Energy Conservation Program: Energy Conservation Standards for High-Intensity Discharge Lamps
Federal Register, Volume 80 Issue 236 (Wednesday, December 9, 2015)
Federal Register Volume 80, Number 236 (Wednesday, December 9, 2015)
Rules and Regulations
Pages 76355-76374
From the Federal Register Online via the Government Publishing Office www.gpo.gov
FR Doc No: 2015-30992
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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: Final determination.
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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 final determination, DOE determines that energy conservation standards for high-intensity discharge (HID) lamps do not meet these criteria.
DATES: This final determination is effective December 9, 2015.
ADDRESSES: The docket, which includes Federal Register notices, framework documents, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the www.regulations.gov index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
The docket Web page can be found at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. This Web page contains a link to the docket for this final determination on the regulations.gov site. The regulations.gov Web page contains
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simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email: Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC, 20585-0121. Telephone: (202) 287-1604. Email: high_intensity_discharge_lamps@ee.doe.gov.
Ms. Francine Pinto, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC, 20585-
0121. Telephone: (202) 586-7432. Email: francine.pinto@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Determination
II. Introduction
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Legal Authority
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Background
1. Current Standards
2. History of Standards Rulemaking for High-Intensity Discharge Lamps
3. Changes From the 2010 Determination
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Color
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Replacement Options
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Shipments
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Summary of Changes
III. Issues Affecting the Lamps Analyzed by This Determination
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Lamps Analyzed by This Determination
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Standby/Off Mode
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Metric
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Coordination of the Metal Halide Lamp Fixture and HID Lamp Rulemakings
IV. General Discussion
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Test Procedures
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Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
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Energy Savings
1. Determination of Savings
2. Significance of Savings
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Economic Justification
V. Methodology and Discussion
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Market and Technology Assessment
1. General
2. Equipment Classes
3. Technology Options
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Mercury Vapor
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High-Pressure Sodium Lamps
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Metal Halide
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Summary
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Screening Analysis
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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
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Equipment Price Determination
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Markups Analysis
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Energy Use Analysis
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Life-Cycle Cost and Payback Period Analysis
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Shipments Analysis
I. National Impact Analysis
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Manufacturer Impact Analysis
VI. Analytical Results
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Economic Impacts on Individual Commercial Consumers
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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
5. Cumulative Regulatory Burden
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National Impact Analysis
1. Significance of Energy Savings
2. Net Present Value of Commercial Consumer Costs and Benefits
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Determination
1. Technological Feasibility
2. Significance of Energy Savings
3. Economic Justification
4. Conclusions
VII. Procedural Issues and Regulatory Review
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Review Under Executive Orders 12866 and 13563
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Review Under the Regulatory Flexibility Act
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Review Under the Paperwork Reduction Act
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Review Under the National Environmental Policy Act of 1969
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Review Under Executive Order 13132
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Review Under Executive Order 12988
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Review Under the Unfunded Mandates Reform Act of 1995
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Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
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Review Under the Treasury and General Government Appropriations Act, 2001
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Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VIII. Approval of the Office of the Secretary
I. Synopsis of the Determination
DOE determines that energy conservation standards for HID lamps do not meet the EPCA requirements described in section II.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 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 final determination and in the final determination technical support document (TSD).
II. Introduction
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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 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))
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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 IV.A).
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\1\ The final determination is available at: http://www.regulations.gov/#!documentDetail;D=EERE-2006-DET-0112-0002.
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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. 77 FR 11785. 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)
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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: http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0043-0016.
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 representative units, baselines, and candidate standard levels CSLs), the life-cycle cost (LCC) and payback period (PBP) analysis, and the shipment analysis.
On October 21, 2014, DOE published a notice of proposed determination (NOPD) in the Federal Register which proposed that energy conservations standards for HID lamps were not justified. 79 FR 62910. In conjunction with the NOPD, DOE also published on its Web site the complete TSD for the NOPD, which incorporated the analyses DOE conducted and technical documentation for each analysis. The NOPD TSD was accompanied by the LCC spreadsheet, the national impact analysis (NIA) spreadsheet, and the manufacturer impact analysis (MIA) spreadsheet--all of which are available in the rulemaking docket EERE-
2010-BT-STD-0043 at: http://www.regulations.gov/#!docketDetail;D=EERE-
2010-BT-STD-0043.
In the NOPD, DOE invited comment, particularly on the following issues: (1) The HID lamps selected for and excluded from analysis of economic justification for standards, (2) the decision to analyze equal wattage replacement lamps, as well as the methodology used to select the equal wattage replacement lamps, (3) the decision to include replacement pathways other than full fixture replacement, and (4) the proposal of a negative determination stating that standards for HID lamps were not justified. 79 FR 62910 (October 21, 2014).
The NOPD detailed that there would not be a public meeting unless one was requested by stakeholders. Because a public meeting was not requested, DOE did not hold a public meeting for the NOPD.
All comments received by DOE in response to the NOPD were considered in this final determination, including those received during the reopened comment period. 80 FR 6016 (February 4, 2015). Chapter 2 of this TSD summarizes and responds to comments received on the NOPD.
DOE concludes in this final determination that standards for HID lamps do not meet the statutory requirements for the establishment of standards, based either upon lack of technological feasibility, economic justification, or significant energy savings.
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, received written comments, conducted interviews with 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 final determination, in which DOE concludes that standards for HID lamps are either not technologically feasible or not economically justified.
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Color
In contrast to the 2010 determination, DOE established separate equipment classes based on correlated color temperature (CCT) in this final determination. CCT represents the color appearance of a light source and is expressed in kelvin (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 manufacturer catalog data concluded that CCT is correlated with lamp efficacy. DOE determined that higher-CCT lamps are less efficacious than lower CCT lamps of the same wattage. Because CCT is an approximation of the color appearance of a lamp, commercial consumers 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 established separate equipment classes based on CCT.
DOE established two different equipment classes based on CCT for MH and MV lamps, >=2800 K to 4500 and HPS lamps;
directional HID lamps;
self-ballasted HID lamps;
lamps designed to operate exclusively on electronic ballasts;
high-color rendering index (CRI) MH 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 5000-6999 K, have a non-screw base, and have non-T-shaped bulbs; and
electrodeless HID lamps.
See chapter 2 of the final determination 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.
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Standby/Off Mode
EPCA defines active mode as the condition in which an energy-using
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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 determined that HID lamps that are subject of this final determination 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 did not analyze potential standards for lamp operation in standby and off mode in this final determination.
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Metric
To analyze energy conservation standards related to HID lamps, DOE must select a metric for rating the performance of the lamps. DOE used initial efficacy for consideration and analysis of energy conservation standards for HID lamps. Additionally, because dimming is uncommon for HID lamps, DOE assessed initial efficacy of all lamps while operating at full light output.
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Coordination of the Metal Halide Lamp Fixture and HID Lamp Rulemakings
For this final determination, DOE used shared data sources between the metal halide lamp fixture (MHLF) standards rulemaking (Docket No. EERE-2009-BT-STD-0018) \2\ and this HID lamp determination. DOE's analysis of HID lamps assumed that MHLFs purchased after the compliance date of the MHLF final rule use ballasts compliant with those standards.
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\2\ A final rule for MHLF energy conservation standards was published in February 2014. For more information on the MHLF standards rulemaking, see http://www.regulations.gov/#!docketDetail;D=EERE-2009-BT-STD-0018.
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IV. General Discussion
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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 a HID lamps test procedure notice of proposed rulemaking (NOPR) published on December 15, 2011 (76 FR 77914) and subsequent additional research, DOE proposed revisions to and clarification of the proposed HID lamp test procedures. DOE published these proposed revisions and clarifications in a test procedure supplemental notice of proposed rulemaking (SNOPR).\3\ 79 FR 29631 (May 22, 2014). The analysis in this final determination is based upon the test procedures put forward in the test procedure SNOPR.
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\3\ The HID lamp test procedure SNOPR is available at: http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-TP-0044-0013.
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Technological Feasibility
1. General
In the final determination, 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 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 V.B of this final determination and chapters 2 and 4 of the final determination 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 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 final determination TSD.) The max-tech levels that DOE determined for this final determination are described in chapters 2 and 5 of the final determination TSD.
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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 final determination purchased in the 30-year period that would begin in the expected year of compliance with any new standards (2018-2047). 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 no-new-standards case. The no-new-standards 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.
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\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.
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DOE used its NIA spreadsheet model to estimate energy savings from potential standards for the equipment that are the subject of this final determination. The NIA spreadsheet model (described in section V.I of this final determination) calculates energy
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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 2015 (AEO2015).
DOE estimated full-fuel-cycle (FFC) energy savings. 76 FR 51281 (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 final determination 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 may be displaced if the estimated fuel were not consumed by the equipment covered in this final determination. 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 V.I of this determination, and chapter 11 and appendix 11A of the final determination TSD.
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\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: http://www.nap.edu/catalog/12670/review-of-site-point-of-use-and-full-fuel-cycle-measurement-approaches-to-doeeere-building-appliance-energy-efficiency-standards-letter-report.
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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 final determination (presented below in section VI.C.1).
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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) The market and technology assessment that characterizes where and how HID lamps are used; (2) an engineering analysis that estimates the relationship between equipment 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 efficacy in the considered HID lamps; and (5) an MIA that determines the potential impact new standards for HID lamps would have on manufacturers.
V. Methodology and Discussion
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Market and Technology Assessment
1. General
In conducting the market and technology assessment for this final determination, 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 final determination 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 final determination TSD for further discussion of the market and technology assessment.
2. Equipment Classes
For this final determination, 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 considered establishing separate standard levels for each equipment class based on the criteria set forth in 42 U.S.C. 6317(a).
In this final determination, DOE analyzed CCT, wattage, bulb finish, and luminaire characteristic as the equipment-class-setting factors. DOE analyzed 24 equipment classes for HID lamps, as shown in Table V.1. See chapters 2 and 3 of the final determination TSD for a more detailed discussion on equipment classes analyzed for HID lamps.\6\
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\6\ When delineating the equipment class CCT ranges of >=2800 K and 4500 K and =50 W and 400 W and 1000 W and =2800 and =50 and 400 and 1000 and 4500 and =50 and 400 and 1000 and =2800 and =50 and 400 and 1000 and 2800 K and =50 W to 2800 K and =50 W to 2800 K and =50 W to 2800 K and 400 and 2800 K and 1000 W to 2800 K and =50 W to 2800 K and 400 and 2800 K and 1000 W to =50 W to >=400 W Equipment Class--Flat Markup Scenario
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No-new- EL
Units standards ----------------------------------------
case 1 2 3
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INPV............................... 2014$ millions....... 290.0 285.3 256.6 311.8
Change in INPV..................... 2014$ millions....... ........... (4.7) (33.3) 21.8
%.................... ........... (1.6) (11.5) 7.5
Product Conversion Costs........... 2014$ millions....... ........... 7.4 31.4 55.0
Capital Conversion Costs........... 2014$ millions....... ........... ............ 6.0 54.5
Total Conversion Costs............. 2014$ millions....... ........... 7.4 37.4 109.5
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Table VI.8--Manufacturer Impact Analysis for the >=50 W to >=400 W Equipment Class--Preservation of Operating
Profit Markup Scenario
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No-new- EL
Units standards ----------------------------------------
case 1 2 3
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INPV............................... 2014$ millions....... 290.0 284.9 239.8 214.1
Change in INPV..................... 2014$ millions....... ........... (5.1) (50.1) (75.9)
%.................... ........... (1.7) (17.3) (26.2)
Product Conversion Costs........... 2014$ millions....... ........... 7.4 31.4 55.0
Capital Conversion Costs........... 2014$ millions....... ........... ............ 6.0 54.5
Total Conversion Costs............. 2014$ millions....... ........... 7.4 37.4 109.5
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Table VI.9 and Table VI.10 present the projected results of the 401-1000 W equipment class under the flat and preservation of operating profit markup scenarios.
Table VI.9--Manufacturer Impact Analysis for the >=400 W to >=1000 W Equipment Class--Flat Markup Scenario
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No-new- EL
Units standards --------------------------
case 1 2
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INPV...................................... 2014$ millions.............. 44.6 44.2 44.8
Change in INPV............................ 2014$ millions.............. ........... (0.3) 0.2
%........................... ........... (0.8) 0.6
Product Conversion Costs.................. 2014$ millions.............. ........... 0.5 4.9
Capital Conversion Costs.................. 2014$ millions.............. ........... ............ 0.8
Total Conversion Costs.................... 2014$ millions.............. ........... 0.5 5.7
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Table VI.10--Manufacturer Impact Analysis for the >=400 W to >=1000 W Equipment Class--Preservation of Operating
Profit Markup Scenario
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No-new- EL
Units standards --------------------------
case 1 2
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INPV...................................... 2014$ millions.............. 44.6 44.2 40.7
Change in INPV............................ 2014$ millions.............. ........... (0.3) (3.9)
%........................... ........... (0.8) (8.7)
Product Conversion Costs.................. 2014$ millions.............. ........... 0.5 4.9
Capital Conversion Costs.................. 2014$ millions.............. ........... ............ 0.8
Total Conversion Costs.................... 2014$ millions.............. ........... 0.5 5.7
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Table VI.11 and Table VI.12 present the projected results of the 1001-2000 W equipment class under the flat and preservation of operating profit markup scenarios.
Table VI.11--Manufacturer Impact Analysis for the >=1000 W to >=2000 W
Equipment Class--Flat Markup Scenario
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No-new- EL
Units standards -------------
case 1
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INPV........................ 2014$ millions. 3.0 2.2
Change in INPV.............. 2014$ millions. ........... (0.8)
%.............. ........... (25.2)
Product Conversion Costs.... 2014$ millions. ........... 0.6
Capital Conversion Costs.... 2014$ millions. ........... 0.4
Total Conversion Costs...... 2014$ millions. ........... 0.9
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Table VI.12--Manufacturer Impact Analysis for the >=1000 W to >=2000 W
Equipment Class--Preservation of Operating Profit Markup Scenario
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No-new- EL
Units standards -------------
case 1
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INPV........................ 2014$ millions. 3.0 2.3
Change in INPV.............. 2014$ millions. ........... (0.7)
%.............. ........... (24.4)
Product Conversion Costs.... 2014$ millions. ........... 0.6
Capital Conversion Costs.... 2014$ millions. ........... 0.4
Total Conversion Costs...... 2014$ millions. ........... 0.9
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2. Impacts on Employment
DOE quantitatively assessed the impacts of analyzed energy conservation standards on direct employment. DOE used the GRIM to estimate the domestic labor expenditures and number of domestic production workers in the no-new-standards case and at each EL for the 50-400 W equipment class, since the 50-400 W equipment class represents over 90 percent of all covered HID lamp shipments in 2018. Furthermore, manufacturers stated that most domestic employment decisions would be based on the standards set for the 50-400 W equipment class.
The employment impacts shown in Table VI.13 represent the potential production employment that could result following analyzed 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 the analyzed 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 production does not shift to lower labor-cost countries. Because there is a real risk of manufacturers evaluating sourcing decisions in response to analyzed 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 219 domestic production workers involved in manufacturing HID lamps in 2018. The table below shows the range of the impacts of analyzed standards on U.S. production workers in the HID lamp industry.
Table VI.13--Potential Changes in the Total Number of Domestic High-Intensity Discharge Lamp Production Workers
in 2018
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No-new- 50-400 W Equipment Class EL
standards -----------------------------------------------
case 1 2 3
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Total Number of Domestic Production Workers in 219 220 228 357
2018 (without changes in production locations).
Potential Changes in Domestic Production Workers .............. 0 to 1 (110) to 9 (219) to 138
in 2018 *......................................
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* 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 50-400 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 final determination 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
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these reasons, DOE conducted a cumulative regulatory burden analysis to make sure that the standards considered in this determination do not create a cumulative regulatory burden that is unacceptable to the overall lighting industry.
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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 2018, ending in the year 2047. 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 no-new-standards case. Table VI.14 presents the estimated primary energy savings for each efficacy level analyzed. Table VI.15 presents the estimated FFC energy savings for each efficacy level. Chapter 11 of the final determination TSD describes these estimates in more detail.
Table VI.14--Cumulative National Primary Energy Savings for HID Lamp
Efficacy Levels for Units Sold in 2018-2047
------------------------------------------------------------------------
National
primary
Equipment class Efficacy energy
level savings
(quads)
------------------------------------------------------------------------
>=2800 K and =50 W to =2800 K and 400 and =2800 K and 1000 W to =2800 K and =50 W to =2800 K and 400 and =2800 K and 1000 W to =2800 K and =50 W to =2800 K and 400 and =2800 K and 1000 W to
