[Federal Register Volume 79, Number 203 (Tuesday, October 21, 2014)]
[Proposed Rules]
[Pages 62910-62928]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-24971]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE-2010-BT-STD-0043]
RIN 1904-AC36
Energy Conservation Program: Energy Conservation Standards for
High-Intensity Discharge Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed determination (NOPD).
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, requires DOE to prescribe test procedures and energy
conservation standards for high-intensity discharge (HID) lamps for
which it has determined that standards would be technologically
feasible and economically justified, and would result in significant
energy savings. In this notice, DOE proposes to determine that energy
conservation standards for high-intensity discharge (HID) lamps do not
meet these criteria.
DATES: DOE will accept comments, data, and information regarding this
NOPD no later than December 22, 2014. Interested parties may further
request, no later than November 5, 2014, a public meeting to discuss
this NOPD. See section VII Public Participation for details.
ADDRESSES: Any comments submitted must identify the NOPD for Energy
Conservation Standards for High-Intensity Discharge Lamps and provide
docket number EE-2010-BT-STD-0043 and/or regulatory information number
(RIN) 1904-AC36. Comments may be submitted using any of the following
methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: [email protected]. Include the docket
number and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW.,
Washington, DC 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section VII of this document
(Public Participation).
Docket: The docket is available for review at www.regulations.gov,
including Federal Register notices, framework documents, public meeting
attendee lists and transcripts, comments, and other supporting
documents/materials. All documents in the docket are listed in the
www.regulations.gov index. However, not all documents listed in the
index may be publicly available, such as information that is exempt
from public disclosure.
The docket Web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. This Web page
contains a link to the docket for this notice on the regulations.gov
site. The regulations.gov Web page contains simple instructions on how
to access all documents, including public comments, in the docket. See
section VII for further information on how to submit comments through
www.regulations.gov.
For further information on how to submit a comment or review other
public comments and the docket, contact Ms. Brenda Edwards at (202)
586-2945 or by email: [email protected].
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone:
(202) 287-1604. Email: [email protected].
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-7796. Email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Determination
A. Legal Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for High-Intensity Discharge
Lamps
3. Changes From the 2010 Determination
a. Color
b. Replacement Options
c. Shipments
d. Summary of Changes
II. Issues Affecting the Lamps Analyzed by This Determination
A. Lamps Analyzed by This Determination
B. Standby/Off Mode
C. Metric
D. Coordination of the Metal Halide Lamp Fixture and HID Lamp
Rulemakings
III. General Discussion
A. Test Procedures
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
IV. Methodology and Discussion
A. Market and Technology Assessment
1. General
2. Equipment Classes
3. Technology Options
a. Mercury Vapor
b. High-Pressure Sodium Lamps
c. Metal Halide
d. Summary
B. Screening Analysis
C. Engineering Analysis
1. Representative Equipment Classes
2. Baseline Lamps and Representative Lamp Types
3. More Efficacious Substitutes
4. Determine Efficacy Levels
5. Scaling to Equipment Classes Not Directly Analyzed
6. HID Systems
D. Equipment Price Determination
E. Markups Analysis
F. Energy Use Analysis
G. Life-Cycle Cost and Payback Period Analysis
H. Shipments Analysis
I. National Impact Analysis
J. Manufacturer Impact Analysis
V. Analytical Results
A. Economic Impacts on Individual Customers
B. Economic Impacts on Manufacturers
1. Industry Cash-Flow Analysis Results
2. Impacts on Employment
3. Impacts on Manufacturing Capacity
4. Impacts on Subgroups of Manufacturers
[[Page 62911]]
5. Cumulative Regulatory Burden
C. National Impact Analysis
1. Significance of Energy Savings
2. Net Present Value of Customer Costs and Benefits
D. Proposed Determination
1. Technological Feasibility
2. Significance of Energy Savings
3. Economic Justification
4. Conclusions
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
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
VII. Public Participation
A. Public Meeting Requests
B. Submission of Comments
C. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Summary of the Proposed Determination
DOE proposes to determine that energy conservation standards for
HID lamps do not meet the EPCA requirements described in section I.A,
that such standards be technologically feasible, economically
justified, and result in a significant conservation of energy. (42
U.S.C. 6317(a)(1)) Specifically, DOE concludes that standards for high-
pressure sodium (HPS) lamps are not technologically feasible, and that
standards for mercury vapor (MV) and metal halide (MH) lamps are not
economically justified (HPS, MV, and MH lamps are subcategories of HID
lamps). DOE's proposed determination is based on analysis of several
efficacy levels (ELs) as a means of conserving energy. These analyses
and DOE's results are described in the following sections of this
notice and in the notice of proposed determination (NOPD) technical
support document (TSD).
A. Legal Authority
Title III of EPCA (42 U.S.C. 6291, et seq), Public Law 94-163, sets
forth a variety of provisions designed to improve energy efficiency.
Part C of title III, which for editorial reasons was re-designated as
Part A-1 upon incorporation into the U.S. Code (42 U.S.C. 6311-6317),
establishes the ``Energy Conservation Program for Certain Industrial
Equipment,'' a program covering certain industrial equipment, which
include the HID lamps that are the subject of this proposed
determination. Pursuant to EPCA, DOE must prescribe test procedures and
energy conservation standards for HID lamps for which DOE has
determined that standards would be technologically feasible,
economically justified, and would result in a significant conservation
of energy. (42 U.S.C. 6317(a)(1))
B. Background
1. Current Standards
There are currently no Federal energy conservation standards for
HID lamps.
2. History of Standards Rulemaking for High-Intensity Discharge Lamps
Pursuant to EPCA, in 2010 DOE published a final determination \1\
(hereafter the ``2010 determination'') that standards for certain HID
lamps are technologically feasible, economically justified, and would
result in significant energy savings (a positive determination). 75 FR
37975 (July 1, 2010). As a result of the 2010 determination, DOE
initiated a test procedure rulemaking for the specified lamps (see
section III.A).
---------------------------------------------------------------------------
\1\ The final determination is available at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/60.
---------------------------------------------------------------------------
DOE also initiated an energy conservation standards rulemaking in
response to the 2010 determination. On February 28, 2012, DOE published
in the Federal Register an announcement of the availability of a
framework document for energy conservation standards for HID lamps, as
well as a notice of a public meeting. DOE held a public meeting on
March 29, 2012, to receive feedback in response to the framework
document.
DOE gathered additional information and performed interim analyses
to develop potential energy conservation standards for HID lamps. On
February 28, 2013, DOE published in the Federal Register an
announcement of the availability of the interim technical support
document (the interim TSD) and notice of a public meeting (hereafter,
the ``February 2013 notice'') 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 used to
evaluate standards; (3) the results of the interim analyses performed
by DOE; and (4) potential standard levels that DOE could consider. 78
FR 13566. In the February 2013 notice, DOE requested comment on issues
that would affect energy conservation standards for HID lamps or that
DOE should address in the following analysis stage. The interim TSD is
available at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23.
The interim TSD summarized the activities DOE undertook in
developing standards for HID lamps. It also described the analytical
framework that DOE uses in a typical energy conservation standards
rulemaking, including a description of the methodology, the analytical
tools, and the relationships among the various analyses that are part
of the rulemaking. The interim TSD presented and described in detail
each analysis DOE performed, including descriptions of inputs, sources,
methodologies, and results.
The public meeting for the interim analysis took place on April 2,
2013. At this meeting, DOE presented the methodologies and results of
the analyses set forth in the interim TSD. Interested parties discussed
the following major issues at the public meeting: the scope of the
interim analysis, equipment classes, sapphire arc tube technology, the
engineering analysis (including the representative units, baselines,
and candidate standard levels [CSLs]), the life-cycle cost (LCC) and
payback period (PBP) analysis, and the shipment analysis.
All comments received by DOE in response to the framework document
were considered when performing the interim analysis for HID lamps.
Chapter 2 of this NOPD TSD summarizes and responds to comments received
on the framework document and the interim analysis.
After revising the interim analyses based on stakeholder comments
and updated information, DOE proposes in this NOPD to determine that
standards for HID lamps are no longer justified based on technological
feasibility and economic justification.
3. Changes From the 2010 Determination
As discussed previously, DOE published a determination in 2010 that
concluded that standards for certain HID lamps would be technologically
feasible, economically justified, and would result in significant
energy savings. 75 FR 37975 (July 1, 2010) Since the publication of the
2010 determination, DOE held public meetings and received written
comments, conducted interviews with
[[Page 62912]]
manufacturers, and conducted additional research. Based upon this new
information, DOE revised its analyses for potential HID lamp energy
conservation standards. The following sections summarize the major
changes in assumptions and analyses between the 2010 determination and
this NOPD, in which DOE proposes to determine that standards for HID
lamps would not be technologically feasible and economically justified,
and would not result in significant energy savings.
a. Color
In contrast to the 2010 determination, DOE established separate
equipment classes based on correlated color temperature (CCT) in the
interim analysis and in this NOPD. CCT represents the color appearance
of a light source and is expressed in kelvins (K). The higher the CCT,
the cooler or more blue the light appears, and the lower the CCT, the
warmer or more red the light appears. HID lamps are available with a
wide range of CCT values depending on lamp type and design. DOE's
analysis of commercially available lamp catalog data concluded that CCT
is correlated with lamp efficacy. DOE determined that higher-CCT lamps
were less efficacious than lower CCT lamps of the same wattage. Because
CCT is an approximation of the color appearance of a lamp, customers
typically specify different CCTs for different applications. Some lamp
substitutions are not suitable because certain applications have
specific color requirements (typically indoor applications that demand
white light). Because CCT affects HID lamp efficacy and impacts
consumer utility, DOE has established separate equipment classes based
on CCT.
DOE established equipment classes based on three different ranges
of CCT. HPS lamps were included in the 1900 K-2800 K equipment class
while MH lamps were included in the 2800 K-4500 K or 4500 K-7000 K
equipment classes. DOE investigated higher efficacy replacement options
for HPS lamps such that customers could save energy while maintaining
the utility (e.g., CCT) of the lamp type. As discussed in section
IV.A.3, DOE concluded no technology options exist for improving the
efficacy of HPS lamps. Therefore, DOE tentatively determined standards
for HPS lamps are not technologically feasible in this NOPD.
b. Replacement Options
In the 2010 determination, DOE assumed that any customer purchasing
a compliant lamp would choose a reduced-wattage lamp more efficacious
than their existing non-compliant lamp. However, DOE received feedback
from manufacturer interviews that not all customers would choose to
reduce wattage in response to standards for HID lamps. Some customers
would choose to continue using their existing wattage (e.g., a more-
efficacious, increased lumen output lamp that complies with standards,
but has the same wattage) for the convenience and lower cost of not
purchasing a new fixture and/or ballast that may be necessary for use
with the reduced-wattage lamp. During interviews, manufacturers also
indicated that some customers may not understand the metrics used to
measure light output and would opt to keep lamps at their existing
wattage because wattage is the metric they most commonly consider for
lighting. The result for these customers would be an increase in light
output, but no energy savings. As a result of this information, DOE
models a percentage of customers replacing lamps with more efficacious,
equal wattage lamps in this NOPD. The results of the model indicate a
reduced potential for energy savings and corresponding operating cost
savings associated with HID lamp standards. See chapter 5 of the NOPD
TSD for more details about the engineering analysis and chapter 12 of
the NOPD TSD for more detail about the national impact analysis (NIA).
c. Shipments
For the 2010 determination, DOE calculated the installed base of
HID lamps using historical shipments data provided by the National
Electrical Manufacturers Association (NEMA). DOE projected future lamp
shipments based on the lamp lifetimes and operating scenarios developed
for the LCC and PBP analysis, as well as estimated market and
substitution trends in the base case and standards case. 75 FR 37975,
37981 (July 1, 2010). The shipments analysis and NIA for this NOPD (see
sections IV.H and IV.I) draw upon the same historical NEMA lamp
shipments data in calculating the installed base of HID lamps,
supplemented with additional shipments data and manufacturer input on
HID market trends. DOE's current projections illustrate a sharper
decline in and lower overall HID lamp shipments than projected in the
2010 determination.
d. Summary of Changes
Since the publication of the 2010 determination, DOE received
additional information from public meetings, written comments,
manufacturer interviews, and further research. This new information led
to the following major changes presented in this NOPD: (1) The
determination that equipment classes should be separated based on CCT;
(2) the introduction of a percentage of customers replacing lamps with
more efficacious, equal wattage lamps in response to potential
standards; and (3) the revision downward of projected HID lamp
shipments in the shipments analysis, based on supplemental data and
collected manufacturer input on HID market trends. As a result of the
update regarding separate equipment classes for CCT, DOE tentatively
determined that standards for HPS lamps are not technologically
feasible in this NOPD. Additionally, as a result of the updates
regarding customers replacing lamps with equal wattage lamps and
supplemental shipment data, the NIA yielded negative NPVs in this NOPD
(see section V.C for a discussion of NIA results in the NOPD). As such,
DOE tentatively proposes to determine that standards for MV and MH
lamps would not be economically justified.
II. Issues Affecting the Lamps Analyzed by This Determination
A. Lamps Analyzed by This Determination
HID is the generic name for a family of lamps including MV, MH, and
HPS lamps. Although low-pressure sodium lamps are often included in the
family, the definition of HID lamp set forth in EPCA requires the arc
tube wall loading to be greater than three watts per square centimeter.
(42 U.S.C. 6291(46)) Because low-pressure sodium lamps do not satisfy
this requirement, they are not considered HID lamps according to the
statute, and are therefore not considered in this NOPD. Definitions for
these lamps are discussed in chapter 2 of the NOPD TSD.
DOE first analyzed the potential energy savings of the HID lamp
types that fall within the EPCA definition of ``HID lamp'', as well as
the technological feasibility of more efficient lamps for each type.
For the HID lamps that passed those criteria, DOE conducted a full
economic analysis with the LCC analysis, NIA, and manufacturer impact
analysis (MIA) (see sections IV.G, IV.I, and IV.J) to determine whether
standards would be economically justified.
After considering the comments on the interim analysis, and
additional feedback from manufacturer interviews, DOE determined that
there are no design options to increase the efficacy of HPS lamps,
indicating that standards for this lamp technology are not
[[Page 62913]]
technologically feasible. Specifically, DOE determined that sapphire
arc tube technology is not a valid technology option for increased
efficacy in HPS lamps (see section IV.B for further details).
Available information indicates that energy conservation standards
for certain MV and MH lamps are both technologically feasible and would
save a significant amount of energy. Therefore, DOE conducted the full
economic analysis for those lamp types to determine whether standards
would be economically justified. Specifically, DOE analyzed the
economic justification of potential energy conservation standards for
MH lamps with a rated wattage of greater than or equal to 50 watts (W)
and less than or equal to 2000 W, and CCTs greater than or equal to
2800 K and less than 7000 K. DOE also analyzed the economic
justification of energy conservation standards for MV lamps with a
rated wattage greater than or equal to 50 W and less than or equal to
1000 W, and CCTs greater than or equal to 3200 K and less than or equal
to 6800 K. Table II.1 provides a summary of the HID lamps analyzed.
Table II.1--CCT and Wattage Ranges Analyzed
------------------------------------------------------------------------
Lamp type Wattage CCT
------------------------------------------------------------------------
MV...................................... 50 W-1000 W 3200 K-6800 K.
MH...................................... 50 W-2000 W 2800 K-6999 K.
------------------------------------------------------------------------
In summary, DOE excluded the following HID lamps from its analysis
based on those lamps not meeting the criteria of potential for
significant energy savings or technological feasibility:
HPS lamps;
directional HID lamps;
self-ballasted HID lamps;
lamps designed to operate exclusively on electronic
ballasts;
high-color rendering index (CRI) lamps (a CRI greater than
or equal to 95);
colored MH lamps (a CRI of less than 40);
MV lamps that are double-ended, have a non-screw base, and
have no outer bulb;
HID lamps that have a CCT of 5000 K-6999 K, have a non-
screw base, and have non-T-shaped bulbs; and
electrodeless HID lamps.
See chapter 2 of the NOPD TSD for a more detailed discussion of
which HID lamps did and did not meet the criteria for analysis and of
the rationale behind those selections.
B. Standby/Off Mode
EPCA defines active mode as the condition in which an energy-using
piece of equipment is connected to a main power source, has been
activated, and provides one or more main functions (42 U.S.C.
6295)(gg)(1)(A)). Standby mode is defined as the condition in which an
energy-using piece of equipment is connected to a main power source and
offers one or more of the following user-oriented or protective
functions: facilitating the activation or deactivation of other
functions (including active mode) by remote switch (including remote
control), internal sensor, or timer; or providing continuous functions,
including information or status displays (including clocks) or sensor-
based functions. Id. Off mode is defined as the condition in which an
energy-using piece of equipment is connected to a main power source,
and is not providing any standby or active mode function. Id.
DOE conducted an analysis of the applicability of standby mode and
off mode energy use for HID lamps. DOE tentatively determined that HID
lamps that are subject of this NOPD do not operate in standby mode or
off mode. HID lamps do not offer any secondary user-oriented or
protective functions or continuous standby mode functions. Because all
energy use of HID lamps is accounted for in the active mode, DOE does
not analyze potential standards for lamp operation in standby and off
mode in this NOPD.
C. Metric
To analyze energy conservation standards related to HID lamps, DOE
must select a metric for rating the performance of the lamps. In the
framework document and interim analysis, DOE considered a number of
potential metrics for the energy conservation standards of HID lamps
and requested comment. In response to comments received and based on
DOE's own analysis, DOE used initial efficacy for consideration and
analysis of energy conservation standards for HID lamps. For a full
description of metrics explored and discussion of stakeholder comments,
see chapter 2 of the NOPD TSD.
D. Coordination of the Metal Halide Lamp Fixture and HID Lamp
Rulemakings
For this NOPD, DOE continued to use shared data sources between the
metal halide lamp fixture (MHLF) standards rulemaking \2\ and this HID
lamp determination. DOE's analysis of HID lamps assumes that MHLFs
purchased after the compliance date of the MHLF final rule use ballasts
compliant with those standards.
---------------------------------------------------------------------------
\2\ A final rule for MHLF energy conservation standards was
published in February 2014. For more information on the MHLF
standards rulemaking, see http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16.
---------------------------------------------------------------------------
III. General Discussion
A. Test Procedures
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6314)
Manufacturers of covered equipment must use these test procedures to
certify to DOE that their equipment complies with EPCA energy
conservation standards and to quantify the efficiency of their
equipment. Also, these test procedures must be used whenever testing is
required in an enforcement action to determine whether covered
equipment complies with EPCA standards.
Based on comments received on the HID lamps test procedures notice
of proposed rulemaking (NOPR) and subsequent additional research, DOE
proposed revisions to and clarification of the proposed HID lamp test
procedures. DOE published these revisions and clarifications in a test
procedure supplemental notice of proposed rulemaking (SNOPR).\3\ 79 FR
29631 (May 22, 2014). The analysis in this NOPD is based upon the test
procedures put forward in the test procedure SNOPR.
---------------------------------------------------------------------------
\3\ The HID lamp test procedure SNOPR is available at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/21.
---------------------------------------------------------------------------
B. Technological Feasibility
1. General
In this NOPD, DOE conducted a screening analysis based on
information gathered on all current technology options and prototype
designs that could improve the efficacy of HID lamps. As the first step
in such an analysis, DOE developed a list of technology options for
consideration in consultation with manufacturers, design engineers, and
other interested parties. DOE then determined which of those means for
improving efficacy are technologically feasible. DOE considers
technologies incorporated in commercially available products or in
working prototypes to be technologically feasible, pursuant to 10 CFR
part 430, subpart C, appendix A, section 4(a)(4)(i).
After DOE has determined that particular technology options are
[[Page 62914]]
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; and (3) adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
4(a)(4)(ii)-(iv). For further details on the screening analysis, see
section IV.B of this NOPD and chapters 2 and 4 of the NOPD TSD.
2. Maximum Technologically Feasible Levels
When DOE analyzes a new standard for a type or class of covered
product, it must determine the maximum improvement in energy efficiency
or maximum reduction in energy use that is technologically feasible for
that product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering
analysis, DOE determined the maximum technologically feasible (``max-
tech'') improvements in energy efficacy for HID lamps, using the design
parameters for the most efficacious products available on the market or
in working prototypes. (See chapter 5 of the NOPD TSD.) The max-tech
levels that DOE determined for this NOPD are described in chapters 2
and 5 of the NOPD TSD.
C. Energy Savings
1. Determination of Savings
For each EL in each equipment class, DOE projected energy savings
for the equipment that is the subject of this NOPD purchased in the 30-
year period that would begin in the expected year of compliance with
any new standards (2017-2046). The savings are measured over the entire
lifetime of equipment purchased in the 30-year analysis period.\4\ DOE
quantified the energy savings attributable to each EL 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 mandatory efficacy standards, and it considers market
forces and policies that affect demand for more efficient equipment.
---------------------------------------------------------------------------
\4\ 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
potential standards for the equipment that are the subject of this
NOPD. The NIA spreadsheet model (described in section IV.I of this
notice) calculates energy savings in site energy, which is the energy
directly consumed by equipment at the locations where they are used.
DOE reports national energy savings on an annual basis in terms of the
source (primary) energy savings, which is the savings in the energy
that is used to generate and transmit the site energy. To convert site
energy to source energy, DOE derived annual conversion factors from the
model used to prepare the Energy Information Administration's (EIA's)
Annual Energy Outlook 2013 (AEO2013).
DOE has begun to also estimate full-fuel-cycle (FFC) energy
savings. 76 FR 51282 (August 18, 2011), as amended at 77 FR 49701
(August 17, 2012). The 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.\5\ The NAS report
discusses that FFC was primarily intended for energy efficiency
standards rulemakings where multiple fuels may be used by particular
equipment. In the case of this NOPD pertaining to HID lamps, 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 rulemakings is consistent with the recommendations, the
methodology for estimating FFC does not project how fuel markets would
respond to a potential 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 NOPD. It is also important to note that
inclusion of FFC savings does not affect DOE's choice of potential
standards. For more information on FFC energy savings, see section IV.I
of this notice, and chapter 11 and appendix 11A of the NOPD TSD.
---------------------------------------------------------------------------
\5\ ``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
To adopt standards that are more stringent for a covered product,
DOE must determine that such action would result in ``significant''
energy savings. 42 U.S.C. 6295(o)(3)(B) 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 the context of EPCA to be savings that were not
``genuinely trivial.'' DOE analyzed the energy savings for each
potential standard level for each equipment class in this NOPD
(presented in section V.C.1).
D. Economic Justification
In determining whether potential energy conservation standards for
HID lamps would be economically justified, DOE analyzed the results of
the following analyses: (1) A market and technology assessment that
characterizes where and how HID lamps are used; (2) an engineering
analysis that estimates the relationship between product costs and
energy use; (3) an LCC and PBP analysis that estimates the costs and
benefits to users from increased efficacy in HID lamps; (4) an NIA that
estimates potential energy savings on a national scale and potential
economic costs and benefits that would result from improving energy
efficacy in the considered HID lamps; and (5) an MIA that determines
the potential impact new standards for HID lamps would have on
manufacturers.
IV. Methodology and Discussion
A. Market and Technology Assessment
1. General
In conducting the market and technology assessment for this NOPD,
DOE developed information that provides an overall picture of the
market for the equipment concerned, including the purpose of the
products, the industry structure, and the market characteristics. This
activity included both quantitative and qualitative assessments based
on publicly available information. The subjects addressed in the market
and technology assessment for this NOPD include: Equipment classes and
manufacturers; historical shipments; market trends; regulatory and non-
regulatory programs; and technologies that could improve the efficacy
of the HID lamps under examination. See chapter 3 of the NOPD TSD for
further discussion of the market and technology assessment.
[[Page 62915]]
2. Equipment Classes
For this NOPD, DOE divided equipment into classes by: (a) The type
of energy used, (b) the capacity of the equipment, or (c) any other
performance-related features that justifies different standard levels,
such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE
then considers establishing separate standard levels for each equipment
class based on the criteria set forth in 42 U.S.C. 6295(o).
In this NOPD, DOE analyzed CCT, wattage, bulb finish, and luminaire
characteristics as the equipment-class-setting factors. DOE analyzed 24
equipment classes for HID lamps, as shown in Table IV.1. See chapters 2
and 3 of the NOPD TSD for a more detailed discussion on equipment
classes analyzed for HID lamps.\6\
---------------------------------------------------------------------------
\6\ When writing out the equipment class CCT ranges of >=2800 K
and <=4500 K and of >4500 K and <7000 K in text, DOE uses the
shorthand 2800 K-4500 K and 4501 K-6999 K, respectively. Similarly,
when writing out the equipment class wattage ranges of >=50 W and
<=400 W, >400 W and <=1000 W, and >1000 W and <=2000 W in text, DOE
uses the shorthand 50 W-400 W, 401 W-1000 W, and 1001 W-2000 W,
respectively.
Table IV.1--Equipment Classes Analyzed in NOPD
----------------------------------------------------------------------------------------------------------------
CCT Range K Wattage W Bulb finish * Luminaire characteristic **
----------------------------------------------------------------------------------------------------------------
>=2800 and <=4500................ >=50 and <=400..... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
>400 and <=1000.... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
>1000 and <=2000... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
>4500 and <7000.................. >=50 and <=400..... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
>400 and <=1000.... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
>1000 and <=2000... Clear................... Enclosed.
Open.
Coated.................. Enclosed.
Open.
----------------------------------------------------------------------------------------------------------------
* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and
wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.
3. Technology Options
The following sections detail the technology options that DOE is
analyzing in this NOPD as viable means of increasing the efficacy of
HID lamps.
a. Mercury Vapor
MV ballasts, other than specialty application MV ballasts, have
been banned from import or production in the United States since
January 1, 2008. (42 U.S.C. 6295(ee)) This ban effectively limits the
installation of new MV fixtures and ballasts, meaning the only MV lamps
currently sold are replacement lamps. DOE understands there is limited
industry design emphasis on MV lamps and that there are limited methods
to improving the efficacy of MV lamps. DOE found that the only pathway
to increase efficacy is a change of technology to MH lamps, and
considers a change of technology as the sole technology option for MV
lamps in this NOPD.
b. High-Pressure Sodium Lamps
HPS lamps are already very efficacious (up to 150 lumens per watt),
but have intrinsically poor color quality. DOE did not identify any
technology options currently utilized in commercially available HPS
lamps. In the interim analysis, DOE identified academic papers that
indicated potential increases in efficacy were possible by constructing
the arc tubes out of a sapphire material, or single crystal aluminum
oxide. Several manufacturers produced HPS lamps with a sapphire arc
tube beginning in the late 1970s, but these lamps have since been
discontinued.
In the interim analysis, DOE found that sapphire had five percent
greater transmission of light compared to the traditionally used
polycrystalline alumina (PCA) and equated this with a potential five
percent increase in lamp efficacy. However, DOE has since received
feedback from manufacturers that the increase in transmission
associated with using sapphire material instead of PCA does not
necessarily result in an equal increase in efficacy. This is because
the material does not transmit all wavelengths uniformly, which affects
the perceived brightness of the light. Because these lamps are no
longer manufactured, DOE cannot empirically validate the potential
increase in efficacy using sapphire arc tubes. Additionally, DOE has
received feedback that HPS lamps using sapphire arc tubes are much more
susceptible to catastrophic failure and would require enclosed fixtures
for safe operation. Currently all HPS lamps that are commercially
available can be used in open fixtures. An enclosed fixture would
reduce the efficacy of the sapphire HPS system (due to absorption in
the lens used to enclose the fixture) and likely negate any small
increase in efficacy gained from using sapphire arc tubes.
For these reasons, DOE does not believe that the use of sapphire
arc
[[Page 62916]]
tubes would increase the efficacy of HPS lamps in practice. As such,
DOE no longer finds sapphire arc tubes to be a valid technology option
for HPS lamps in this NOPD.
c. Metal Halide
DOE identified a number of technology options that could improve MH
lamp efficacy. These technology options include improving arc tube
design through the use of ceramic arc tubes, optimization of the arc
tube, and optimization of the arc tube fill gas.
d. Summary
Table IV.2 summarizes the technology options identified for HID
lamps in this NOPD. For more detail on the technology options that DOE
considered to improve MV, HPS, and MH lamp efficacy, see chapters 2 and
3 of the NOPD TSD.
Table IV.2--NOPD HID Lamp Technology Options
------------------------------------------------------------------------
Lamp type Technology option Description
------------------------------------------------------------------------
MV.................. Change Lamp Type. Use MH technology instead of MV
technology.
MH.................. Ceramic Arc Tubes Use CMH technology instead of
quartz MH lamps.
Arc Tube Design the shape of the arc
Optimization. tube so that it facilitates an
increase in MH vapor pressure;
change the thickness of
quartz, optimize electrode
positioning, improve the
purity of the materials; and
improve the manufacturing
processes to ensure the
consistency and quality of the
arc tube construction.
Fill Gas Optimize the gas fill pressure
Optimization. and chemistry.
------------------------------------------------------------------------
B. Screening Analysis
DOE consults with industry, technical experts, and other interested
parties to develop a list of technology options for consideration. In
the screening analysis, DOE determines 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 an energy conservation standard. In particular,
sections 4(b)(4) and 5(b) of the Process Rule provide guidance to DOE
for determining which technology options are unsuitable for further
consideration: Technological feasibility, practicability to
manufacture, install and service, adverse impacts on product utility or
product availability, and adverse impacts on health or safety.
For MH lamps, DOE identified ceramic arc tubes as a technology
option. While CMH lamps are commercially available from 50 W-400 W,
they are not manufactured from 401 W-2000 W.\7\ DOE learned from
manufacturers that it is technologically possible to create CMH lamps
in this wattage range on an individual scale in laboratory conditions.
However, the difficulty in mass manufacturing these lamps would result
in a very costly lamp which may not be able to be produced at a large
enough scale to serve the entire market. Because of this, DOE
determined that ceramic arc tubes from 401 W-2000 W do not pass the
criterion that they be practicable to manufacture, install, and
service. In this NOPD, DOE does not consider ceramic arc tubes as
design options for MH lamps from 401 W-2000 W.
---------------------------------------------------------------------------
\7\ There is one example of a CMH lamp in this wattage range. It
is an 860 W CMH lamp that is designed to be used on a 1000 W ballast
and can operate on both probe-start and pulse-start ballasts.
Because this lamp employs proprietary technology, DOE does not use
this lamp as an example of CMH lamps being commercially available
from 401 W-1000 W.
---------------------------------------------------------------------------
All other technology options for MV and MH lamps meet the screening
criteria and are considered as design options in the engineering
analysis. These design options are summarized in Table IV.3. Chapters 2
and 4 of the NOPD TSD provide additional information regarding the
design options considered in the NOPD.
Table IV.3--NOPD HID Lamp Design Options
------------------------------------------------------------------------
Lamp type Technology option Description
------------------------------------------------------------------------
MV.................. Change Lamp Type. Use MH technology instead of MV
technology.
MH.................. Ceramic Arc Tubes Use CMH technology instead of
quartz MH lamps.
Arc Tube Design the shape of the arc
Optimization. tube so that it facilitates an
increase in MH vapor pressure;
change the thickness of
quartz, alter the fill gas
chemistry; optimize electrode
positioning; improve the
purity of the materials; and
improve the manufacturing
processes to ensure the
consistency and quality of the
arc tube construction.
Fill Gas Optimize the gas fill pressure
Optimization. and chemistry.
------------------------------------------------------------------------
C. Engineering Analysis
For this NOPD, DOE derived ELs in the engineering analysis and lamp
end-user prices in the equipment price determination. The engineering
analysis focuses on selecting commercially available lamps that
incorporate design options that improve efficacy. The following
discussion summarizes the general steps and results of the engineering
analysis.
1. Representative Equipment Classes
When multiple equipment classes exist, to streamline analysis, DOE
selects certain classes as ``representative,'' primarily because of
their high market volumes and unique performance characteristics. DOE
then adapts the ELs from representative equipment classes to those
equipment classes it does not analyze directly.
[[Page 62917]]
Table IV.4 lists the equipment classes that DOE selected as
representative.
Table IV.4--Representative Equipment Classes for HID Lamps
----------------------------------------------------------------------------------------------------------------
CCT Range K Wattage W Bulb finish * Luminaire characteristic **
----------------------------------------------------------------------------------------------------------------
>=2800 and <=4500................ >=50 and <=400..... Clear................... Enclosed.
>400 and <=1000.... Clear................... Enclosed.
>1000 and <=2000... Clear................... Enclosed.
----------------------------------------------------------------------------------------------------------------
* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and
wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.
2. Baseline Lamps and Representative Lamp Types
Because no federal energy conservation standards exist for HID
lamps, the baseline lamps represent the most common, least efficacious
lamps sold within the equipment class. For each baseline lamp, DOE
selected more efficacious replacement lamps to measure potential
energy-saving improvements. DOE refers to the baseline lamp and its
more efficacious replacements collectively herein as a ``representative
lamp type.'' The representative lamp type is named by its baseline
unit. For example, the 400 W MV representative lamp type refers to the
400 W MV baseline lamp and all of its more efficacious replacements.
DOE uses performance data presented in manufacturer catalogs to
determine lamp efficacy. DOE also considers other lamp characteristics
in choosing the most appropriate baseline for each equipment class.
These characteristics include the wattage and technology type (i.e., MH
or MV), among others. For some of the representative lamp types, DOE
selects multiple baseline models to ensure consideration of different
high-volume lamps and their associated customer economics. For example,
although MV lamps are the least efficacious products available, the HID
market has largely shifted away from MV lamps and customers of MH lamp-
and-ballast systems incur different costs than customers of MV lamp-
and-ballast systems. For these reasons, DOE selects both MV and MH
lamps as baselines for certain equipment classes.
Table IV.5 lists the baseline lamps and representative lamp types.
See chapters 2 and 5 of the NOPD TSD for additional detail.
Table IV.5--Baseline Lamps and Representative Lamp Types
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline
CCT Range Wattage Bulb finish * Luminaire characteristic ** Representative lamp type Baseline lamp type wattage
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
2800 K-4500 K.................... 50 W-400 W.......... Clear.................... Enclosed....................... 100 W MV...................... MV............................ 100
MH............................ 70
175 W MV...................... MV............................ 175
MH............................ 150
250 W MV...................... MV............................ 250
MH............................ 175
400 W MV...................... MV............................ 400
MH............................ 250
400 W MH...................... MH............................ 400
401 W-1000 W........ Clear.................... Enclosed....................... 1000 W MV..................... MV............................ 1000
1000 W MH..................... MH............................ 1000
1001 W-2000 W....... Clear.................... Enclosed....................... 2000 W MH..................... MH............................ 2000
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.
3. More Efficacious Substitutes
DOE selects commercially available HID lamps with efficacies above
the baseline as replacements for the baseline model(s) in each
representative equipment class. When selecting more efficacious
substitute lamps, DOE considers only design options that meet the
criteria outlined in the screening analysis (see section IV.B).
Depending on the equipment class, DOE analyzes standard efficacy quartz
MH, high efficacy quartz MH, and CMH lamps as more efficacious
substitutes for the baseline lamps.
In this NOPD, DOE considers a number of different potential
pathways a customer might choose when identifying replacements that are
more efficacious. When purchasing a new and compliant lamp, a customer
can purchase just a new lamp, a new lamp-and-ballast system, or an
entirely new fixture. For each of these options, a customer can also
choose between keeping the lighting system at the wattage they already
had or reducing the wattage of the lighting system. See chapters 2 and
5 of the NOPD TSD for additional detail.
4. Determine Efficacy 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.
DOE's ELs are based on catalog data. Table IV.6 summarizes the EL
equations for each representative equipment class. More information on
the described ELs can be found in chapters 2 and 5 of the NOPD TSD.
[[Page 62918]]
Table IV.6--Efficacy Level Equations for the Representative Equipment Classes
----------------------------------------------------------------------------------------------------------------
Minimum initial efficacy [dagger] (lm/W)
Representative equipment class --------------------------------------------------------------------------
EL1 EL2 EL3
----------------------------------------------------------------------------------------------------------------
2800 K-4500 K, 50 W-400 W, clear/ 38.5 x P\0.1350\....... 44.4 x P\0.1350\....... 40.4 x P\0.1809\
enclosed.
2800 K-4500 K, 401 W-1000 W, clear/ 0.0116 x P + 81.8...... 0.0173 x P + 92.8...... N/A
enclosed.
2800 K-4500 K, 1001 W-2000 W, clear/ 93.4................... N/A.................... N/A
enclosed.
----------------------------------------------------------------------------------------------------------------
* MV lamps are placed in the clear equipment classes for their respective CCT and wattage regardless of bulb
finish.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.
[dagger] P is defined as the rated wattage of the lamp.
5. Scaling to Equipment Classes Not Directly Analyzed
For the equipment classes not analyzed directly, DOE scaled the ELs
from the representative to non-representative equipment classes based
on efficacy ratios observed in catalog data. For example, DOE
calculated an average percentage difference in efficacy between lamps
in different equipment classes (one representative and one non-
representative) and used this percentage difference to scale the ELs
from the representative to the non-representative equipment classes.
Table IV.7 lists the scaling factors calculated in the NOPD analysis.
Table IV.7--Scaling Factors
------------------------------------------------------------------------
Bulb finish Luminaire characteristic CCT
------------------------------------------------------------------------
0.945 0.950 0.812
------------------------------------------------------------------------
* To calculate the efficacy requirement for a scaled equipment class,
the representative equipment class equation is multiplied by each
scaling factor of the characteristics of the equipment class that
differ from the representative class.
6. HID Systems
In this NOPD, DOE is only analyzing standards for HID lamps.
However, HID lamps are just one component of an HID lighting system.
HID lamps must be paired with specific ballasts to regulate the current
and power supplied to the lamp. These lamp-and-ballast systems are then
housed in an HID lamp fixture \8\ to protect the components, enable
mounting, and direct the light to the target area. When considering
changes to HID lamps, DOE recognizes the importance of also analyzing
the impact on both the ballast and the fixture. Additional components
may also be required if placing a new lamp-and-ballast system in an
existing fixture, including an appropriate lamp socket and ballast
brackets. See chapters 2, 5, and appendices 5A and 5B of the NOPD TSD
for additional detail.
---------------------------------------------------------------------------
\8\ Here, DOE uses the term ``fixture'' to refer to the
enclosure that houses the lamp and ballast.
---------------------------------------------------------------------------
D. Equipment Price Determination
The equipment price determination describes the methodology
followed in developing end-user prices for HID lamps and manufacturer
selling prices (MSPs) for ballasts, fixtures, and retrofit kit
components (brackets and sockets) analyzed in this NOPD. DOE developed
ballast and fixture MSPs in addition to lamp MSPs because a change of
ballast and fixture is often required when switching to a more
efficacious lamp. In addition, DOE developed MSPs for brackets and
sockets packaged in lamp-and-ballast retrofit kits because customers
will sometimes also have the option of keeping the fixture housing and
installing a new lamp-and-ballast system. These systems will often
require a change in the socket and brackets used for mounting the
ballast.
For HID lamps, DOE developed three sets of discounts from blue-book
prices, representing low (State procurement), medium (electrical
distributors), and high (Internet retailers) end-user lamp prices. For
MH ballasts, fixtures, sockets, and brackets, DOE performed teardown
analyses to estimate manufacturer production costs (MPCs) and a
manufacturer markup analysis to estimate the MSPs. For additional
detail on the equipment price determination, see chapters 2, 6, and
appendix 6A of the NOPD TSD.
E. Markups Analysis
Markups are multipliers that relate MSPs to end-user purchase
prices, and vary with the distribution channel through which purchase
the equipment. DOE estimated end-user prices for representative HID
lamp designs directly, rather than develop MSPs from a bill of
materials and manufacturer markup analysis (NOPD TSD chapter 6).\9\
However, DOE also estimated price markups to calculate end-user prices
from MSPs for HID ballasts and fixtures as inputs to the LCC and PBP
analysis, and the NIA (chapters 9 and 11, respectively, of the NOPD
TSD). Appendix 6A of the NOPD TSD describes the process by which DOE
developed MPCs and MSPs for HID ballasts and fixtures. Chapters 2 and 7
of the NOPD TSD provide additional detail on the markups analysis for
developing end-user prices for HID ballasts and fixtures.
---------------------------------------------------------------------------
\9\ For this NOPD, DOE used estimated markups to develop MSPs
for HID lamps for the MIA (see chapter 12 of the NOPD TSD).
---------------------------------------------------------------------------
F. Energy Use Analysis
For the energy use analysis, DOE estimated the energy use of HID
lamp-and-ballast systems in actual field conditions. The energy use
analysis provided the basis for other DOE analyses, particularly
assessments of the energy savings and the savings in operating costs
that could result from DOE's adoption of potential new standard levels.
DOE multiplied annual usage (in hours per year) by the lamp-and-ballast
system input power (in watts) to develop annual energy use estimates.
Chapters 2 and 8 of the NOPD TSD provide a more detailed description of
DOE's energy use analysis.
G. Life-Cycle Cost and Payback Period Analysis
DOE conducted the LCC and PBP analysis to evaluate the economic
effects of potential energy conservation standards for HID lamps on
individual customers. For any given EL, DOE calculated the PBP and the
change in LCC relative to an estimated baseline equipment EL. The LCC
is the total customer expense over the life of the
[[Page 62919]]
equipment, consisting of purchase, installation, and operating costs
(expenses for energy use, maintenance, and repair). To compute the
operating costs, DOE discounted future operating costs to the time of
purchase and summed them over the lifetime of the equipment. The PBP is
the estimated amount of time (in years) it takes customers to recover
the increased purchase cost (including installation) of more
efficacious equipment through lower operating costs. DOE calculates the
PBP by dividing the change in purchase cost (normally higher) by the
change in average annual operating cost (normally lower) that results
from the more stringent standard. Chapters 2 and 9, and appendices 9A
and 9B, of the NOPD TSD provide details on the spreadsheet model and
all the inputs to the LCC and PBP analysis.
H. Shipments Analysis
DOE projected equipment shipments to calculate the national effects
of potential standards on energy use, NPV, and future manufacturer cash
flows. DOE developed shipment projections based on an analysis of key
market drivers for each considered HID lamp type. In DOE's shipments
model, shipments of equipment are driven by new construction, stock
replacements, and other types of purchases. The shipments model takes
an accounting approach, tracking market shares of each equipment class
and the vintage of units in the existing stock. Stock accounting uses
equipment shipments as inputs to estimate the age distribution of in-
service equipment stocks for all years. The age distribution of in-
service equipment stocks is a key input to calculations of both the NES
and the NPV, because operating costs for any year depend on the age
distribution of the stock. Chapters 2 and 10 of the NOPD TSD provide a
more detailed description of DOE's shipments analysis.
I. National Impact Analysis
DOE's NIA assessed the cumulative NES and the cumulative national
economic impacts of ELs (i.e., potential standards cases) considered
for the equipment classes analyzed. The analysis measures economic
impacts using the NPV metric, which presents total customer costs and
savings expected to result from potential standards at specific ELs,
discounted to their present value. For a given EL, DOE calculates the
NPV, as well as the NES, as the difference between a baseline
projection and the standards-case projections. Chapters 2 and 11, and
appendices 11A and 11B, of the NOPD TSD provide details on the
spreadsheet model and all the inputs to the NIA.
J. Manufacturer Impact Analysis
DOE conducted an MIA for HID lamps to estimate the financial impact
of potential energy conservation standards on manufacturers. The MIA
has both quantitative and qualitative aspects. The quantitative part of
the MIA relies on the Government Regulatory Impact Model (GRIM), an
industry cash-flow model customized for HID lamps covered in this NOPD.
The key GRIM inputs are industry cost structure data, shipment data,
equipment costs, and assumptions about markups and conversion costs.
The key MIA output is INPV. DOE used the GRIM to calculate cash flows
using standard accounting principles and to compare changes in INPV
between a base case and various ELs at each equipment class (the
standards case). The difference in INPV between the base and standards
cases represents the financial impact of potential energy conservation
standards on HID lamp manufacturers. Different sets of assumptions
(scenarios) produce different INPV results. The qualitative part of the
MIA addresses how potential standards could impact manufacturing
capacity and industry competition, as well as any differential impact
the potential standard could have on any particular subgroup of
manufacturers. See chapter 12 of this NOPD TSD for additional details
on DOE's MIA.
V. Analytical Results
A. Economic Impacts on Individual Customers
To evaluate the net economic impact of standards on customers, DOE
conducted an LCC and PBP analysis for each EL. In general, a higher
efficacy product would affect customers in two ways: (1) Annual
operating expenses would decrease; and (2) purchase prices would
increase. Section IV.G of this notice discusses the inputs DOE used for
calculating the LCC and PBP.
The key outputs of the LCC analysis are mean LCC savings relative
to the baseline case, as well as a probability distribution or
likelihood of LCC reduction or increase, for each efficacy level and
equipment class.\10\ In its LCC analysis, DOE traditionally assumes
that the customer purchases a covered design upon the effective date of
potential standards (in this case, 2017). The resulting values then
necessarily reflect the projected market for HID equipment in 2017, and
are reported by equipment class in Table V.1, Table V.2, and Table V.3.
The LCC analysis also estimates the fraction of customers for which the
LCC will decrease (net benefit), remain unchanged (no impact), or
increase (net cost) relative to the baseline case. The last column in
each table contains the median PBPs for the customers purchasing a
design compliant with the efficacy level.
---------------------------------------------------------------------------
\10\ Customers, in the base-case scenario, who buy the equipment
at or above the EL under consideration, would be unaffected (no
impact) if the potential standard were to be set at that EL.
---------------------------------------------------------------------------
In evaluating these results relative to cumulative NPV, it is
important to note that the LCC and PBP analysis does not reflect the
long-term dynamics of the declining market for HID equipment, which are
captured in the NIA shipments period (2017-2046). As a result, the
average LCC savings--based on the projected 2017 market--may be
positive in some cases (e.g., EL2 and EL3 for the >2800 K and <=4500 K
and >=50 W to <=400 W equipment class), whereas the cumulative NPV
results for these ELs are negative (see Table V.16). DOE explored the
effects of the declining HID market on average LCC savings by
conducting a sensitivity analysis based on the projected market in
2022, with results reported by equipment class in Table V.4, Table V.5,
and Table V.6. These results show a general erosion of average LCC
savings, and demonstrate increasing consistency with the cumulative NPV
results. For the >2800 K and <=4500 K and >=50 W to <=400 W equipment
class, average LCC savings for EL2 become negative, with a majority of
affected customers remaining negatively impacted. Average LCC savings
for EL3 in this equipment class--while still positive--are
significantly diminished, with a majority of affected customers
experiencing a net cost. Following this trend, DOE would expect LCC
savings for EL3 to become increasingly negative for an increasing
proportion of affected customers over the NIA analysis period.
Based on this sensitivity analysis, DOE believes its main LCC and
PBP analysis results (including some cases of positive average LCC
savings) are consistent with negative cumulative NPV results in the
NIA, given the declining market for HID equipment. Chapter 9 of the
NOPD TSD examines the relationship of the LCC and PBP analysis and
projected HID market in further detail.
[[Page 62920]]
Table V.1--HID Lamps >2800 K and <=4500 K and =50 W to <=400 W--LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 309.16 1671.22 1980.38 ........... ........... ........... ........... ...........
1............................................... 316.37 1667.70 1984.07 -3.69 2 98 0 100
2............................................... 368.59 1602.68 1971.27 9.11 53 35 12 100
3............................................... 520.38 1374.17 1894.55 85.83 35 23 42 11.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding.
Table V.2--HID Lamps >2800 K and <=4500 K and 400 and <=1000 W--LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 444.54 5755.21 6199.75 ........... ........... ........... ........... ...........
1............................................... 445.65 5754.56 6200.22 -0.47 0 100 0 100
2............................................... 486.34 5792.61 6278.94 -79.19 91 7 1 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding, including cases where the percentage of customers experiencing a
net cost or net benefit are greater than zero, but round to zero.
Table V.3--HID Lamps >2800 K and <=4500 K and 1000 W to <=2000 W--LCC and PBP Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 534.23 596.88 1131.11 ........... ........... ........... ........... ...........
1............................................... 592.96 554.33 1147.29 -16.18 6 91 2 39.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding.
Table V.4--HID Lamps >2800 K and <=4500 K and =50 W to <=400 W--LCC and PBP Results
[2022 Projected market basis]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 303.01 1626.38 1929.39 ........... ........... ........... ........... ...........
1............................................... 303.41 1626.17 1929.58 -0.19 0 100 0 100
2............................................... 508.38 1479.10 1987.48 -58.09 52 37 11 41.3
3............................................... 569.12 1337.34 1906.45 22.94 42 23 35 16.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding, including cases where the percentage of customers experiencing a
net cost or net benefit are greater than zero, but round to zero.
Table V.5--HID Lamps >2800 K and <=4500 K and 400 and <=1000 W--LCC and PBP Results
[2022 Projected market basis]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 442.66 5772.61 6215.27 ........... ........... ........... ........... ...........
1............................................... 442.66 5772.61 6215.27 0.00 0 100 0 N/A**
2............................................... 695.12 5718.91 6414.03 -198.76 91 8 0 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding.
** Zero impacted customers (median PBP calculated for affected customers only).
[[Page 62921]]
Table V.6--HID Lamps >2800 K and <=4500 K and 1000 W to <=2000 W--LCC and PBP Results
[2022 Projected market basis]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost 2012$ Life-cycle cost savings
------------------------------------------------------------------------------------------- Median
Percentage of customers that payback
Efficacy level Installed Discounted Average experience * period
cost operating LCC savings --------------------------------------- years
cost 2012$ Net cost No impact Net benefit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................................ 581.65 611.01 1192.67 ........... ........... ........... ........... ...........
1............................................... 649.70 562.86 1212.57 -19.90 9 88 3 30.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Any minor incongruities among various reported metrics are the result of rounding.
B. Economic Impacts on Manufacturers
DOE performed the MIA to estimate the impact of potential energy
conservation standards on manufacturers of HID lamps. The section below
describes the expected impacts on HID lamp manufacturers at each EL for
each equipment class. Chapter 12 of the NOPD TSD explains the MIA in
further detail.
1. Industry Cash-Flow Analysis Results
The tables in the following sections depict the financial impacts
(represented by changes in INPV) of potential energy conservation
standards on HID lamp manufacturers as well as the conversion costs
that DOE estimates HID lamp manufacturers would incur at each EL for
each equipment class. To evaluate the range of cash-flow impacts on the
HID lamp industry, DOE modeled two markup scenarios that correspond to
the range of anticipated market responses to potential standards. Each
scenario results in a unique set of cash flows and corresponding
industry values at each EL for each equipment class. In the following
discussion, the INPV results refer to the difference in industry value
between the base case and the standards case that result from the sum
of discounted cash flows from the base year (2014) through the end of
the analysis period.
To assess the upper (less severe) end of the range of potential
impacts on HID lamp manufacturers, DOE modeled a flat, or preservation
of gross margin, markup scenario. This scenario assumes that in the
standards case, manufacturers would be able to pass along all the
higher production costs required for more efficacious equipment to
their customers. To assess the lower (more severe) end of the range of
potential impacts, DOE modeled a preservation of operating profit
markup scenario. The preservation of operating profit markup scenario
assumes that in the standards case, manufacturers would be able to earn
the same operating margin in absolute dollars as they would in the base
case. This represents the lower bound of industry profitability in the
standards case.
Table V.7 and Table V.8 present the projected results of the 50 W-
400 W equipment class under the flat and preservation of operating
profit markup scenarios.
Table V.7--Manufacturer Impact Analysis for the 50 W-400 W Equipment Class--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base Case -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
INPV.......................... (2012$ millions) 351.0 346.6 327.8 335.9
Change in INPV................ (2012$ millions) .............. (4.5) (23.3) (15.2)
(%)............. .............. -1.3% -6.6% -4.3%
Product Conversion Costs...... (2012$ millions) .............. 7.4 31.4 55.0
Capital Conversion Costs...... (2012$ millions) .............. 0.0 6.0 54.5
---------------------------------------------------------------------------------
Total Conversion Costs.... (2012$ millions) .............. 7.4 37.4 109.5
----------------------------------------------------------------------------------------------------------------
Table V.8--Manufacturer Impact Analysis for the 50 W-400 W Equipment Class--Preservation of Operating Profit
Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base Case -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
INPV.......................... (2012$ millions) 351.0 345.9 300.2 268.9
Change in INPV................ (2012$ millions) .............. (5.1) (50.9) (82.1)
(%)............. .............. -1.5% -14.5% -23.4%
Product Conversion Costs...... (2012$ millions) .............. 7.4 31.4 55.0
Capital Conversion Costs...... (2012$ millions) .............. 0.0 6.0 54.5
---------------------------------------------------------------------------------
Total Conversion Costs.... (2012$ millions) .............. 7.4 37.4 109.5
----------------------------------------------------------------------------------------------------------------
Table V.9 and Table V.10 present the projected results of the 401
W-1000 W equipment class under the flat and preservation of operating
profit markup scenarios.
[[Page 62922]]
Table V.9--Manufacturer Impact Analysis for the 401 W-1000 W Equipment Class--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base case -------------------------------
1 2
----------------------------------------------------------------------------------------------------------------
INPV.................................. (2012$ millions)........ 55.3 55.0 56.1
Change in INPV........................ (2012$ millions)........ .............. (0.3) 0.8
(%)..................... .............. -0.6% 1.4%
Product Conversion Costs.............. (2012$ millions)........ .............. 0.5 4.9
Capital Conversion Costs.............. (2012$ millions)........ .............. 0.0 0.8
Total Conversion Costs................ (2012$ millions)........ .............. 0.5 5.7
----------------------------------------------------------------------------------------------------------------
Table V.10--Manufacturer Impact Analysis for the 401 W-1000 W Equipment Class--Preservation of Operating Profit
Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base case -------------------------------
1 2
----------------------------------------------------------------------------------------------------------------
INPV.................................. (2012$ millions)........ 55.3 55.0 51.5
Change in INPV........................ (2012$ millions)........ .............. (0.3) (3.9)
(%)..................... .............. -0.6% -7.0%
Product Conversion Costs.............. (2012$ millions)........ .............. 0.5 4.9
Capital Conversion Costs.............. (2012$ millions)........ .............. 0.0 0.8
Total Conversion Costs................ (2012$ millions)........ .............. 0.5 5.7
----------------------------------------------------------------------------------------------------------------
Table V.11 and Table V.12 present the projected results of the 1001
W-2000 W equipment class under the flat and preservation of operating
profit markup scenarios.
Table V.11--Manufacturer Impact Analysis for the 1001 W-2000 W Equipment Class--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base case ---------------
1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 4.7 4.0
Change in INPV................................ (2012$ millions)................ .............. (0.8)
(%)............................. .............. -15.9%
Product Conversion Costs...................... (2012$ millions)................ .............. 0.6
Capital Conversion Costs...................... (2012$ millions)................ .............. 0.4
Total Conversion Costs........................ (2012$ millions)................ .............. 0.9
----------------------------------------------------------------------------------------------------------------
Table V.12--Manufacturer Impact Analysis for the 1001 W-2000 W Equipment Class--Preservation of Operating Profit
Markup Scenario
----------------------------------------------------------------------------------------------------------------
EL
Units Base case ---------------
1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 4.7 4.0
Change in INPV................................ (2012$ millions)................ .............. (0.7)
(%)............................. .............. -15.4%
Product Conversion Costs...................... (2012$ millions)................ .............. 0.6
Capital Conversion Costs...................... (2012$ millions)................ .............. 0.4
Total Conversion Costs........................ (2012$ millions)................ .............. 0.9
----------------------------------------------------------------------------------------------------------------
2. Impacts on Employment
DOE quantitatively assessed the impacts of potential energy
conservation standards on direct employment. DOE used the GRIM to
estimate the domestic labor expenditures and number of domestic
production workers in the base case and at each EL for the 50 W-400 W
equipment class, since the 50 W-400 W equipment class represents over
90 percent of all covered HID lamp shipments in 2017. Furthermore,
manufacturers stated that most domestic employment decisions would be
based on the standards set for the 50 W-400 W equipment class.
The employment impacts shown in Table V.13 represent the potential
production employment that could result following potential energy
conservation standards. The upper bound of the results estimates the
maximum change in the number of production workers that could occur
after compliance with any potential energy conservation standards
assuming that manufacturers continue to produce the same scope of
covered equipment in the same domestic production facilities. It also
assumes that domestic
[[Page 62923]]
production does not shift to lower labor-cost countries. Because there
is a real risk of manufacturers evaluating sourcing decisions in
response to potential energy conservation standards, the lower bound of
the employment results includes the estimated total number of U.S.
production workers in the industry who could lose their jobs if some or
all existing production were moved outside of the United States.
DOE estimates that approximately one third of the HID lamps sold in
the United States are manufactured domestically. With this assumption,
DOE estimates that in the absence of potential energy conservation
standards, there would be approximately 292 domestic production workers
involved in manufacturing HID lamps in 2017. The table below shows the
range of the impacts of potential standards on U.S. production workers
in the HID lamp industry.
Table V.13--Potential Changes in the Total Number of Domestic High-Intensity Discharge Lamp Production Workers
in 2017
----------------------------------------------------------------------------------------------------------------
50 W-400 W Equipment class EL
Base case -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Total Number of Domestic Production Workers in 292 294 317 388
2017 (without changes in production locations).
Potential Changes in Domestic Production Workers .............. 2-0 25-(146) 96-(292)
in 2017 *......................................
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
3. Impacts on Manufacturing Capacity
HID lamp manufacturers stated that they did not anticipate any
significant capacity constraints unless all lamps in the 50 W-400 W
equipment class had to be converted to CMH technology. Most
manufacturers stated that they do not have the equipment to produce the
volume of CMH lamps that would be necessary to satisfy demand.
Manufacturers would have to expend significant capital resources to
obtain additional equipment that is specific to CMH lamp production.
Manufacturers also pointed out that thousands of man-hours would be
necessary to redesign specific lamps and lamp production lines at ELs
requiring CMH. The combination of obtaining new equipment and the
engineering effort that manufacturers would have to undergo could cause
significant downtime for manufacturers. Most manufacturers agreed that
there would not be any significant capacity constraints at any ELs that
did not require CMH technology.
4. Impacts on Subgroups of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche equipment
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE did not identify any adversely impacted
subgroups for HID lamps for this NOPD based on the results of the
industry characterization. DOE analyzed the impacts on small
manufacturers as required by the Regulatory Flexibility Act, 5 U.S.C.
601, et. seq.
5. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or impending regulations
may have serious consequences for some manufacturers, groups of
manufacturers, or an entire industry. Assessing the impact of a single
regulation may overlook this cumulative regulatory burden. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and lead companies
to abandon product lines or markets with lower expected future returns
than competing equipment. For these reasons, DOE conducts a cumulative
regulatory burden analysis as part of its rulemakings pertaining to
lighting efficacy to make sure that this proposed standard does not
create a cumulative regulatory burden that is unacceptable to the
overall lighting industry.
C. National Impact Analysis
1. Significance of Energy Savings
For each efficacy level, DOE projected energy savings for HID lamps
purchased in the 30-year period that begins in the year 2017, ending in
the year 2046. The savings are measured over the entire lifetime of
equipment purchased in the 30-year period. DOE quantified the energy
savings attributable to each efficacy level as the difference in energy
consumption between each standards case and the base case. Table V.14
presents the estimated primary energy savings for each efficacy level
analyzed. Table V.15 presents the estimated FFC energy savings for each
efficacy level. Chapter 11 of the NOPD TSD describes these estimates in
more detail.
Table V.14--Cumulative National Primary Energy Savings for HID Lamp
Efficacy Levels for Units Sold in 2017-2046
------------------------------------------------------------------------
National
primary
Equipment class Efficacy level energy
savings quads
------------------------------------------------------------------------
>2800 K and <=4500 K and >=50 W to <=400 1 0.01
W...................................... 2 0.1
3 1.55
>2800 K and <=4500 K and >400 and <=1000 1 0.0001
W...................................... 2 0.003
>2800 K and <=4500 K and >1000 W to 1 0.001
<=2000 W...............................
------------------------------------------------------------------------
[[Page 62924]]
Table V.15--Cumulative National Full-Fuel-Cycle Energy Savings for HID
Lamp Efficacy Levels for Units Sold in 2017-2046
------------------------------------------------------------------------
National
primary
Equipment class Efficacy level energy
savings quads
------------------------------------------------------------------------
>2800 K and <=4500 K and >=50 W to <=400 1 0.01
W...................................... 2 0.17
3 1.57
>2800 K and <=4500 K and >400 and <=1000 1 0.0001
W...................................... 2 0.003
>2800 K and <=4500 K and >1000 W to 1 0.001
<=2000 W...............................
------------------------------------------------------------------------
2. Net Present Value of Customer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
customers that would result from the efficacy levels considered for HID
lamps. In accordance with the Office of Management and Budget's (OMB's)
guidelines on regulatory analysis,\11\ DOE calculated the NPV using
both a 7-percent and a 3-percent real discount rate. The 7-percent rate
is an estimate of the average before-tax rate of return on private
capital in the U.S. economy, and reflects the returns on real estate
and small business capital as well as corporate capital. This discount
rate approximates the opportunity cost of capital in the private sector
(OMB analysis has found the average rate of return on capital to be
near this rate). The 3-percent rate reflects the potential effects of
standards on private consumption (e.g., through higher prices for
products and reduced purchases of energy). This rate represents the
rate at which society discounts future consumption flows to their
present value. It can be approximated by the real rate of return on
long-term government debt (i.e., yield on U.S. Treasury notes), which
has averaged about 3 percent for the past 30 years.
---------------------------------------------------------------------------
\11\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
Table V.16 shows the customer NPV results for each efficacy level
DOE considered for HID lamps, using both 7-percent and 3-percent
discount rates. In each case, the impacts cover the lifetime of
equipment purchased in 2017 through 2046. See chapter 11 of the NOPD
TSD for more detailed NPV results.
Table V.16--Net Present Value of Customer Benefits for HID Lamp Efficacy
Levels for Units Sold in 2017-2046
------------------------------------------------------------------------
Net present value
billion 2012$
Efficacy -------------------------
Equipment class level 7-Percent 3-Percent
discount discount
rate rate
------------------------------------------------------------------------
>2800 K and <=4500 K and >=50 W 1 -0.06 -0.03
to <=400 W...................... 2 -2.00 -3.42
3 -4.98 -6.37
>2800 K and <=4500 K and >400 and 1 -0.0001 0.0002
<=1000 W........................ 2 -0.49 -0.90
>2800 K and <=4500 K and >1000 W 1 -0.02 -0.03
to <=2000 W.....................
------------------------------------------------------------------------
D. Proposed Determination
As required by EPCA, this NOPD analyzes whether standards for HID
lamps would be technological feasible, economically justified, and
would result in significant energy savings. (42 U.S.C. 6317(b)(1)) Each
of these criteria is discussed below.
1. Technological Feasibility
EPCA mandates that DOE determine whether energy conservation
standards for HID lamps would be ``technologically feasible.'' (42
U.S.C. 6317(a)(1)) DOE proposes to determine that standards for HPS
lamps would not be technologically feasible due to the lack of
technology options discussed in section IV.A.3. DOE proposes to
determine that energy conservation standards for other HID lamps (MV
and MH lamps) would be technologically feasible because they can be
satisfied with HID lighting systems currently available on the market.
2. Significance of Energy Savings
EPCA also mandates that DOE determine whether energy conservation
standards for HID lamps would result in ``significant energy savings.''
(42 U.S.C. 6317(a)(1)) The proposed determination estimates that a
standard for HID lamps would result in energy savings of up to 1.6
quads over a 30-year analysis period (2017-2046). Therefore, DOE
proposes to determine that potential energy conservation standards for
HID lamps would result in significant energy savings.
3. Economic Justification
EPCA requires DOE to determine whether energy conservation
standards for HID lamps would be economically justified. (42 U.S.C.
6317(b)(1)) Using the methods and data described in section IV.G, DOE
conducted an LCC analysis to estimate the net costs/benefits to users
from increased efficacy in the considered HID lamps. DOE then
[[Page 62925]]
aggregated the results from the LCC analysis to estimate national
energy savings and national economic impacts in section V.A. DOE also
conducted an MIA to estimate the financial impact of potential energy
conservation standards on manufacturers.
DOE first considered the most efficacious level, EL 3, which is
applicable only to the 50 W-400 W equipment class. As listed in Table
V.16, EL3 would have a negative NPV at both a 7-percent and 3-percent
discount rate. EL3 could result in HID lamp manufacturers experiencing
a loss in INPV. On the basis of the negative NPV and decrease in
industry value for HID lamp manufacturers, DOE determined that the EL3
standard was not economically justified.
DOE then considered the next most efficacious level, EL2, which
applies to the 50 W-400 W and 401 W-1000 W equipment classes. As listed
in Table V.16, EL2 results in a negative NPV for all applicable
equipment classes at both a 7-percent and 3-percent discount rate. As
listed in section V.A, available designs result in positive mean LCC
savings for the 50 W-400 W equipment class and negative mean LCC
savings for the 401 W-1000 W equipment class. However, a majority of
customers affected by the standard experience a net cost at EL2 in all
applicable equipment classes. EL2 could result in HID lamp
manufacturers experiencing a loss in INPV for the applicable equipment
classes. On the basis of the negative NPV, majority of customers
affected by the standard experiencing a net cost, and potential
decrease in industry value for HID lamp manufacturers, DOE determined
that an EL2 standard was not economically justified.
DOE finally considered EL1, which would apply to all equipment
classes. DOE's NPV analysis (results listed in Table V.16) indicates
that all equipment classes have a negative or negligible NPV at a 7-
percent and 3-percent discount rate for EL1. As listed in section V.A,
available designs result in negative mean LCC savings for all three of
the representative equipment classes at EL 1, with a majority of
customers affected by the standard experiencing a net cost. EL1 could
result in HID lamp manufacturers experiencing a loss in INPV for all
equipment classes. On the basis of the negative NPV, negative mean LCC
savings, majority of customers affected by the standard experiencing a
net cost, and decrease in industry value for HID lamp manufacturers,
DOE determined that an EL1 standard was not economically justified.
4. Conclusions
DOE tentatively determines that potential standards for HID lamps
are either not technologically feasible or not economically justified.
DOE will consider all comments received on this proposed determination
in issuing any final determination of whether standards for HID lamps
would be technologically feasible and economically justified, and would
result in significant energy savings. If DOE determines that all of
these criteria are met, DOE must prescribe test procedures and energy
conservation standards for HID lamps. If DOE determines that one or
more of the criteria are not met, DOE will not consider establishing
test procedures and standards for these lamps.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
This proposed determination is not subject to review under
Executive Order (E.O.) 12866, ``Regulatory Planning and Review.'' 58 FR
51735 (October 4, 1993).
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990 DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (http://energy.gov/gc/office-general-counsel).
DOE reviewed this proposed determination under the provisions of
the Regulatory Flexibility Act and the policies and procedures
published on February 19, 2003. In the proposed determination, DOE
finds that standards for HID lamps would not meet all of the required
criteria of technologically feasibility, economic justification, and
significant energy savings. If adopted, the determination would not
establish any energy conservation standards for HID lamps, and DOE
would not consider prescribing test procedures and standards for HID
lamps. On the basis of the foregoing, DOE certifies that the proposed
determination, if adopted, would have no significant economic impact on
a substantial number of small entities. Accordingly, DOE has not
prepared an IRFA for this proposed determination. DOE will transmit
this certification and supporting statement of factual basis to the
Chief Counsel for Advocacy of the Small Business Administration for
review under 5 U.S.C. 605(b).
C. Review Under the Paperwork Reduction Act
This proposed determination, which proposes to determine that
energy conservation standards for HID lamps would not meet all of the
required criteria of technologically feasibility, economic
justification, and significant energy savings, would impose no new
information or record keeping requirements. Accordingly, the Office of
Management and Budget (OMB) clearance is not required under the
Paperwork Reduction Act. (44 U.S.C. 3501 et seq.)
D. Review Under the National Environmental Policy Act of 1969
In this NOPD, DOE tentatively determines that energy conservation
standards for HID lamps would not meet all of the required criteria of
technologically feasibility, economic justification, and significant
energy savings. DOE has determined that review under the National
Environmental Policy Act of 1969 (NEPA), Pub. L. 91-190, codified at 42
U.S.C. 4321 et seq. is not required at this time because standards are
not being proposed. NEPA review can only be initiated ``as soon as
environmental impacts can be meaningfully evaluated.'' Because this
final determination concludes only that future standards are unlikely
to be warranted, and does not propose or set any standard, DOE has
determined that there are no environmental impacts to be evaluated at
this time. Accordingly, neither an environmental assessment nor an
environmental impact statement is required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on Federal agencies formulating and
implementing policies or regulations that preempt State law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit
[[Page 62926]]
the policymaking discretion of states and to carefully assess the
necessity for such actions. The Executive Order also requires agencies
to have an accountable process to ensure meaningful and timely input by
State and local officials in the development of regulatory policies
that have Federalism implications. On March 14, 2000, DOE published a
statement of policy describing the intergovernmental consultation
process it will follow in the development of such regulations. 65 FR
13735. As this NOPD determines that standards are not likely to be
warranted for HID lamps, there is no impact on the policymaking
discretion of the states. Therefore, no action is required by Executive
Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; and (3)
provide a clear legal standard for affected conduct rather than a
general standard and promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Section 3(b) of Executive Order 12988 specifically
requires that Executive agencies make every reasonable effort to ensure
that the regulation: (1) Clearly specifies the preemptive effect, if
any; (2) clearly specifies any effect on existing Federal law or
regulation; (3) provides a clear legal standard for affected conduct
while promoting simplification and burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately defines key terms; and (6)
addresses other important issues affecting clarity and general
draftsmanship under any guidelines issued by the Attorney General.
Section 3(c) of Executive Order 12988 requires Executive agencies to
review regulations in light of applicable standards in section 3(a) and
section 3(b) to determine whether they are met or it is unreasonable to
meet one or more of them. DOE has completed the required review and
determined that, to the extent permitted by law, this proposed
determination meets the relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by State, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at http://energy.gov/gc/office-general-counsel. This proposed determination contains neither an
intergovernmental mandate nor a mandate that may result in the
expenditure of $100 million or more in any year, so these UMRA
requirements do not apply.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This proposed determination would not have any impact on the autonomy
or integrity of the family as an institution. Accordingly, DOE has
concluded that it is not necessary to prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (Mar. 18, 1988), that this proposed determination
would not result in any takings that might require compensation under
the Fifth Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed this proposed determination under the OMB and
DOE guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any proposed significant
energy action. A ``significant energy action'' is defined as any action
by an agency that promulgates or is expected to lead to promulgation of
a final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
Because the NOPD finds that standards for HID lamps are unlikely to
be warranted, it is not a significant energy action, nor has it been
designated as such by the Administrator at OIRA. Accordingly, DOE has
not prepared a Statement of Energy Effects.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal
[[Page 62927]]
Government, including influential scientific information related to
agency regulatory actions. The purpose of the Bulletin is to enhance
the quality and credibility of the Government's scientific information.
Under the Bulletin, the energy conservation standards rulemaking
analyses are ``influential scientific information,'' which the Bulletin
defines as scientific information the agency reasonably can determine
will have, or does have, a clear and substantial impact on important
public policies or private sector decisions. 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report'' dated February 2007 has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
VII. Public Participation
A. Public Meeting Requests
Interested parties may submit comments requesting that a public
meeting discussing this NOPD be held at DOE Headquarters. DOE will
accept such requests no later than the date provided in the DATES
section at the beginning of this notice. As with other comments
regarding this determination, interested parties may submit requests
using any of the methods described in the ADDRESSES section at the
beginning of this notice.
B. Submission of Comments
DOE will accept comments, data, and information regarding this NOPD
no later than the date provided in the DATES section at the beginning
of this determination. Interested parties may submit comments, data,
and other information using any of the methods described in the
ADDRESSES section at the beginning of this determination.
Submitting comments via regulations.gov. The regulations.gov Web
page will require you to provide your name and contact information.
Your contact information will be viewable to DOE Building Technologies
staff only. Your contact information will not be publicly viewable
except for your first and last names, organization name (if any), and
submitter representative name (if any). If your comment is not
processed properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information [CBI]). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section
below.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery, or mail also
will be posted to regulations.gov. If you do not want your personal
contact information to be publicly viewable, do not include it in your
comment or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible. It is
not necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked confidential including all the
information believed to be confidential, and one copy of the document
marked non-confidential with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received,
[[Page 62928]]
including any personal information provided in the comments (except
information deemed to be exempt from public disclosure).
C. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposed
determination, DOE is particularly interested in receiving comments and
views of interested parties concerning the following issues:
1. The HID lamps selected for and excluded from analysis of
economic justification for standards;
2. The technology options analyzed and in particular the
elimination of sapphire arc tubes and starting method as technology
option(s);
3. The equipment classes analyzed in this NOPD;
4. The design options identified in the screening analysis;
5. The representative equipment classes analyzed in this NOPD;
6. The baseline lamps selected, including the inclusion of a 150 W
MH lamp;
7. The selection of more efficacious substitute lamps analyzed in
this NOPD;
8. The decision to analyze equal wattage replacement lamps, as well
as the methodology used to select the equal wattage replacement lamps;
9. The methodology used to determine ELs, as well as the resulting
ELs analyzed in this NOPD;
10. The factors used in this NOPD to scale to equipment classes not
directly analyzed;
11. The decision to include replacement pathways other than full
fixture replacement in this NOPD;
12. The results and methodology from the equipment price
determination;
13. Methods to improve DOE's energy use analysis, as well as any
data supporting alternate operating hour estimates or assumptions
regarding dimming of HID lamp-and-ballast systems;
14. The assumptions and methodology for estimating annual operating
hours, which were based on data from the 2010 U.S. Lighting Market
Characterization;
15. Methods to improve DOE's equipment price projections beyond the
assumption of constant real prices, as well as any data supporting
alternate methods;
16. The reasonableness of assuming a zero percent rebound effect
(the potential tendency for customers to increase HID lamp usage in
response to more efficient lamp-and-ballast systems);
17. Whether the shipment scenarios under various policy scenarios
are reasonable and likely to occur;
18. The impediments that prevent users of HID lamps from switching
to LED lighting to garner further energy savings;
19. The expected impact of potential standards on the rate at which
HID lamp customers transition to non-HID technology;
20. The methodology used in the MIA and the results of the MIA;
21. The proposal of a negative determination stating that standards
for HID lamps are not justified.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this NOPD.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation, and Reporting and recordkeeping
requirements.
Issued in Washington, DC, on October 10, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
[FR Doc. 2014-24971 Filed 10-20-14; 8:45 am]
BILLING CODE 6450-01-P