"Mercury-free lamps, such as LEDs, can be included in the picogram per lumen-hour calculations only if they have efficiency levels that are equal to or greater than those of comparable mercury-containing counterparts."

What documentation is required to prove this? We are including some halogen lamps that have no mercury in our purchasing plan. We have the MSDS for each lamp. Do we then also need to get MSDS for some other lamps that we are not using, just to show that our lamp has higher lumen/watt than a mercury lamp? I guess my question is: how do we decide which lamp is comparable? It seems sort of random, like I could search out any mercury containing lamp and just find one that is less efficient than mine so I can include mine in the plan.

We also purchased LED lights during our performance period. Can we include those in Table 4-2 in order to drive down our overall picogram per lumen-hour number? Will those require additional comparison information as well?