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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM ............................................................................................. 1-1

1.3 OVERVIEW OF FLUORESCENT LAMP BALLAST STANDARDS ......................... 1-2

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS ...................... 1-4

1.5 STRUCTURE OF THE DOCUMENT ............................................................................ 1-7

LIST OF TABLES

Table 1.4.1 Analyses Under the Process Rule ............................................................................ 1-5
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This technical support document (TSD) is a stand-alone report that provides the technical 

analyses supporting the information in the notice of proposed rulemaking (NOPR) for 

fluorescent lamp ballasts.

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM

Part B of Title III of the Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 

6291–6309) established the energy conservation program for consumer products other than 

automobiles, covering major household appliances. Additional amendments to EPCA have 

given the U.S. Department of Energy (DOE) the authority to regulate the energy efficiency of 

several products, including certain fluorescent lamp ballasts, the products that are the focus of 

this document. 

DOE designs any new or amended standard to achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) To determine whether economic justification exists, DOE must review comments 

on the proposal and determine that the benefits of the proposed standard exceed its burdens to the 

greatest extent practicable, weighing the following seven factors: 

(1) the economic impact of the standard on the manufacturers and consumers of the 

products subject to the standard; 

(2) the savings in operating costs throughout the estimated average life of the products 

compared to any increases in the price, initial charges, or maintenance expenses for 

the products that are likely to result from the imposition of the standard; 

(3) the total projected amount of energy savings likely to result directly from 

imposition of the standard; 

(4) any lessening of the utility or the performance of the products likely to result from 

imposition of the standard; 

(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard; 

(6) the need for national energy conservation; and 

(7) other factors the Secretary considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)) 
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1.3 OVERVIEW OF FLUORESCENT LAMP BALLAST STANDARDS

Amendments to EPCA in the National Appliance Energy Conservation Amendments of 

1988 (NAECA 1988), Pub. L.100-357, established energy conservation standards for fluorescent 

lamp ballasts. a

 (42 U.S.C. 6295(g)(5)) These same amendments also required that DOE: (1) 

conduct two rulemaking cycles to determine whether these standards should be amended; and (2) 

for each rulemaking cycle, determine whether the standards in effect for fluorescent lamp 

ballasts should be amended so that they would be applicable to additional fluorescent lamp 

ballasts. (42 U.S.C. 6295(g)(7)(A)-(B))

On September 19, 2000, DOE published a final rule in the Federal Register which 

completed the first of the two rulemaking cycles to evaluate and amend the energy conservation 

standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”). 65 FR 56740. This 

rulemaking established a consensus standard, representing an agreement between the fluorescent 

lamp ballast industry and energy-efficiency advocacy organizations. The standard levels adopted 

replaced the ballast efficacy factors that were promulgated in NAECA 1988 for certain 

fluorescent lamp ballasts. A table of the standards codified by DOE can be found in Appendix 

3A under 10 CFR 430.32(m)(3). 

Congress promulgated new energy conservation standards for certain fluorescent lamp 

ballasts under the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58. (EPACT section 

135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)) On October 18, 2005, DOE published a final 

rule in the Federal Register codifying those new fluorescent lamp ballast standards into the Code 

of Federal Regulations at 10 CFR 430.32(m). 70 FR 60407. These standards established 

minimum ballast efficacy requirements for “energy saver” versions of full-wattage ballasts, such 

as the F34T12 ballast. A table of the standards promulgated by EPACT 2005 can be found in 

Appendix 3A under 10 CFR 430.32(m)(5).

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as 

amended, include fluorescent lamp ballasts that are designed to operate one and two nominally 

40 watt (W) and 34W 4-foot T12 medium bipin lamps (F40T12 and F34T12), two nominally 

75W and 60W 8-foot T12 single pin slimline lamps (F96T12 and F96T12/ES), and two 

nominally 110W and 95W 8-foot T12 recessed double contact high output lamps (F96T12 and 

F96T12/ES) at nominal input voltages of 120 or 277 volts with an input current frequency of 60 

hertz. 10 CFR 430.32(m). Ballasts that were excluded from regulation in the 2000 Ballast Rule 

 

a Although fluorescent lamp ballasts are typically understood to be a product used in the commercial and industrial 

sectors, it is the “consumer products” section of the statute which grants authority to DOE to cover and regulate this 

product. In the United States Code, Title 42 “The Public Health and Welfare,” Chapter 77 “Energy Conservation,” 

Subchapter III “Improving Energy Efficiency,” there are two parts which cluster together the group of products 

which DOE regulates. First, there is “Part A – Energy Conservation Program for Consumer Products Other than 

Automobiles” which includes a range of consumer products, some which may be classified as being used primarily 

in the residential sector, such as refrigerators, dishwashers and clothes washers. However, Part A also includes 

consumer products that might also be used primarily in the commercial sector, such as fluorescent lamps, 

fluorescent lamp ballasts and urinals. Second, Subchapter III has “Part A-1 – Certain Industrial Equipment,” which 

includes products that are primarily used in the commercial and industrial sectors, such as electric motors and 

pumps, and packaged terminal air conditioners and heat pumps.
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include: (1) ballasts designed for dimming to 50 percent or less of its maximum output; (2) 

ballasts designed for use with two F96T12HO lamps at ambient temperatures of -20 degrees 

Fahrenheit (F) or less and for use in an outdoor sign or ballasts designed for use with two 

F96T12HO/ES lamps at ambient temperatures of 20°F or less and for use in an outdoor sign; (3) 

ballasts with a power factor of less than 0.90 and designed and labeled for use only in residential 

building applications; and (4) replacement ballasts as defined in paragraph (m)(4)(ii).b 10 CFR 

430.32(m)(2), (m)(4). 

The standards promulgated by EPACT 2005 included similar exemptions, but these

exemptions expired for ballasts manufactured after July 1, 2010 and sold by the manufacturer on 

or after October 1, 2010. 10 CFR 430.32(m)(6) and (m)(7). Thus, the following ballasts that 

operate certain “energy saver” lamps are currently subject to standards: (1) ballasts designed for 

dimming to 50 percent or less of its maximum output; (2) ballasts designed for use with two 

F96T12HO lamps at ambient temperatures of -20 degrees F or less and for use in an outdoor sign 

or ballasts designed for use with two F96T12HO/ES lamps at ambient temperatures of 20 

degrees F or less and for use in an outdoor sign;c (3) ballasts with a power factor of less than 

0.90 and designed and labeled for use only in residential building applications; and (4) 

replacement ballasts. 10 CFR 430.32(m)(7). 

On December 19, 2007, the President signed the Energy Independence and Security Act of 

2007 (EISA 2007) (Pub. L. 110-140) which makes numerous amendments to EPCA and directs 

DOE to undertake several new rulemakings for appliance energy efficiency standards. EISA 

2007 did not amend standards for fluorescent lamp ballasts, but instead directed DOE to consider 

standby mode and off mode energy use for these ballasts. More specifically, EISA 2007 directed 

DOE to amend its test procedure for fluorescent lamp ballasts to incorporate a measure of 

standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2)(B)(ii)) DOE 

published a final rule for the standby and off mode test procedure on October 22, 2009. 74 FR 

54445. In addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate standby mode 

and off mode energy use in any amended (or new) standard adopted after July 1, 2010. Because 

this energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 

2011, the requirement to incorporate standby mode energy use into the energy conservation 

standards analysis is applicable.

This rulemaking encompasses DOE’s second cycle of review to determine whether the 

standards in effect for fluorescent lamp ballasts should be amended and whether standards 

 

b The exclusion provided for replacement ballasts requires that they meet certain criteria in order to be considered a 

replacement ballast, such as being designed to replace an existing ballast in a previously installed luminaire and 

being marked “FOR REPLACEMENT USE ONLY.” This exclusion only applies to replacement ballasts 

manufactured on or before June 30, 2010. After that date, replacement ballasts will no longer be excluded. (10 CFR 

430.32(m)(4)(ii)(A)) See Appendix A for the exact language of the exclusion for replacement ballasts. c Note that in 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly different than 

that contained in sections (m)(2) and (m)(4). In subsection (m)(7), ballasts designed for use with two

F96T12HO/ES lamps at ambient temperatures “of 20 degrees F or less” and designated for use in an outdoor sign 

are exempt from the standards in paragraph (m)(5). The other sections require the ballast to be for ambient 

temperatures of negative 20 degrees F or less.
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should be made applicable to additional fluorescent lamp ballasts as stated under section 

325(g)(7)(B) of EPCA. This rulemaking also addresses 42 U.S.C. 6295(o) in which DOE is 

directed to incorporate standby mode and off mode energy use in any amended (or new) standard 

adopted after July 1, 2010. 

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS

DOE considers the participation of interested parties to be a very important part of the 

standards-setting process. DOE encourages the participation of all interested parties during the 

comment period of each rulemaking stage. Beginning with the rulemaking framework document 

for fluorescent lamp ballasts (the framework document) and during subsequent comment periods, 

interactions among interested parties provide a balanced discussion of the information that is 

required for the standards rulemaking. 

In conducting the active mode test procedure and the energy conservation standard 

rulemakings, DOE involves interested parties through formal public notifications (i.e., Federal 

Register notices). For this fluorescent lamp ballast energy conservation standards rulemaking, 

DOE will employ the procedures set forth in DOE’s Process Rule (Procedures for Consideration 

of New or Revised Energy Conservation Standards for Consumer Products, 61 FR 36974, July 

15, 1996, 10 CFR Part 430, Subpart C, Appendix A) to the extent they are appropriate for 

developing energy conservation standards for the ballasts covered under this rulemaking. 

Before DOE determines whether to establish or amend energy conservation standards for 

fluorescent lamp ballasts, it must first solicit comments on a proposed standard. (42 U.S.C. 

6295(o)(2)(B)(i)). DOE must design each new or amended standard for these products to 

achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in significant energy savings. (42 U.S.C. 6295(o)(2)(A) 

and (3)) To determine whether a proposed standard complies with these requirements, DOE 

must, after receiving comments on the proposed standard, determine whether the benefits of the 

standard exceed its burdens to the greatest extent practicable, weighing the seven factors 

described above. 

Subsequent to the publication of the framework document, the standards rulemaking 

process involves preliminary analyses followed by two additional formal, major public notices, 

which are published in the Federal Register. The preliminary analyses are designed to publicly 

vet the models and tools used in the rulemaking and to facilitate public participation before the 

proposed rule stage. After the preliminary analyses are vetted, DOE issues the first major notice, 

the notice of proposed rulemaking (NOPR), which presents a discussion of comments received in 

response to the preliminary analyses of the impacts of standards on consumers, manufacturers, 

and the nation; DOE’s weighing of the impacts; and the proposed standards. The second notice 

is the final rule, which presents a discussion of comments received in response to the NOPR; the 

revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards 

adopted by DOE; and the compliance dates of the standards. 
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Table 1.4.1 Analyses Under the Process Rule

Preliminary Analysis NOPR Final Rule*

Market and technology assessment Revised ANOPR analyses Revised analyses

Screening analysis Life-cycle cost sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use characterization Utility impact analysis

Product price determination Employment impact analysis

Life-cycle cost and payback period analyses Environmental assessment

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice concerning 

the impact of any lessening of competition that is likely to result from the imposition of the standard. (42 U.S.C. 

6295(o)(2)(B)(v))

In January 2008, DOE published a rulemaking framework document for fluorescent lamp 

ballasts, which describes the procedural and analytical approaches DOE anticipated using to 

evaluate the establishment of energy conservation standards for fluorescent lamp ballasts. A 

PDF copy of the framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ballast_framework_

011408.pdf 

DOE held a public meeting on February 6, 2008 (hereafter “framework public meeting”), 

to discuss procedural and analytical approaches to the rulemaking, and to inform and facilitate 

the involvement of interested parties in the rulemaking process. The analytical framework 

presented at the framework public meeting described rulemaking analyses, such as the 

engineering analysis and the LCC and PBP analyses, the methods proposed for conducting them, 

and the relationships among the various analyses. See Table 1.4.1 for all the analyses discussed 

at the framework public meeting to be undertaken in each of the formal public rulemaking 

documents. PDF copies of the slides and other material associated with the framework public 

meeting are available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/ballast_framework_mtg.

html

During the framework public meeting and the framework document comment period, 

interested parties, including manufacturers, trade associations, and environmental advocates

submitted several comments about the fluorescent lamp ballast rulemaking. The major issues 

discussed were: (1) the rulemaking’s scope of coverage; (2) the development of product classes; 

(3) investigating the use a of a new energy efficiency metric for ballasts; (4) updating the active 

mode test procedure and developing a standby mode and off mode test procedure; (5) the 

methodology for the engineering analyses; (6) the lifetime of the ballast and lamp; (7) the 

methodology for developing shipment estimates; and (8) the use of marginal versus average 

electricity rates. Written comments submitted during the framework document comment period 
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elaborated upon the issues raised at the public meeting. A detailed discussion of comments from 

interested parties is available in chapter 2 of the preliminary TSD.

d

As part of the information gathering and sharing process, DOE organized and held 

preliminary interviews with fluorescent lamp ballast manufacturers and fixture manufacturers 

who operate in the U.S. ballast market. DOE had five objectives for these interviews: (1) solicit 

feedback on the scope of coverage for the rulemaking; (2) solicit feedback on the engineering 

analysis (including methodology, prices, and ballast technologies); (3) solicit feedback on topics 

related to the preliminary manufacturer impact analysis; (4) provide an opportunity early in the 

rulemaking process to express specific concerns to DOE; and (5) foster cooperation between 

manufacturers and DOE. During the manufacturer interviews, DOE discussed these and other 

issues regarding market data, distribution channels, anticipated consumer responses to standards, 

production and product mix, conversion costs, and cumulative regulatory burden. 

DOE published a notice announcing the availability of the preliminary analysis in March 

2010 and held a public meeting on April 26, 2010. At this meeting, DOE presented the 

methodologies and results of the analyses set forth in the preliminary TSD. Interested parties 

discussed the following major issues at the public meeting: the pros and cons of various 

efficiency metrics; how test procedure variation might affect efficiency measurements; special 

requirements for EMI-sensitive environments; product class divisions; manufacturer selling 

prices and overall pricing methodology; markups; the maximum technologically feasible ballast 

efficiency; regulatory burden; and shipments. Written comments received since publication of 

the March 2010 notice, including those received at the April 2010 public meeting, have 

contributed to DOE’s proposed resolution of the issues in this rulemaking. A detailed discussion 

of comments from interested parties is available in the NOPR Federal Register notice for this 

rulemaking. 

Following the publication of the preliminary analysis and the preliminary analysis public 

meeting, DOE held additional meetings with manufacturers as part of the consultative process 

for the manufacturer impact analysis conducted during the NOPR phase. The interviews covered 

several key issues, including: (1) test procedure follow-up; (2) preliminary TSD follow-up; (3) 

key issues to this rulemaking; (4) a company overview and organizational characteristics; (5) 

manufacturer markups and profitability; (6) shipment projections; (7) financial parameters; (8) 

conversion costs; (9) cumulative regulatory burden; (10) direct employment impact assessment; 

(11) manufacturing capacity and non-US sales; (12) impact on competition; and (13) impacts on 

small business.

For the LCC, PBP and national impact analyses (NIA), DOE developed spreadsheets 

using Microsoft Excel®. The LCC and PBP spreadsheets calculate the economic impacts of 

replacing products with standard-compliant ones. The NIA spreadsheets calculate the national 

energy savings (NES) and national net present values (NPVs) at various energy efficiency levels 

and include a model that forecasts the impacts of energy conservation standards at various levels 

on product shipments. These spreadsheets are available on the DOE website at

 

d

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts_ecs_prelim_tsd.

html
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http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballast

s.html

1.5 STRUCTURE OF THE DOCUMENT

This NOPR TSD outlines the analytical approaches used in this rulemaking. The TSD 

consists of 17 chapters and appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards 

program and how it applies to the rulemaking for fluorescent lamp 

ballasts, and outlines the structure of the document 

Chapter 2 Analytical Framework: describes the rulemaking process, provides 

an overview of each analysis, and discusses comments received 

during the framework document public meeting comment period. 

Chapter 3 Market and Technology Assessment: characterizes the fluorescent 

lamp ballast market and the technologies available for increasing 

ballast luminous efficiency and outlines product classes 

Chapter 4 Screening Analysis: determines which technology design options 

are viable for consideration in the engineering analysis

Chapter 5 Engineering Analysis: describes DOE’s approach to the 

engineering analysis and discusses how manufacturer costs and 

selling prices relate to ballast luminous efficiency 

Chapter 6 Energy Use Characterization: discusses the sources and methods 

for developing energy use estimates for fluorescent lamp ballasts

Chapter 7 Markups Analysis: discusses the methods DOE used for 

establishing markups manufacturer selling price to installed 

customer prices

Chapter 8 LCC and PBP Analyses: discusses the economic effects of 

standards and compares the LCC and PBP of fluorescent lamp 

ballasts with and without higher energy conservation standards 

Chapter 9 Trial Standard Levels: discusses the efficiency levels for each 

analyzed product class as they pertain to the trial standard levels 

chosen for fluorescent lamp ballasts 
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Chapter 10 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards 

Chapter 11 National Impact Analysis: describes the national forecast of energy 

consumption, efficiency of new ballasts, and annual fluorescent 

lamp ballast sales in the absence or presence of new standards 

Chapter 12 Life-Cycle Cost Sub-Group Analysis: discusses the effects of 

standards on a subgroup of fluorescent lamp ballast consumers and 

compares the LCC and PBP of product with and without higher 

efficiency standards for these consumers 

Chapter 13 Manufacturer Impact Analysis: discusses the effects of standards 

on the finances and profitability of fluorescent lamp ballasts, and 

presents preliminary manufacturer impact analysis results

Chapter 14 Utility Impact Analysis: discusses the effects of standards on 

electric utilities

Chapter 15 Employment Impact Analysis: discusses the effects of standards on 

national employment

Chapter 16 Environmental Assessment: discusses the effects of standards on 

two pollutants, sulfur dioxide (SO2) and nitrogen oxides (NOx), as 

well as carbon emissions 

Chapter 17 Regulatory Impact Analysis: discusses the impact of nonregulatory alternatives to energy conservation standards

Appendix AA Acronyms and Abbreviations: provides a set of acronyms and 

abbreviations used throughout the TSD. 

Appendix 3A Fluorescent Lamp Ballasts in the United States Code and Code of 

Federal Regulations: provides a set of existing statutory and 

regulatory definitions and requirements for fluorescent lamp 

ballasts

Appendix 5A Material Prices: analyzes how commodity price changes affect the 

manufacturer selling price of ballasts 

Appendix 5B T5 Miniature Bipin Baseline Ballasts: describes the methodology 

behind developing low efficiency T5 baseline ballasts 

Appendix 5C Test Data: lists the test data used for the fluorescent lamp ballast 

engineering analysis
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Appendix 5D Analysis of Potential Efficiency Improvements: presents details of 

an analysis of efficiency improvements for commercially available 

ballasts

Appendix 5E Electromagnetic Interference: presents research regarding EMI 

generated by electronic ballasts

Appendix 5F Advanced Technology Scenario: explores the possibility of a 

higher efficiency level for instant start ballasts

Appendix 8A Manufacturer Price Projections 

Appendix 8B User Instructions for Life-Cycle Cost and Payback Period 

Spreadsheet

Appendix 8C Advanced Technology Scenario: reports life-cycle costs and 

payback periods for the advanced technology scenario. 

Appendix 11A User Instructions for Shipments and NIA Spreadsheet 

Appendix 11B Advanced Technology Scenario: reports NIA results for the 

advanced technology scenario 

Appendix 13A Preliminary Manufacturer Interview Guide

Appendix 13B Government Regulatory Impact Model Overview 

Appendix 13C Advanced Technology Scenario: reports MIA results for the 

advanced technology scenario 

Appendix 16A Social Cost of Carbon for Regulatory Impact Analysis Under 

Executive Order 12866