms of the savings in the energy that is used to generate and transmit the site electricity. To calculate this quantity, DOE derives annual conversion factors from the model used to prepare the Energy Information Administration's (EIA)
Annual Energy Outlook 2013
(
AEO2013
).
DOE has begun to also estimate full-fuel-cycle energy savings. 76 FR 51282 (August 18, 2011), as amended at 77 FR 49701 (August 17, 2012). The full-fuel-cycle (FFC) metric includes the energy consumed in extracting, processing, and transporting primary fuels, and thus presents a more complete picture of the impacts of energy efficiency standards. DOE's evaluation of FFC savings is driven in part by the National Academy of Science's (NAS) report on FFC measurement approaches for DOE's Appliance Standards Program.
21
The NAS report discusses that FFC was primarily intended for energy efficiency standards rulemakings where multiple fuels may be used by a particular product. In the case of this rulemaking pertaining to metal halide lamp fixtures, only a single fuel—electricity—is consumed by the equipment. DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered equipment. Although the addition of FFC energy savings in the rulemakings is consistent with the recommendations, the methodology for estimating FFC does not project how fuel markets would respond to this particular standards rulemaking. The FFC methodology simply estimates how much additional energy, and in turn how many tons of emissions, may be displaced if the estimated fuel were not consumed by the equipment covered in this rulemaking. It is also important to note that inclusion of FFC savings does not affect DOE's choice of adopted standards.
21
“Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building Appliance Energy-Efficiency Standards,” (Academy report) was completed in May 2009 and included five recommendations. A copy of the study can be downloaded at:
www.nap.edu/catalog.php?record_id=12670
.
2. Significance of Savings
As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard for covered equipment unless such standard would result in “significant” energy savings. Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in this context to be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in this rulemaking (presented in section VII.B.3.a) are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
D. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Customers
In determining the impacts of an amended standard on manufacturers, DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period.
22
The industry-wide impacts analyzed include INPV, which values the industry on the basis of expected future cash flows; cash flows by year; changes in revenue and income; and other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
22
DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.
For individual customers, measures of economic impact include the changes in LCC and payback period (PBP) associated with new or amended standards. These measures are discussed further in the following section. For customers in the aggregate, DOE also calculates the national net present value of the economic impacts applicable to a particular rulemaking. DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of customers that may be affected disproportionately by a national standard.
b. Savings in Operating Costs Compared to Increase in Price
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered equipment compared to any increase in the price of the covered equipment that are likely to result from the imposition of the standard (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of equipment (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the equipment. To account for uncertainty and variability in specific inputs, such as equipment lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value. For its analysis, DOE assumes that consumers will purchase the covered products in the first year of compliance with amended standards.
The LCC savings and the PBP for the considered ELs are calculated relative to a base case that reflects projected market trends in the absence of amended standards. DOE identifies the percentage of customers estimated to receive LCC savings or experience an LCC increase, in addition to the average LCC savings associated with a particular standard level.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for imposing an energy conservation standard, EPCA requires DOE, in determining the economic
justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section V.G, DOE uses the NIA spreadsheet to project national site energy savings.
d. Lessening of Utility or Performance of Equipment
In establishing classes of equipment, and in evaluating design options and the impact of potential standard levels, DOE evaluates standards that would not lessen the utility or performance of the considered equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) The standards adopted in today's final rule will not reduce the utility or performance of the equipment under consideration in this rulemaking. One piece of evidence for this claim includes that magnetic ballast ELs are allowed for every covered MHLF wattage and application, meaning that manufacturers are not required to change the electronic configuration of their current offerings. A second piece of evidence is that commercially available stack height and footprint is being maintained for all ballasts, resulting in no required change from current MHLF size. Another piece of evidence is that no standards were adopted for MHLFs greater than 1000 W, so that all commercially available MHLFs at such wattages are subjected to no mandatory adjustments. Overall, the adopted standards were selected to protect the interest of customers and do not lessen MHLF performance or utility.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE transmitted a copy of its proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOE addresses the Attorney General's determination in this final rule.
f. Need for National Energy Conservation
The energy savings from new and amended standards are likely to provide improvements to the security and reliability of the nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the nation's needed power generation capacity.
The new and amended standards also are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with energy production. DOE reports the emissions impacts from today's standards, and from each TSL it considered, in section VII.B.6 of this notice. DOE also reports estimates of the economic value of emissions reductions resulting from the considered TSLs.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a standard is economically justified, to consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the customer of equipment that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values used to calculate the effect potential amended energy conservation standards would have on the payback period for customers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to customers, manufacturers, the nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable-presumption payback calculation is discussed in section VII.B.1 of this final rule.
V. Methodology and Discussion
DOE used two spreadsheets to estimate the impact of the adopted standards. The first spreadsheet calculates LCCs and PBPs of potential new energy conservation standards. The second provides shipments forecasts and then calculates national energy savings and NPV impacts of new energy conservation standards. The Department also assessed manufacturer impacts, largely through use of the Government Regulatory Impact Model (GRIM).
Additionally, DOE uses a version of EIA's National Energy Modeling System (NEMS) to estimate the impacts of energy efficiency standards on electric utilities and the environment. The NEMS model simulates the energy sector of the U.S. economy. The version of NEMS used for appliance standards analysis is called NEMS-BT (BT stands for DOE's Building Technologies Program), and is based on the
AEO2013
version of NEMS with minor modifications.
23
The NEMS-BT accounts for the interactions between the various energy supply and demand sectors and the economy as a whole. For more information on NEMS, refer to
The National Energy Modeling System: An Overview,
DOE/EIA-0581 (98) (Feb. 1998), available at:
tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf
.
23
The EIA does not approve use of the name “NEMS” unless it describes an
AEO
version of the model without any modification to code or data. Because the present analysis entails some minor code modifications and runs the model under various policy scenarios that deviate from
AEO
assumptions, the name “NEMS-BT” refers to the model as used here.
As a basis for this final rule, DOE has continued to use the approaches explained in the NOPR. DOE used the same general methodology as applied in the NOPR, but revised some of the assumptions and inputs for the final rule in response to public comments. The following sections discuss these revisions.
A. Market and Technology Assessment
1. General
When completing an energy conservation standards rulemaking, DOE develops information that provides an overall picture of the market for the equipment concerned, including the purpose of the equipment, the industry structure, and the market characteristics. This activity includes both quantitative and qualitative assessments based on publicly available information. The subjects addressed in the market and technology assessment for this rulemaking include: equipment classes and manufacturers; historical
shipments; market trends; regulatory and non-regulatory programs; and technologies or design options that could improve the energy efficiency of the equipment under examination. See chapter 3 of the final rule TSD for further discussion of the market and technology assessment.
2. Equipment Classes
When evaluating and establishing energy conservation standards, DOE divides covered equipment into equipment classes by the type of energy used or by capacity or other performance-related features that justifies a different standard. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility to the customer of the feature and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) DOE then considers separate standard levels for each equipment class based on the criteria set forth in 42 U.S.C. 6295(o). In the NOPR, DOE proposed to divide equipment classes by input voltage, rated lamp wattage, and designation for indoor versus outdoor applications.
a. Input Voltage
MHLFs are available in a variety of input voltages (most commonly 120 V, 208 V, 240 V, 277 V, and 480 V), and the majority of fixtures are equipped with ballasts that are capable of operating at multiple input voltages (for example, quad-input-voltage ballasts are able to operate at 120 V, 208 V, 240 V, and 277 V). DOE determined that input voltage represents a feature affecting consumer utility as certain applications demand specific input voltages. DOE's ballast testing did not indicate a prevailing relationship (
e.g.,
higher voltages are not always more efficient) between discrete input voltages and ballast efficiencies, with one exception. In the NOPR, DOE found that ballasts tested at 480 V were less efficient on average than ballasts tested at 120 V or 277 V.
As discussed in section IV.A of this final rule, MH ballasts will be tested at a single input voltage based on the lamp wattage operated by the ballast. Ballasts that operate lamps less than 150 W shall be tested at 120 V, and all others shall be tested at 277 V, unless the ballast is incapable of operating at the specified input voltage; in that case, the ballast shall be tested at the highest input voltage possible. Because dedicated 480 V ballasts have a distinct utility in that certain applications require 480 V operation and a difference in efficiency relative to ballasts tested at 120 V and 277 V, in the NOPR DOE proposed separate equipment classes for ballasts tested at 480 V (in accordance with the test procedure).
Philips noted that when manufacturing multi-tap magnetic ballasts, each tap must be precisely placed. The voltage variation in each tap makes it more difficult for multi-tap ballasts to meet efficiency requirements than ballasts with dedicated voltage. (Philips, Public Meeting Transcript, No. 48 at p. 99) NEMA, ULT, and Southern Company supported a separate equipment class for dedicated 480 V ballasts. (NEMA, No. 56 at p. 12; ULT, No. 50 at p. 5; Southern Company, No. 64 at p. 2)
DOE acknowledges that the existence of multiple voltage taps could cause multi-tap ballasts to be less efficient than dedicated voltage ballasts. However, DOE's testing of commercially available ballasts did not identify this trend. Rather, DOE's test results indicated that the only obvious relationship between input voltage and ballast efficiency is that ballasts tested at 480 V were less efficient on average than ballasts tested at 120 V or 277 V. As stated above, DOE believes that input voltage offers unique utility because certain applications require specific input voltages. Therefore, in this final rule, DOE creates a separate equipment class for ballasts that are tested at 480 V.
b. Lamp Wattage
As lamp wattage increases, lamp-and-ballast systems generally produce increasing amounts of light (lumens). Because certain applications require more light than others, wattage often varies by application. For example, low-wattage (less than 150 W) lamps are typically used in commercial applications for general lighting. Medium-wattage (150 W-500 W) lamps are commonly used in warehouse, street, and general commercial lighting. High-wattage (greater than 500 W) lamps are used in searchlights, stadiums, and other applications that require powerful white light. Because different applications require different amounts of light and the light output of lamp-and-ballast systems is typically reflected by the wattage, wattage affects consumer utility. Additionally, the wattage of a lamp operated by a ballast is correlated with the ballast efficiency; ballast efficiency generally increases as lamp wattage increase. Because wattage affects consumer utility and has a strong correlation to efficiency, DOE determined in the NOPR that separate equipment classes based on wattage were warranted.
DOE found that even within a designated wattage range (such as 101 W-150 W), the potential efficiencies ballasts can achieve is not constant, but rather varies with wattage. Thus for certain wattage bins, instead of setting a constant efficiency standard, DOE used an equation-based energy conservation standard (see section V.C). DOE combined the wattage bins and equations rather than using a single equation spanning all covered wattages for two reasons. First, the range of ballast efficiencies considered can differ significantly by lamp wattage, making it difficult to construct a single continuous equation for ballast efficiency from 50 W to 2000 W. This efficiency difference can be attributed to the varying cost of increasing ballast efficiency for different wattages and the impact of legislated (EISA 2007) standards that affect only some wattage ranges. Second, different wattages often serve different applications and have unique cost-efficiency relationships. Analyzing certain wattage ranges as separate equipment classes allows DOE to establish the energy conservation standards that are cost-effective for every wattage.
In the NOPR, DOE proposed to define MHLF equipment classes by the following rated lamp wattage ranges: 50 W-100 W, 101 W-150 W, 150 W-250 W, 251 W-500 W, and 501 W-2000 W.
24
As discussed previously in section III.A.1, there is an existing EISA 2007 exemption for ballasts rated for only 150 W lamps, used in wet locations, and that operate in ambient air temperatures higher than 50 °C. This exemption has led to a difference in the commercially available efficiencies for ballasts that are contained within fixtures exempted versus not exempted from EISA 2007. The exempted fixtures have ballasts with a range of efficiencies similar to ballasts that operate lamps less than 150 W. Fixtures not exempted by EISA 2007 have ballasts that follow efficiency trends representative of ballasts greater than 150 W. As a result, DOE proposed that 150 W MHLFs previously exempted by EISA 2007 be included in the 101 W-150 W range, while 150 W MHLFs subject to EISA 2007 standards continue to be included in the 150 W-250 W range.
24
DOE uses this shorthand to refer to MHLFs designed to operate lamps rated at equal to or greater than 50 W and equal to or less than 100 W, greater than 100 W and less than 150 W (however, including MHLFs designed to operate lamps rated at 150 W and exempted from EISA 2007), equal to or greater than 150 W and less than or equal to 250 W, greater than 250 W and less than or equal to 500 W, and greater than 500 W and less than or equal to 2000 W, respectively.
ULT and NEMA stated that industry data shows ballast losses are significantly higher in 150 W ballasts relative to 175 W to 500 W ballasts due to the increased lamp current in 150 W MHLFs. (ULT, Public Meeting Transcript, No. 48 at p. 108; ULT, No. 50 at pp. 5-6, 23; NEMA, No. 56 at p. 13) ULT explained that for 150 W-175 W fixtures, the lower the wattage, the larger the ballast needed to maintain efficiency. ULT noted that this relationship is the net effect of three main factors: (1) Higher lamp current, (2) increased impedance, and (3) decreased wire cross‐section. In conjunction, these factors make it impossible to have an 88 percent efficient 150 W ballast on a 3.25 inch by 3.75 inch (commonly referred to as a “3x4”) frame. (ULT, No. 50 at pp. 23-24) ULT believed that 150 W fixtures could belong to the lower wattage bin; otherwise, the proposed standards would result in a ban of magnetic autotransformer 150 W ballasts. (ULT, No. 50 at p. 5)
DOE agrees with ULT and NEMA that 150 W ballasts have a lower maximum achievable efficiency relative to 175 W ballasts because of the resistive losses characteristic to ballasts at 150 W. Commercially, DOE also found that 150 W ballasts have a range of efficiencies similar to wattages below 150 W. Both of these trends support 150 W fixtures being categorized in separate equipment classes than 175 W fixtures. While DOE continues to group 150 W fixtures covered by EISA 2007 in the 150 W-250 W equipment class, in this final rule DOE maintains the NOPR approach to group 150 W fixtures previously exempt by EISA 2007 in the 101 W-150 W equipment class.
NEMA proposed that DOE establish a separate equipment class for 575 W ballasts but did not provide supporting detail for this proposal. (NEMA, No. 56 at p. 17) DOE examined the efficiency distribution of 575 W ballasts and found that efficiency varied in a manner similar to that of other ballasts within the 500 W to 1000 W wattage range. DOE is unaware of significant differences in the cost-efficiency relationship, consumer utility, or application of 575W fixtures relative to 1000 W fixtures, and therefore is not establishing a separate equipment class for these MHLFs. DOE continues to group all 501 W-1000 W MHLFs in one wattage bin, using 1000 W fixtures as representative of the entire class.
Musco Lighting disagreed with the grouping of fixtures in the 501 W-2000 W range. Musco Lighting stated that there are significant differences between the markets and applications of 1500 W and 1000 W MHLFs, and, accordingly, they should not be grouped together. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 107) Musco Lighting commented that 1500 W fixtures should not be in the same equipment class as 1000 W fixtures. Musco Lighting commented that a majority of 1500 W fixtures operate at 480 V input, which distinguishes them from other equipment classes. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 129) Musco Lighting further commented that annual operating hours should be taken into account so that MHLFs used in applications with very different operating hours would not be included in the same equipment class. Musco Lighting gave the example of sports lighting having much fewer operating hours than indoor warehouse lighting. (Musco Lighting, Public Meeting Transcript, No. 48 at p. 161)
Upon further review, DOE agrees that there are differences between 1500 W and 1000 W fixtures. DOE determined that the trend between increasing wattage and increasing efficiency found from 501 W-1000 W did not continue above 1000 W. DOE found that above 1000 W, efficiency increased to a lesser extent with increased wattage. This is consistent with the NOPR analysis, in which different equations were used above and below 1000 W. DOE also found that lamp lifetime and annual operating hours are much shorter for 1500 W fixtures relative to 1000 W fixtures because 1500 W fixtures are predominantly used in sports lighting. This causes 1500 W fixtures to have different cost-efficiency relationships relative to 1000 W fixtures. There is also a different cost-efficiency relationship based on the MSP of the fixtures themselves, representing a different portfolio of applications used from 501-1000 W and above 1000 W. Therefore, DOE determined that separate equipment classes should be established for 501 W-1000 W and 1001 W-2000 W fixtures.
25
25
DOE uses this shorthand to refer to MHLFs designed to operate with lamps rated at greater than 500 W and less than or equal to 1000 W, and greater than 1000 W and less than or equal to 2000 W, respectively.
In summary, DOE established MHLF equipment classes by the following rated lamp wattage bins: 50 W-100 W, 101 W-150 W, 150 W-250 W, 251 W-500 W, 501 W-1000 W, and 1001 W-2000 W. DOE maintained that 150 W fixtures previously exempted by EISA 2007 are included in the 101 W-150 W range, while 150 W fixtures subject to EISA 2007 standards are included in the 150 W-250 W range.
c. Fixture Application
MHLFs are used in a variety of applications such as parking lots, roadways, warehouses, big-box retail, and flood lighting. Although the fixture size, shape, and optics are often tailored to the application, generally the same type of ballast is utilized for most of the applications. DOE found in the NOPR, however, that indoor and outdoor MHLFs are subject to separate cost-efficiency relationships, specifically at the electronic ballast levels.
As outdoor applications can be subject to large voltage transients, MHLFs in such applications require 10 kV voltage transient protection. Magnetic MH ballasts are typically resistant to voltage variations of this magnitude, while electronic MH ballasts are generally not as resilient. Therefore, in order to meet this requirement, electronic ballasts in outdoor MHLFs would need either (1) an external surge protection device or (2) internal transient protection of the ballast using metal-oxide varistors (MOVs) in conjunction with other inductors and capacitors.
DOE also noted that indoor fixtures can require the inclusion of a 120 V auxiliary tap. This output is used to operate an emergency incandescent lamp after a temporary loss of power while the MH lamp is still too hot to restart. These taps are generally required for only one out of every ten indoor lamp fixtures. A 120 V tap is easily incorporated into a magnetic ballast due to its traditional core and coil design, and incurs a negligible incremental cost. Electronic ballasts, though, require additional design to add this 120 V auxiliary power functionality.
These added features impose an incremental cost to the ballast or fixture (further discussed in section V.C.12 of this notice). As these incremental costs could affect the cost-effectiveness of fixtures for indoor versus outdoor applications, in the NOPR DOE proposed separate equipment classes for indoor and outdoor fixtures.
DOE proposed that outdoor fixtures be defined as those that (1) are rated for use in wet locations and (2) have 10 kV of voltage transient protection. DOE proposed to define the wet location rating as specified by the National Fire Protection Association (NFPA) 70-2002,
26
section 410.10(A) or UL 1598
Wet Location Listed.
27
Providing two possible definitions will reduce the compliance burden as many manufacturers are already familiar with one or both of these ratings (the NFPA 70-2002 definition was included in EISA 2007 and both are used in California energy efficiency regulations). For 10 kV voltage transient protection, DOE proposed to use the 10 kV voltage pulse withstand requirement from ANSI C136.2-2004.
26
The NFPA 70-2002 states that fixtures installed in wet or damp locations shall be installed such that water cannot enter or accumulate in wiring components, lampholders, or other electrical parts. All fixtures installed in wet locations shall be marked, “Suitable for Wet Locations.” All fixtures installed in damp locations shall be marked
“Suitable for Wet Locations” or “Suitable for Damp Locations.”
27
UL Standard Publication 1598 defines a wet location is one in which water or other liquid can drip, splash, or flow on or against electrical equipment. A wet location fixture shall be constructed to prevent the accumulation of water on live parts, electrical components, or conductors not identified for use in contact with water. A fixture that permits water to enter the fixture shall be provided with a drain hole.
APPA agreed with separating equipment classes for indoor and outdoor fixtures, as they have separate uses that create differences in the frequency and length of use. APPA stated that because the circumstances are different when considering both classes, it is difficult to understand the effects of proposed efficiency standards on each group. (APPA, No. 51 at p. 4; APPA, Public Meeting Transcript, No. 48 at p. 103) Conversely, NEMA noted that separate equipment classes for indoor and outdoor fixtures could be problematic as, at the ballast level, there is no way of knowing whether equipment will be used indoors or outdoors. (NEMA, No. 56 at p. 14) Acuity Brands Lighting, Inc. (Acuity) commented that fixture application should also take into account the probability of transient voltages and extreme conditions, even in indoor applications. (Acuity, Public Meeting Transcript, No. 48 at p. 162) NEMA and ULT suggested combining indoor and outdoor equipment classes, except for electronic ballasts, as fewer classes will mean fewer reporting requirements. NEMA acknowledged that this will conflict with DOE's desire to encourage electronic ballasts in outdoor applications. (NEMA, No. 56 at p. 9; ULT, No. 50 at p. 4)
DOE believes that indoor and outdoor MHLFs should be placed into separate equipment classes. While the efficiencies achievable indoors and outdoors are the same, the different costs between indoor and outdoor fixtures result in different cost-efficiency curves. When electronic ballasts are used in outdoor applications, they require additional transient protection because of the potential for voltage surges in outdoor locations. Indoor fixtures with electronic ballasts also have an added cost to provide 120 V auxiliary power functionality for use in the event of a power outage. Both of these cost adders are discussed in more detail in section V.C.12. As these costs adders differ based on a fixture being used indoors or outdoors, the cost-efficiency relationships differ based on indoor or outdoor application, and therefore separate equipment classes are warranted. Thus, in this final rule DOE establishes separate equipment classes for indoor and outdoor fixtures. DOE defines outdoor fixtures as those that (1) are rated for use in wet locations and (2) have 10 kV of voltage transient protection. Conversely, fixtures that do not meet these requirements will be defined as indoor fixtures. DOE continues to use the wet location rating definition from the National Fire Protection Association 70-2002, section 410.10(A) or UL 1598 Wet Location listing.
d. Electronic Configuration
Of the two MH ballast types (electronic and magnetic), magnetic ballasts are currently more common, making up more than 90 percent of MH ballast shipments. Magnetic ballasts typically use transformer-like copper or aluminum windings on a steel or iron core. The newer electronic ballasts, which are more efficient but less common, rely on integrated circuits, switches, and capacitors or inductors to control current and voltage to the lamp. Both electronic and magnetic ballasts are capable of producing the same light output and, with certain modifications (
e.g.,
thermal management, transient protection, 120 V auxiliary power functionality), can be used interchangeably in all applications. In the NOPR, DOE concluded that electronic configuration and circuit type do not affect consumer utility. With the necessary design alterations, electronic ballasts can provide the same utility as any magnetic ballast circuit type. Because electronic ballasts are typically more efficient than magnetic ballasts, utility is not lost with increasing efficiency. Therefore, DOE did not propose to define equipment classes based on electronic configuration.
ULT stated that electronic HID ballasts were originally intended for indoor, niche purposes. Therefore, automatically expecting that electronic MH ballasts would be able to perform in outdoor conditions, including applications subjected to wind, extreme temperature, and transient surges, is not reasonable. ULT noted that electronic ballasts' vulnerability in outdoor applications is known throughout the industry. (ULT, Public Meeting Transcript, No. 48 at p. 52)
NEMA also disagreed with DOE not dividing equipment classes by electronic configuration. NEMA stated that performance requirements should be separated for electronic and magnetic ballasts to avoid an enormous burden on the industry. (NEMA, No. 56 at p. 12, 24) NEMA commented that they disagreed with DOE's suggestion that an electronic ballast is a design option for a magnetic ballast, as they are completely different technologies. (NEMA, No. 56 at p. 14).
DOE has determined that these electronic ballasts, when fitted in an appropriate fixture, can be used in the same applications as magnetic ballasts. As mentioned in the previous section, various protections will be required for electronic ballasts in these applications. See section V.C.8.b for more detail about the feasibility of electronic ballasts as more efficient replacements for magnetic ballasts. After adjusting outdoor fixture prices to account for the modifications necessary to incorporate electronic ballasts, DOE has found that electronic ballasts can be reliably used in the same outdoor applications as magnetic ballasts. Therefore, DOE did not find that magnetic ballasts provided a unique utility over electronic ballasts. Thus, in this final rule, DOE included electronic and magnetic ballasts in the same equipment class.
e. Circuit Type
NEMA disagreed with DOE not dividing equipment classes by circuit type, citing the fluorescent lamp ballast rule as precedent. (NEMA, No. 56 at pp. 12, 24) ULT and NEMA proposed three different technology classes; magnetic series reactors, magnetic autotransformers, and electronic. (ULT, No. 50 at p. 5; NEMA, No. 44 at p. 17) NEMA explained the need for dividing equipment classes in this way by describing the technologies' different utilities and relationships to efficiency. Specifically, NEMA stated that series reactors circuits are the most efficient, although they do not offer any power regulation. Power factor correction is weak with this ballast type, and high power factor increases total harmonic distortion. This circuit type only works for lamps that require an open circuit voltage lower than the mains. It results in an increased inrush and current, and reduced maximum number of lamps per circuit. (NEMA, No. 44 at p. 18) Autotransformer ballasts may be used on various mains voltages, and the ballast open circuit voltage may be higher than the mains voltage. Constant-wattage autotransformer (CWA) designs
include a secondary coil and operate with lower harmonic distortion. They offer better power regulation than series reactors and are highly reliable. (NEMA, No. 44 at p. 19) Electronic circuits are typically less reliable than autotransformer circuits, but operate with similar energy efficiency to series reactors. (NEMA, No. 44 at p. 20)
DOE agrees that within magnetic ballasts there are multiple circuit types, such as reactor and autotransformer. However, DOE has found that electronic ballasts can provide the same utility as any magnetic circuit type and can be substituted in all applications, while being generally more efficient than all magnetic ballasts. DOE also notes that all of the magnetic ELs in this final rule are determined by autotransformer magnetic ballasts, as autotransformer ballasts are the most common type on the market. Because reactor ballasts are typically more efficient than autotransformer ballasts, DOE found that setting a magnetic ballast EL based on autotransformer efficiency would not prohibit reactor ballasts. For these reasons, DOE did not find it necessary in this final rule to separate equipment classes by circuit type.
f. Summary
DOE developed equipment classes in this final rule using three class-setting factors: input voltage, rated lamp wattage, and fixture application. DOE presents the resulting equipment classes in Table V.1
Table V.1—MHLF Equipment Classes Table
Designed to be operated with lamps of the following
rated lamp wattage
Indoor/outdoor †
Input voltage
type‡
≥50 W and ≤100 W
Indoor
Tested at 480 V.
≥50 W and ≤100 W
Indoor
All others.
≥50 W and ≤100 W
Outdoor
Tested at 480 V.
≥50 W and ≤100 W
Outdoor
All others.
>100 W and <150 W *
Indoor
Tested at 480 V.
>100 W and <150 W *
Indoor
All others.
>100 W and <150 W *
Outdoor
Tested at 480 V.
>100 W and <150 W *
Outdoor
All others.
≥150 W ** and ≤250 W
Indoor
Tested at 480 V.
≥150 W ** and ≤250 W
Indoor
All others.
≥150 W ** and ≤250 W
Outdoor
Tested at 480 V.
≥150 W ** and ≤250 W
Outdoor
All others.
>250 W and ≤500 W
Indoor
Tested at 480 V.
>250 W and ≤500 W
Indoor
All others.
>250 W and ≤500 W
Outdoor
Tested at 480 V.
>250 W and ≤500 W
Outdoor
All others.
>500 W and ≤1000 W
Indoor
Tested at 480 V.
>500 W and ≤1000 W
Indoor
All others.
>500 W and ≤1000 W
Outdoor
Tested at 480 V.
>500 W and ≤1000 W
Outdoor
All others.
>1000 W and ≤2000 W
Indoor
Tested at 480 V.
>1000 W and ≤2000 W
Indoor
All others.
>1000 W and ≤2000 W
Outdoor
Tested at 480 V.
>1000 W and ≤2000 W
Outdoor
All others.
* Includes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A);); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
** Excludes 150 W MHLFs exempted by EISA 2007, which are MHLFs rated only for 150 W lamps; rated for use in wet locations, as specified by the NFPA 70-2002, section 410.4(A);); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029-2007.
† DOE's proposed definitions for “indoor” and “outdoor” MHLFs are described in section V.A.2.c.
‡ Input voltage for testing would be specified by the test procedures. Ballasts rated to operate lamps less than 150 W would be tested at 120 V, and ballasts rated to operate lamps ≥150 W would be tested at 277 V. Ballasts not designed to operate at either of these voltages would be tested at the highest voltage the ballast is designed to operate. See section IV.A for further detail.
B. Screening Analysis
For the screening analysis, DOE consults with industry, technical experts, and other interested parties to determine which technology options to consider further and which to screen out. Appendix A to subpart C of 10 CFR Part 430, “Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products” (the Process Rule), sets forth procedures to guide DOE in its consideration and promulgation of new or revised energy conservation standards. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 6295(o) and, in part, eliminate problematic technologies early in the process of prescribing or amending an energy conservation standard. In particular, sections 4(b)(4) and 5(b) of the Process Rule provide guidance to DOE for determining which design options are unsuitable for further consideration:
Technological feasibility. DOE will consider technologies incorporated in commercial products or in working prototypes to be technologically feasible.
Practicability to manufacture, install, and service. If mass production and reliable installation and servicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE will consider that technology practicable to manufacture, install, and service.
Adverse impacts on product utility or product availability. If DOE determines a technology would have significant adverse impacts on the utility of the product to significant subgroups of consumers, or would result in the unavailability of any covered equipment type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as equipment generally available in the United States
at the time, it will not consider this technology further.
Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider this technology further.
In the NOPR, DOE screened out one technology option: laminated sheets of amorphous steel. For magnetic metal halide ballasts, DOE found one method of decreasing transformer losses is to create the core of the inductor from laminated sheets of amorphous steel, insulated from each other. DOE screened out amorphous steel technology because it failed to pass the “practicable to manufacture, install, and service” criterion, and using amorphous steel could have adverse impacts on consumer utility because increasing the size and weight of the ballast may limit the places a customer could use the ballast. DOE received no comments to the contrary, and thus continues to screen out amorphous steel in the final rule.
DOE identified the design options listed in Table V.2 as technologies that could improve MHLF ballast efficiency and pass the screening criteria discussed above. For further details on these design options, see chapter 3 of the final rule TSD.
Table V.2—Metal Halide Lamp Fixture Design Options
Ballast type
Design option
Description
Magnetic
Improved Core Steel
Use a higher grade of electrical steel, including grain-oriented silicon steel, to lower core losses.
Copper Wiring
Use copper wiring in place of aluminum wiring to lower resistive losses.
Increased Stack Height
Add steel laminations to lower core losses.
Increased Conductor Cross Section
Increase conductor cross section to lower winding losses.
Electronic Ballast
Replace magnetic ballasts with electronic ballasts.
Electronic
Improved Components
Magnetics
Use grain-oriented or amorphous electrical steel to reduce core losses.
Use optimized-gauge copper or litz wire to reduce winding losses.
Add steel laminations to lower core losses.
Increase conductor cross section to lower winding losses.
Diodes
Use diodes with lower losses.
Capacitors
Use capacitors with a lower effective series resistance and output capacitance.
Transistors
Use transistors with lower drain-to-source resistance.
Improved Circuit Design
Integrated Circuits
Substitute discrete components with an integrated circuit.
C. Engineering Analysis
1. Approach
The engineering analysis develops cost-efficiency relationships depicting the manufacturing costs of achieving increased ballast efficiency. DOE applies two methodologies to estimate manufacturing costs for the engineering analysis: (1) The design-option approach, which provides the incremental costs of adding the design options discussed in section V.B of this notice to improve the efficiency of a baseline model; and (2) the efficiency-level approach, which estimates the costs of achieving increases in ELs through ballast efficiency testing, manufacturer catalogs, and teardowns. Details of the engineering analysis are in chapter 5 of the final rule TSD. The following discussion summarizes the general steps of the engineering analysis:
Determine Representative Equipment Classes.
When multiple equipment classes exist, to streamline testing and analysis, DOE selects certain classes as “representative,” primarily because of their high market volumes. DOE then scales the ELs from representative equipment classes to those equipment classes it does not analyze directly.
Determine Representative Wattages.
Within each representative equipment class, DOE also selects a particular wattage fixture as “representative” of the wattage range, primarily because of their high market volumes. In this final rule, DOE assigns only one representative wattage per representative equipment class.
Representative Fixture Types.
To calculate the typical cost of a fixture at each representative wattage, DOE selects certain types of fixtures to analyze as representative.
Select Baseline Units.
DOE establishes a baseline unit for each representative wattage. The baseline unit has attributes (circuit type, input voltage capability, electronic configuration) typical of ballasts used in fixtures of that wattage. The baseline unit also has the lowest (baseline) efficiency for each representative wattage. DOE measures changes resulting from potential amended energy conservation standards compared with this baseline. For fixtures subject to existing federal energy conservation standards, a baseline unit is a MHLF with a commercially available ballast that just meets existing standards. If no standard exists for a fixture, the baseline unit is the MHLF at a representative wattage with a ballast with the lowest tested ballast efficiency that is sold. To determine energy savings and changes in price, DOE compares each higher EL with the baseline unit.
To determine the ballast efficiency, DOE tested a range of MH ballasts from multiple ballast manufacturers. In some cases, when test data was unavailable, DOE used efficiency values listed in manufacturer catalog data sheets. Appendix 5A of the final rule TSD presents the test results. When necessary, DOE selects more than one baseline for a representative wattage to ensure consideration of different fixture and ballast types and their associated customer economics.
Select More-Efficient Units.
DOE selected both commercially available MHLFs and modeled MHLFs with higher-than-baseline-efficiency ballasts as replacements for each baseline model in each representative equipment class. In general, DOE can identify the design options associated with each more-efficient ballast model by considering the design options that meet the criteria of the screening analysis (chapter 4 of the final rule TSD). For electronic ballasts, where design options cannot be identified for that class by the product number or catalog description, DOE
conducts testing to determine their efficiency. Appendix 5A of the final rule TSD presents these test results. These ballast efficiencies were calculated according to the MH ballast test procedures (10 CFR 431.324), unless otherwise specified. DOE estimates the design options likely to be used to achieve a higher efficiency based on information gathered during manufacturer interviews and information presented in ballast catalogs.
Determine Efficiency Levels.
DOE develops ELs based on: (1) The design options associated with the equipment class studied and (2) the max-tech EL for that class. As previously noted and as discussed in section IV.B.2, DOE's ELs are based on test data collected from commercially available equipment, catalog data, manufacturer input, and ballast modeling.
Conduct Price Analysis.
DOE generated a bill of material (BOM) by disassembling multiple manufacturers' ballasts from a range of ELs and fixtures that span a range of applications for each equipment class. The BOMs describe the equipment in detail, including all manufacturing steps required to make and assemble each part. DOE then developed a cost model to convert the BOMs for each representative unit into manufacturer production costs (MPCs). By applying derived manufacturer markups to the MPCs, DOE calculated the MSPs
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and constructed industry cost-efficiency curves. In cases where DOE was not able to generate a BOM for a given ballast, DOE estimated an MSP based on the relationship between teardown data and retail data. DOE also estimated ballast and fixture cost adders necessary to allow replacement of more-efficient substitutes for baseline models.
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The MSP is the price at which the manufacturer can recover all production and non-production costs and earn a profit. Non-production costs include selling, general, and administration (SG&A) costs, the cost of R&D, and interest.
2. Representative Equipment Classes
As described in the previous section, DOE selects certain equipment classes as “representative” to focus its analysis. The 24 equipment classes (based on rated lamp wattage, indoor or outdoor designation, and test voltage) and the criteria used for development are presented in section V.A.2. Due to their low shipment volume (as indicated through manufacturer interviews), DOE does not directly analyze the equipment classes containing only fixtures with ballasts tested at 480 V. DOE selected all other equipment classes as representative, resulting in a total of 12 representative classes that cover the full range of lamp wattages, as well as indoor and outdoor designations. DOE had only analyzed 10 representative equipment classes in the NOPR. This increase is a result of DOE's decision to split the 501 W-2000 W equipment classes into 501 W-1000 W and 1001 W-2000 W. This new equipment class structure is discussed in section V.A.2.
3. Representative Wattages
In the NOPR, DOE selected five representative wattages of MHLFs (70 W, 150 W, 250 W, 400 W, and 1000 W) to analyze in the engineering analysis. Each representative wattage was typically the most commonly sold wattage within each equipment class, based on analysis of fixture availability from catalogs and manufacturer input.
As discussed in section V.A.2, DOE has split the 501 W-2000 W equipment classes from the NOPR into 501 W-1000 W and 1001 W-2000 W in the final rule. From 501 W-1000 W, DOE still finds 1000 W to be an appropriate representative wattage based on it being the most commonly sold. In the final rule, DOE is analyzing 1500 W as the representative wattage for the 1001 W-2000 W equipment classes based on this wattage being the most commonly shipped in the wattage range.
4. Representative Fixture Types
After selecting representative wattages for analysis, DOE identified the applications commonly served by each equipment class's wattage range in order to select representative fixture types. DOE recognizes that technological changes in the ballast caused by standards considered in this rulemaking, especially moving from magnetic ballasts to electronic ballasts, could necessitate alterations to the fixture. These changes often incur additional costs depending on the fixture type that needs to be altered. In the engineering analysis, DOE estimates a baseline fixture cost, as well as incremental costs to the fixture based on the type of ballast used (
e.g.,
electronic ballasts require specific fixture adaptations that magnetic ballasts do not). The cost adders to the fixtures are discussed in section V.C.12.
In the NOPR, DOE selected one to three representative fixture types for each rated wattage range based on the most common application(s) within that range. For the 50 W-100 W range, DOE selected canopy fixtures as the representative fixture types. For the 101 W-150 W and 150 W-250 W range, DOE selected canopy, low bay, and wallpack fixtures as representative fixture types. For wattages greater than 250 W, DOE chose canopy, flood, and high bay fixtures as representative fixture types.
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Descriptions of each of these fixtures types can be found in chapter 3 of the final rule TSD.
In this final rule, DOE has expanded its analysis of representative fixtures to account for separate uses in indoor and outdoor applications. This allows DOE to develop separate prices for indoor and outdoor fixtures, taking into account the weather protection built into outdoor fixtures. The new representative fixture types, which include from one to four applications for each equipment class, are shown in Table V.3.
Table V.3—Representative Wattages and Fixtures
Designed to be operated with lamps of the following rated lamp wattage
Representative wattage
Representative fixture types
Indoor
Outdoor
≥50 W and ≤100 W
70 W
Recessed Can
Wallpack, Post Top, Flood.
>100 W and <150 W *
150 W
Low Bay
Parking Lot, Area, Wallpack, Flood.
≥150 W and ≤250 W **
250 W
Low Bay
Area, Flood, Wallpack.
>250 W and ≤500 W
400 W
Flood, High Bay
Pole Top, Flood.
>500 W and ≤1000 W
1000 W
High Bay
Flood, Sports.
>1000 W and ≤2000 W
1500 W
Sports
Sports.
* Includes 150 W fixtures exempted by EISA 2007, which are fixtures rated only for 150 W lamps; rated for use in wet locations, as specified
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