### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 1 

# U.S. Department of Energy Energy Conservation Program for Consumer Products an d Commercial and Industrial Equipment 

## Framework Document Public Meeting on En ergy Conservation Standards for Fluorescent Lamp Ballasts February 6, 2008 Washington, DC

http://www.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

2 

## Welcome and Introduction • Introductions • Role of the Facilitator • Ground Rules (norms) – Listen as an ally – Use short, succinct statements/keep to the point – Hold sidebar conversations outside the room – Focus on issues, not personalities – One person speak at a time (raise hand to be recognized; state your name for the record) – Set cell phones to silent/vibrate • Housekeeping Items

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 2 3 

## Morning Agenda Welcome In troductions and Agenda Review Opening Remarks Regulatory History and Scope of Coverage Test Procedure and Energy Conservation Standard Overview Break Market and Technology Assessment and Screening Analysis Engineering Analysis and Product Price Determination 9:00 – 9:05 am 9:05 – 9:20 am 9:20 – 9:40 am 9:40 – 10:00 am 10:00 – 10:30 am
10:30 – 10:45 am 10:45 – 11:30 am 11:30 – 12:00 pm

4



## Afternoon Agenda Break for lunch Preliminary Manufacturer Impact Analysis Energy Use and End-Use Load Characterization; and Life-Cycle Cost and Payback Period Analysis Shipments Analysis, National Impact Analysis, and Life-Cycle Cost Subgroup Analysis Break Manufacturer Impact Analysis Utility Impact Analysis, Employment Impact Analysis, Environmental Assessment, and Regulatory Impact Analysis Other issues and comments; closing remarks 12:00 – 1:00 pm 1:00 – 1:15 pm 1:15 – 2:00 pm 2:00 – 2:30 pm 2:30 – 2:45 pm 2:45 – 3:15 pm 3:15 – 3:45 pm
3:45 – 4:30 pm

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 3 5 

## Stakeholder Opening Statements

Stakeholders who contacted DOE and requested an opportunity to make an opening statement should speak now.

6



## Public Meeting Agenda

2 3 NOPR Analyses 1

ANOPR Analyses 4 Test Procedures Introduction

3 ANOPR Analyses Energy Conservation Standards 4 Introduction

Final Rule 5 NOPR Analyses 6 Closing Remarks

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 4 7 Introduction 

## Purpose of the Framework Document Public Meeting • Present the procedural and analytical approaches to evaluate energy conservation standards for fluorescent lamp ballasts. • Provide a forum for public discussion of rulemaking issues. • Encourage stakeholders to submit data, information, and written comments. • Inform stakeholders and facilitate the rulemaking process.

8



## Requests for Comment

Issue Box In the Rulemaking Framework Document for Fluorescent Lamp Ballasts, DOE welcomes comment. Throughout this presentation specific issues will be brought up for discussion on slides such as this, with identifying numbers corresponding to those in the Framework Document. Nonetheless, comments concerning any part of the document or presentation are welcome. Introduction

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 5 9 

### In all correspondence, please refer to the Fluorescent Lamp Ballast rulemaking by: – Fluorescent Lamp Ballasts Rulemaking, – Docket Number EERE–2007–BT–STD–0016, and – Regulatory Identification Number (RIN) 1904-AB50 Email : Ballasts.Rulemaking@ee.doe.gov

Comment period closes: March 7, 2008



## Feedback Is Requested Especially on Items Identified in Framework Document Introduction

Mrs. Brenda Edwards U.S . Department of Energy Building Technologies Program, 6th Floor 950 L’Enfant Plaza, SW Washington, DC 20024 Tel: 202 586-2945 Mrs. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE-2J 1000 Independence Avenue, SW Washington, DC 20585-0121 

### Courier : Postal :

10



## Regulatory History Regulatory History


### • Energy Policy and Conservation Act (EPCA) of 1975, Pu b. L. 94-163 – Established the energy conservation program. 

### • National Appliance Energy Conservation Amendments (N AECA) of 1988, Pub. L.100-357 – Prescribed test procedure, codified in 1989, 54 FR 6076 – P rescribed standards, codified in 1989, 54 FR 6077 – Directed DOE to review and amend standards – “first cycle” (complete, Sept. 19, 2000)

– D irected DOE to review and amend standards – “s econd cycle” (being initiated now) 

### • Fluorescent Lamp Ballasts Energy Conservation Sta ndard published Sept. 19, 2000, 65 FR 56740 – Standard adopted was a consensus agreement between industry and efficiency advocates.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 6 11 

## Regulatory History (continued) • Energy Policy Act (EPACT) of 2005, Pub. L. 109-58 – Added definitions for T12 energy saver lamps – S et standards for ballasts operating T12 energy saver lamps, codified October 18, 2005, 70 FR 60407. 

### • Energy Independence and Security Act (EISA) of 2007, Pu b. L. 110-140 – Directs DOE to amend the fluorescent lamp ballast test procedure to incorporate standby and off mode. – Directs DOE to incorporate standby and off mode in standards rulemaking of ballasts (i.e., final rule after July 1, 2010). – Defines ‘ballast’ and ‘electronic ballast’ (see next slide). – Removes the requirement to conduct an ANOPR for certain products including fluorescent lamp ballasts. Regulatory History

12 

## Fluorescent Lamp Ballast Definitions • NAECA of 1988 defined fluorescent lamp ballasts:

– “ fluorescent lamp ballast means a device which is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation.” (42 U.S.C. 6291 (29)(A)) 

### • Section 324 of EISA 2007 (i.e., Metal Halide Lamp Fixtures)defines:

– “ Ballast. T

he term ‘ballast' means a device used with an electric discharge lamp to obtain necessary circuit conditions (voltage, current, and waveform) for starting and operating.” (42 U.S.C. 6291(58))

– “ Electronic Ballast. The term ‘electronic ballast' means a device that uses semiconductors as the primary means to control lamp starting and operation.” (42 U.S.C. 6291(60)) Scope of Coverage

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 7 13 

### 120/277V Fluorescent Lamp Ballasts that Operate
One and Two 4-foot Medium Bipin

60W T12 75W

T12 95W T12 40W T12 34W T12 110W T12 

### • Exclusions: – Dimming to 50 percent or less of maximum output – B allasts designed for use with two F96T12HO lamps at ambient temperatures of -20 ° 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 – Power factor of less than 0.90 and designed/labeled for residential building applications – Replacement ballasts as defined in 10 CFR (m)(4)(ii) until June 30, 2010



## Fluorescent Lamp Ballast Standards

Two 8-foot Recessed Double Contact High Output Two 8-foot Single Pin Slimline Scope of Coverage

14 

## Additional Fluorescent Lamp Ballasts • In this rulemaking, DOE will also be considering whether to extend coverage to apply standards to additional fluorescent lamp ballasts.

– The statute directs DOE: “After January 1, 1992, the Secretary shall p ublish a final rule no later than five years after the date of publication of a previous final rule. The Secretary shall determine in such rule whether to amend the standards in effect for fluorescent lamp ballasts, including whether such standards should be amended so that they would be applicable to additional fluorescent lamp ballasts.” (42 U.S.C. 6295(g)(7)(B)) Scope of Coverage

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 8 15 

## Additional Fluorescent Lamp Ballasts (cont.) • DOE is considering extending coverage to ballasts that operate all fluorescent lamps covered under EPCA, which are: • 4-foot, medium bi-pin, rated ≥ 28 watts • 2 -foot, medium bi-pin, U-shaped lamps, rated ≥ 28 watts • 8-foot, recessed double-contact, rapid start, high output lamps, 0.800 nominal amperes, as defined in ANSI C78.1–1991 • 8-foot, single pin, instant start, slimline lamps, rated ≥ 52 watts, as defined in ANSI C78.3–1991 

### • Note: DOE is also considering additional fluorescent lamps for coverage inthe fluorescent lamp rulemaking (i.e., in addition to those listed above). – DOE will consider coverage of ballasts that operate those additional fl uorescent lamps as well. Scope of Coverage

16 

### Fluorescent Lamps which have Standards

4-foot Medium Bipin ≥ 28W 2-foot U-shaped Medium Bipin ≥ 28 W

60W T12 75W

T12 95W

0.8-Amp T12 110W

0.8-Amp T12
DOE has standards for ballasts that operate these lamps. In this rulemaking, DOE is considering establishing standards for ballasts that operate these lamps. 44W T8 40W T12 40W T10 34W T12 32W T8 Other lamps e.g. T8 30W, 28W 40W 6” Center T12 40W 3-5/8” Center T12 31W 1-5/8” Center T8 32W

6” Center T8 Other lamps e.g. T12 34W 

## Standards Map for Fluorescent Lamps and Ballasts

8-foot Recessed Double Contact High Output 8-foot Single Pin Slimline ≥ 52 W Scope of Coverage

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 9 17 

## Request for Comment

Item 1 DOE welcomes comment on the scope of this rulemaking, which implements the statutory requirement to consider additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) Scope of Coverage

18 Introduction 

## Fluorescent Lamp Ballast Rulemakings

2006 ScheduleSetting Process

Fluorescent Lamp Ballast Test Procedure Rulemaking on Standby Mode and Off Mode (EISA 2007) Framework Document 01/2008 ANOPR 1

11/2009 Energy Conservation Standards for Fluorescent Lamp Ballasts NOPR 1 10/2010 Final

Rule 06/2011

1 ANOPR: Advance Notice of Proposed Rulemaking NOPR: Notice of Proposed Rulemaking NOPR 7/2008

Final Rule 10/2010 NOPR 11/2009 Final Rule 3/2009

Potential Additional Fluorescent Lamp Ballast Test Procedure to Update and Amend

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 10 19 

### 2 3 NOPR Analyses 1

ANOPR Analyses 4 Test Procedures Introduction

3 ANOPR Analyses Energy Conservation Standards 4 Introduction

Final Rule 5 NOPR Analyses 6 Closing Remarks 

## Public Meeting Agenda

20 

## Standby Mode and Off Mode Test Procedure (1 of 2) Test Procedures



### • EISA 2007 directs DOE to amend its fluorescent lamp ballast test procedure to incorporate a measure of standby mode and off mode energy use by March 31, 2009. 

### • Off Mode – EISA 2007 defines “off mode” as the condition when a product is co nnected to the main power source and is not providing any standby or active mode function. – DOE believes that when a fluorescent lamp ballast is not providing any standby or active mode function, the fluorescent lamp ballast is disconnected from the main power source. If the ballast is disconnected from the power source, it does not meet the definition of “off mode.” – Therefore, DOE believes fluorescent lamp ballasts do not operate in “off mode” as defined by EISA 2007.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 11 21 

## Standby Mode and Off Mode Test Procedure (2 of 2) Test Procedures


### • Standby Mode – DOE may need to amend its test procedure to include standby mode en ergy use. – EISA 2007 defines standby mode as the condition in which a product is connected to a main power source and either: • Facilitates the activation or deactivation of other functions (including active mode) by remote switch, internal sensor or timer; or • Offers continuous functions including information or status-displays, or sensor-based function. – DOE understands that new ballasts are now being designed with circuitry that adds new features, including intelligent operation. • These ballasts may use standby mode power (e.g., ballasts that employ a lighting controls system such as Digital Addressable Lighting Interface (DALI)).

22



## Request for Comment Test Procedures



### Item 2 DOE welcomes comment on the standby power provisions from EISA 2007 and issues arising therefrom, including: (a) How DOE should modify its test procedure for fluorescent lamp ballasts; (b) Which covered fluorescent lamp ballasts are subject to standby mode and off mode energy use?; and (c) How DOE should take standby mode and off mode energy consumption into its analysis for the energy conservation standard?

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 12 23 

## Potential Additional Test Procedure Test Procedures



### • NAECA of 1988 prescribed test procedures for fluorescent lamp ballasts, bu t only magnetic ballasts, not electronic. • DOE is considering updating the magnetic ballast test procedure citations and adding test procedures for electronic ballasts. • Reference documents DOE is considering: – ANSI C82.2-2002, “For Lamp Ballasts- Method of Measurement of Fl uorescent Lamp Ballasts,” – ANSI C82.1-2004, “For Lamp Ballast- Line Frequency Fluorescent Lamp Ballast,” and – ANSI C82.11-2002, “For Lamp Ballasts- High Frequency Fluorescent Lamp Ballasts.” 

### • DOE notes that ANSI employs a different method to determine the ballast fa ctor for rapid-start and instant-start ballasts. • DOE notes that there are no ANSI test procedures for those ballasts that operate lamps that are not part of ANSI C78.81

24



## Request for Comment Test Procedures



### Item 3 DOE welcomes comment on the issue of updating the fluorescent lamp ballast test procedure. DOE also invites comment on whether it should update the test procedure to include the industry standards ANSI C82.2- 2002, C82.1-2004, C82.11-2002 or any additional procedures that should be considered in its test procedure rulemaking for fluorescent lamp ballasts. Item 4 DOE welcomes comment on the two different ANSI methods used to calculate ballast factor for rapid-start and instant-start ballasts. If the two methods are not comparable, DOE invites comment on any conversion factors necessary to make them comparable. Finally, DOE invites comment on whether manufacturers report the ballast factor for instant-start ballasts in their literature using the ANSI or DOE test procedure. Item 5 DOE also welcomes comment on ballast factor calculation methods used for programmed-start ballasts, modified rapid-start ballasts and other types of fluorescent lamp ballasts not covered by ANSI C82.2-2002. DOE welcomes comment on how to test fluorescent lamp ballasts when operating lamps that are not part of ANSI C78.81.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 13 25 

### 2 3 NOPR Analyses 1

Energy Conservation Standards 4 Rulemaking Overview Introduction 2

ANOPR Analyses Test Procedure

4 Introduction

Final Rule 5 NOPR Analyses 6 Closing Remarks 

## Public Meeting Agenda

26 Energy Conservation Standards 

## EPCA Factors

Environmental Assessment Utility Impact Analysis Employment Impact Analysis 7. Other factors the Secretary considers relevant National Impact Analysis 6. Need for national energy conservation Manufacturer Impact Analysis 5. Impact of any lessening of competition Engineering Analysis Screening Analysis 4. Impact on utility or performance National Impact Analysis 3. Total projected energy savings Life-Cycle Cost Analysis 2. Lifetime operating cost savings compared to increased cost for the product Life-Cycle Cost Analysis Manufacturer Impact Analysis 1. Economic impact on consumers and manufacturers 

### DOE Analysis

EPCA Factors 

### • 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(a) direct DOE to consider seven factors when setting energy conservation standards for fluorescent lamp ballasts:

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 14 27 

## Stages for the Energy Conservation Standard Rulemaking for Fluorescent Lamp Ballasts

R e p o r t t o C o n g r e s s

F r a m e w o r k D o c u m e n t

Framework Document Public Meeting Points of Stakeholder Participation

Milestones for DOE

ANOPR Public Meeting NOPR

Public Meeting 2010 2013 2009 2011 2012 2008 Energy Conservation Standards

2007 2014 A N O P R P u b l i s h e d *
N O P R P u b l i s h e d

F i n a l R u l e P u b l i s h e d

S t a n d a r d s A p p l i c a b l e 2006

*Note: EISA 2007 removed the requirement for DOE to publish an ANOPR for this product.

28



## Framework Document

Framework Document ANOPR NOPR Final Rule Today 

### • Today’s public meeting covers the Framework Document for this product • F ederal Register Notice of Public Meeting, 73 FR 3653, Jan 22, 2008. – Gives notice of the public meeting and availability of the Framework Do cument being discussed today 

### • Framework Document – Provides an overview of the rulemaking process and encourages early stakeholder participation – Encourages interested parties to submit comments by March 7,2008 – The Framework Document and materials from today’s public meeting are available online: http://www.eere.energy.gov/buildings/appliance_standards/residential/ballast _framework_mtg.html Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 15 29 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Energy Use and

End-Use Load Characterization Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

30 

## Analyses for the ANOPR Energy Conservation Standards
Approaches Key Inputs Analyses Key Outputs
Market and Technology Assessment Screening Analysis
Engineering Analysis

Product Price Determination Life-Cycle Cost and Payback Period Analyses

National Impact Analysis Energy Use

Shipments Analysis • Product Classes • Technology Options

• Product Designs

• Life-Cycle Costs • Payback Periods

• National Energy Savings • Net Present Values • Characterize Industry • Market Segmentation • Non-Regulatory Programs Framework Document

• Efficiency-Level Approach • Design Option Approach

• Energy Prices • Installation Costs • Maint. & Repair Costs • Accounting Approach • Backcast and Forecast • Market Saturation • Identify Firms/Products • Historical Shipments

•Retail Price Collection and Analysis Design Options Product Classes

Retail Prices Design Energy/ Use

Advance Notice of Proposed Rulemaking (ANOPR) • Efficiency/Performance • Commercial Products

Candidate Standard Levels • Analysis of Energy Use Data Technology Options • Design Options

• Energy Price Forecasts • Site-to-Source Factors • Energy-Efficiency Levels • Analysis of Market Data • Analysis of Product Data

• Installation Costs • Maint. Costs • Repair Costs • UEC • Energy Prices Annual Energy Use (UEC)

Preliminary Manufacturer Impact Analysis • Manufacturer Prices • Average Costs • Conversion Capital Expenditures • Direct Employment Impacts • Product Prototypes

Energy-Efficiency Levels Product Designs

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 16 31 

## Purpose of the ANOPR Public Meeting • To present methodologies for the ANOPR analyses, and ch aracterize results • To discuss specific issues related to the ANOPR analysis • To seek input from attendees on methodologies, assumptions, data sources • To describe upcoming analyses and next steps, and seek further input Energy Conservation Standards

32 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Environmental Assessment Regulatory

Impact Analysis

Life-Cycle Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

Revise ANOPR Analyses

Engineering Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 17 33 

## Analyses for the NOPR and Final Rule Energy Conservation Standards

Utility Impact Analysis

Notice of Proposed Rulemaking (NOPR)

Final Rule Approaches Key Inputs Analyses Key Outputs

Revise ANOPR Analyses Life-Cycle Cost Sub-Group Analysis Manufacturer Impact Analysis

Employment Impact Analysis

Revise Analyses • Industry Cash Flow • Sub-Group Cash-Flow • Direct Employment Impacts • Competitive Impacts • Cumulative Regulatory Burden

• National Employment Impacts

• Revised Results • Stakeholder Comments
• Demographics

• Manufacturer Interviews • GRIM Analysis

• Emission Rates • National Energy Savings

• Stakeholder Comments • Manufacturer Prices • Average Costs • Manufacturer Financial Data Advance Notice of Proposed Rulemaking (ANOPR)

Environmental Assessment Regulatory Impact Analysis • Emission Estimates • Utility Load Factors • National Energy Savings

• Non-Regulatory Alternatives • NEMS-BT

• ImSET

• NEMS-BT Direct Employment Impacts • National Energy Savings • National Product Costs • National Operating Costs • Utility Impacts • Life-Cycle Costs • Payback Periods

• National Energy Savings • Net Present Values • Trial Standard Levels (TSLs) TSLs

• Department of Justice Review • Efficiency-Level Approach • Design Option Approach

34 

## Purpose of the NOPR Public Meeting • To hear the views of stakeholders on DOE’s proposed standard levels • To obtain input on any remaining issues relating to the Notice of Proposed Rulemaking

DOE will consider all verbal and written comments in preparing its Final Rule. Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 18 35 Framework Document ANOPR NOPR Final Rule 

## Analyses for Final Rule

Final Energy Conservation Standards

Revise NOPR Analyses

36 

### 2 3 ANOPR Analyses 1

ANOPR Analyses 4 Rulemaking Overview Introduction 2 Energy Conservation Standards Test Procedure 3 Introduction

Final Rule 5 NOPR Analyses 6 Closing Remarks 

## Public Meeting Agenda

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 19 37 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Energy Use and

End-Use Load Characterization Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

38 

## Purpose • Characterize the markets, the fluorescent lamp ballast industry, an d the measures to improve efficiency



## Method • Identify and characterize manufacturers of fluorescent lamp ba llasts; • Estimate shipments and trends in the market; • Identify regulatory and non-regulatory initiatives intended to improve the efficiency of the products covered under this rulemaking; • Study market failures or other specific problems that may warrant agency action; and • Identify technologies that could improve efficiency. Market and Technology Assessment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 20 39 

## Relationship of Market and Technology Assessment

to other Analyses Market and Technology Assessment Product Classes Technology Options to improve efficiency

Screening Analysis Design Options to improve efficiency Engineering Analysis Market and Technology Assessment

40 

## Request for Comment

Item 6 DOE welcomes input on shipments, manufacturing costs, product-feature and efficiency trends, distribution channels, and estimates of market shares for the fluorescent lamp ballasts covered in this rulemaking. For DOE to be able to use the data to conduct energy savings calculations, a degree of disaggregation (e.g. by product class) is desirable. Item 7 DOE is seeking stakeholder comment and data on potential market failures that could apply to fluorescent lamp ballasts. Market and Technology Assessment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 21 41 

### • DOE establishes separate energy conservation standards for each product class. • DOE divides covered product into classes by: – The type of energy used – Capacity of the product or other performance-related features that justify different standard levels, such as features affecting consumer utility (42 U.S.C. 6295(q)) Market and Technology Assessment 

## Product Classes

42

Market and Technology Assessment 

## Fluorescent Lamp Ballast Product Classes

and Standards

220 22 0 150 150 80 80 40 40 Total Nominal Lamp Watts

0.39 277 0 .63 277 1.17 277 2.29 277 Ballast Efficacy Factor Ballast Input Voltage Ballast for the Operation of

0.39 0.6 3 1.17 2.29

120 120 120 120

Two F96 T12HO lamps Two F96 T12 lamps Two F40T12 lamps One F40T12 lamp



### 10 CFR 430.32 (m)(3)(ii)(C) • Standards became effective to ballast manufacturers on July 1, 2005. • P roduct classes used by NAECA 1988 and DOE Final Rule, 2000.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 22 43 Market and Technology Assessment 

## Fluorescent Lamp Ballast Product Classes and

Standards (continued)

190 19 0 120 120 68 68 34 34 Total Nominal Lamp Watts

0.42 277 0 .77 277 1.35 277 2.61 277 Ballast Efficacy Factor Ballast Input Voltage Ballast for the Operation of

0.42 0.7 7 1.35 2.61

120 120 120 120

Two F96 T12HO/ES lamps Two F96 T12/ES lamps Two F34T12 lamps One F34T12 lamp



### 10 CFR 430.32 (m)(5)(ii)(C) • Standards will become effective to ballast manufacturers on October 1, 2009. • P roduct Classes used by EPACT 2005.

44 

## Considerations for Fluorescent Lamp Ballast

Product Classes • DOE is considering amending product classes for fluorescent la mp ballasts. • DOE is considering subdividing product classes by: – Lamp Length (e.g., 4-foot vs. 8-foot) – B ase Type (e.g., High Output vs. Normal Output) – Number of Lamps Operated (e.g., 1 lamp vs. 2 lamps) 

### • DOE may also subdivide product classes by: – Lamp Diameter (e.g., T8 vs. T12) – Lamp Wattage (e.g., 34W vs. 40W) – Starting Method (e.g., rapid start vs. instant start) – Total Harmonic Distortion (e.g., <10% vs. <20%) – Able to operate at multiple input voltages (e.g., universal) – Able to operate multiple # of lamps (e.g., 2 or 3 lamps) Market and Technology Assessment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 23 45 

## Sample of Today’s Market: Electronic Ballasts for

Two 4-foot Medium Bipin Lamps Market and Technology Assessment



### 1 1.2 1.4 1.6 1.8 2 2.2

26 28 30 32 34 36 38 40 42 Lamp Wattage of One Lamp (Watts)Ballast Efficacy Factor (BEF) 

### Average BEF of Sample EPCA Standards 

## T12 T8

46 

## Difference in Ballast Efficacy Factor By

Lamp Wattage

Market and Technology Assessment



### • DOE could recognize the variance in Ballast Efficacy Factor by la mp wattage by either: (1) Setting a different product class at each wattage (e.g., 40W, 34W, 32W, 28W); or (2) Have a single product class for a given lamp length, base type, and number of lamps, and set the BEF requirement based on an equation that varies with wattage.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 24 47 

## Possible Product Classes for Discussion Ballast Efficacy Factor

ƒ(W L ) ƒ(W L ) ƒ(W L ) 1 lamp

ƒ(W L )

ƒ(W L ) ƒ(W L ) 2 lamps ƒ(W L )

3 lamps

8-foot recessed double contact high output fluorescent lamp 8-foot single pin slimline fluorescent lamp ƒ(W L ) 4-foot straight-shaped or 2-foot U-shaped medium bipin fluorescent lamp 4 lamps Fluorescent Lamp Ballast for the Operation of Market and Technology Assessment



### • Ballast Efficacy Factor requirements would be an equation that varies with lamp wattage. • Standards would be applicable to all ballast input voltages. 

### Item 8 DOE welcomes comment on product classes for fluorescent lamp ballasts and approaches to defining classes in accordance with the requirements of 42 U.S.C. 6295(q).

48 

## Initial Technology Options for Fluorescent Lamp Ballasts • Cathode Cutout or Hybrid Ballast – Removes electrode power (thereby reducing system energy use) after the di scharge has been initiated for rapid-start lamps. 

### • Electronic Ballast – Allows for high-frequency operation which decreases losses near the lamps el ectrode and reduces other ballast losses by allowing for smaller components. 

### • Integrated Circuits – Integrated circuits reduce conductive energy losses. 

### • Higher Grade Components – Higher-grade magnetic materials and improved semiconductor materials reduce co nductive energy losses. 

### • Improved Circuit Design – Better circuit design can increase a ballast’s efficiency and reduce conductive losses. Market and Technology Assessment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 25 49 

## Request for Comment
Item 9 DOE welcomes comment on the preliminary technology options identified in this section. DOE welcomes comment on whether there are other technology options that it should also consider. In commenting on design options, please discuss their impacts on safety, performance, and consumer utility (if any). Market and Technology Assessment

50 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 26 51 Screening Analysis



### Impacts on health or safety Impacts on product utility or availability to consumers Practicability to manufacture, install and service

Technological feasibility 

## Purpose • Screen out technology options that DOE will not consider in the en gineering analysis for fluorescent lamp ballasts.



## Approach • DOE will evaluate each technology option based on the following criteria:

• See Appendix A to Subpart C of 10 CFR Part 430 (4)(a)(4) and (5)(b).

52



## Request for Comment

Item 10 DOE welcomes comment on how the four screening criteria might apply to any additional technology design option(s) that a stakeholder recommends to DOE. Screening Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 27 53 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

54



### Downstream Rulemaking Analyses

• 

### Life-Cycle Cost and Payback Period Analysis

• 

### Manufacturer Impact Analysis

• 

### National Impact Analysis 

## Purpose • The purpose of the engineering analysis and the product price determination is to determine the relationship between fluorescent lamp ballast efficiency and end-user price. Engineering Analysis



### Engineering Analysis Product Price Determination

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 28 55 

###  Choose product classes to be analyzed in the engineering and life-cycle cost analysis. 

###  Define characteristics of models in each representative product class which will serve as reference points to assess changes due to energy conservation standards. 

###  Identify more-efficient substitutes from a database of commercially-available ballasts. Maintain light output and have the same or better performance than the baseline system. 

###  Develop candidate standard levels that span the range of BEFs from the baseline to the maximum technologically feasible.


###  Scale analyses conducted on baseline ballasts to other ballasts and other product classes. Develop Candidate Standard Levels 

## Engineering Analysis Methodology Engineering Analysis

Scale Res ults Identify Efficient Substitutes Choose Rep resentative Product Classes Choose Representative Product
Define Baseline Models

56 Engineering Analysis 

## Choose Representative Product Classes • There are many potential product classes for which standards must beset. • DOE will choose a subset of product classes to analyze in the engineering analysis and life-cycle cost analysis. • These are called “representative product classes.” • Representative product classes are generally based on high volume product.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 29 57 Engineering Analysis 

## Define Baseline Models • Baseline models will be selected from each representative product cl ass. • Typically the baseline model just meets the current energy conservation standard. • For any baseline ballast where DOE is considering expanding coverage, DOE will select baseline models typical of the least-efficient ballast sold.

58 Engineering Analysis 

## Example Showing Potential for Scaling from

Baseline Ballasts 

# 28W

3- lamp 4-lamp

2-lamp 1-lamp 40W 34W 32W 30W

• Once baseline models and product classes are chosen and analyzed, DOE will scale the results to other fluorescent lamp ballasts. 

## 4-foot straight-shaped and 2-foot U-shaped Lamps

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 30 59 Engineering Analysis



### Item 11 DOE welcomes comment on representative product classes and selection of baseline models from those representative product classes. Item 14 DOE welcomes comment on how BEF varies with lamp wattage


## . Item 12 DOE welcomes comment on the scaling of findings from representative product classes to other product classes that DOE may not analyze.



## Request for Comment

60 Engineering Analysis 

## Identify More Efficient Substitutes • In identifying more-efficient substitutes, DOE will utilize a database of commercially-available ballasts. • Ballast system substitutions will be made so that either: (1) Light output is maintained from the baseline system’s light output. (2) Light output and fixture watts are normalized to the baseline system. 

### • Ballast system substitutions will be selected to have the same or better performance characteristics (e.g., THD).

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 31 61 Engineering Analysis 

## Develop Candidate Standard Levels • DOE is required to analyze maximum technologically feasible (“ max tech”) efficiency levels – In some cases, DOE defines the highest efficiency level based on maximum available efficiency currently on the market. – “Max available” may not correspond to “max tech” if some design options are not yet commercially available. – DOE will seek stakeholder comment to resolve this discrepancy.

62 

## Example of Draft Engineering Analysis for Discussion Engineering Analysis

64 64 64 6 8 Total Lamp W

49

53 54 6 3 Fixture Watts

0%

3,956 0. 88 1.600 T8 IS CSL3 0% 3,956 0.88 1.492 T8 IS CSL2 0% 3,956 0.88 1.443 T8 RS/PS CSL1 0% 3,956 0.86 1.365 T12 RS/PS Baseline % Diff Mean Lumen System Mean Lumen Output BF BEF Lamp Diam. Start Method Candidate Standard Level 64 64 64 Total Lamp W

0%

5 ,016 55 0 .88 1.600 T8 IS CSL3 0% 5,016 59 0.88 1.492 T8 IS CSL2 0% 5,016 61 0.88 1.443 T8 RS/PS Baseline/CSL1 % Diff Mean Lumen System Mean Lumen Output Fixture Watts BF BEF Lamp Diam. Start Method Candidate Standard Level



### 34W T12 Baseline 32W T8 Baseline

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 32 63 

### Item 13 DOE welcomes comment on commercially-available fluorescent lamp ballasts for each of the baseline models with incrementally increasing BEF, all the way to the max tech ballast. DOE welcomes comment on the proposed approach to the engineering analysis. Engineering Analysis



## Request for Comment

64 Engineering Analysis 

## Proprietary Designs • DOE will evaluate all design options that are commercially available or present in a working prototype, including proprietary designs and technologies. • Proprietary designs will only be considered if they do not present a unique path to a given efficiency level. • The confidentiality of manufacturers will be maintained.
Item 15 Are there proprietary designs of which DOE should be aware for any of the fluorescent lamp ballasts under consideration in this rulemaking? If so, how DOE should acquire the cost data necessary for evaluating these designs?

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 33 65 Engineering Analysis 

## Outside Regulatory Changes • DOE takes into consideration the effects on manufacturers of oth er regulatory changes outside of the standards rulemaking process.

Item 16 DOE welcomes comment on regulatory burdens or changes that should be considered in the engineering analysis of fluorescent lamp ballasts. Item 17 DOE welcomes comment on any other engineering issues that could impact the engineering analysis.

66

Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 34 67 Product Price Determination 

## Purpose • Provide an analysis of the relationship between the end-user price and efficiency for fluorescent lamp ballasts.



## Method • Product price determination for ballasts will be based on available pricing lists (e.g., manufacturer price lists, state procurement price lists) • DOE could develop high-range, medium-range, and low-range end-user retail prices. – Low-range prices could be developed to be consistent with prices found in State procurement contracts and other sources which have a single high-volume discount for all products. – Medium-range prices could be developed to be consistent with the typical discount provided by distributors for commercial institutions on high-volume ballasts, incorporating a contractor mark-up. – High-range prices could be developed for small quantity purchasers by observing Internet prices and obtaining distributor quotes. These prices could also incorporate a contractor mark-up.

68 Product Price Determination



### Item 19 DOE welcomes comment on final end-user prices for high-range, medium-range, and low-range fluorescent ballasts. Item 20 DOE welcomes comment on typical contractor and distributor markups associated with the purchase and installation of fluorescent lamp ballasts.



## Request for Comment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 35 69 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

70

Preliminary Manufacturer Impact Analysis 

## Legislative Requirements • The Manufacturer Impact Analysis (MIA) fulfills a legislative requirement to determine if a proposed standard is economically justified. – EPCA provides 7 factors to evaluate in determining whether an efficiency standard is justified. Two factors are addressed in the MIA: • Economic impact of standards on manufacturers • Impacts of any lessening of competition in the industry – MIA format changes described in the 2006 report to Congress, at: http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html 

### • DOE will collect, evaluate, and report preliminary MIA data in the ANOPR, if manufacturers can supply the requisite information. • Preliminary data include: anticipated conversion capital expenditures by efficiency level and anticipated direct employment impacts.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 36 71 

## Methodology • The MIA consists of three main phases. In the ANOPR, the preliminary MIA focuses on Phase 1

Industry profile Develop straw-man GRIM* Develop

interview guide Interviews

& industrywide / subgroup analyses Assess direct

employment, competition, cumulative burden Phase 2

* Government Regulatory Impact Model (GRIM) Phase 3

Preliminary MIA Interviews Phase 1 ANOPR NOP R Preliminary Manufacturer Impact Analysis

72 

## Purpose • Provide initial discussion on any potential impacts of energy co nservation standards on manufacturers of fluorescent lamp ballasts. • Provide an opportunity to verify DOE market information and engineering design options. Preliminary Manufacturer Impact Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 37 73 

## Methodology: Phase 1 • Consists of the industry profile and preliminary manufacturer im pact analysis interviews Industry Profile

» Evaluate current and past industry structure and market characteristics
» Produce an industry profile report with aggregated findings and characteristics
» Identify critical issues that require special consideration in the MIA, for example:
» Types or groups of manufacturers
» Access to technology
» Potential regulatory scenarios » Evaluate current and past industry structure and market characteristics
» Produce an industry profile report with aggregated findings and characteristics
» Identify critical issues that require special consideration in the MIA, for example:
» Types or groups of manufacturers
» Access to technology
» Potential regulatory scenarios 

### Preliminary MIA Interviews

» Occurs during the engineering a nalysis
» Topics include:
» Shipment projections
» Conversion costs
» Product mix and profitability
» Market shares and industry consolidation
» Cumulative regulatory burden » Occurs during the engineering analysis
» Topics include:
» Shipment projections
» Conversion costs
» Product mix and profitability
» Market shares and industry consolidation
» Cumulative regulatory burden Preliminary Manufacturer Impact Analysis

74 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 38 75 

## Purpose • Develop annual energy use data for the life-cycle cost and payback pe riod analyses to calculate annual operating costs. 

## Method • Obtain data to develop a distribution of operating hours for fluorescent la mps by sector and census division. Data sources include: – 2002 U.S. Lighting Market Characterization: Volume I report – EIA’s 2003 Commercial Building Energy Survey – EIA’s 2002 Manufacturer Energy Consumption Survey 

### • Correlate electricity price distribution and sales tax distribution with the operating hour distribution by census division. • Multiply system power by the number of operating hours per year. • Conduct sensitivity analysis for estimates of high and low operating hours. Energy Use and End-Use Load Characterization

76 

## Inputs to Energy Use Calculation • System Input Power: Manufacturer information verified by catalogs. • Operating Hours : Example of commercial sector distribution for fluorescent lamp ballasts is given below.



### Fluorescent Lamp Ballast Annual Operating HoursProbability

0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%1,7052,5702,6433,3313,3943,4603,5453,5703,6383,6813,6863,7803,8194,3854,5984,9735,2245,751 Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 39 77 

### Item 18 DOE welcomes comment on the use of the planned operating hour profile for fluorescent lamp ballasts in this rule.Furthermore, DOE welcomes comment on whether the enduse operating profiles are different for the various types of fluorescent lamp ballasts covered under this rulemaking, and if so, how. 

## Request for Comment Energy Use and End-Use Load Characterization

78 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 40 79 

## Purpose • Assess the payback period (PBP) and the net life-cycle cost (LCC) im pacts on the consumer of fluorescent lamp ballast efficiency standards. 

## Method • LCC equals consumer price plus the sum of annual operating costs di scounted to a particular base year • Economic evaluation from the consumer perspective • Analysis implemented in an Excel ® 

### spreadsheet • Results expressed as LCC difference (baseline minus standard level) • Simple Payback (years) is also calculated and reported
Consumer Life Cycle Cost (Baseline and Standard) 

### LCC impacts (difference between baseline and standard) 

### Operating Cost (Sum & discount to present value) 

### First Cost (Consumer Price & Installation) Life-Cycle Cost and Payback Period Analysis

80 

## Approach

Life-Cycle Cost and Payback Period Analysis


### • Monte Carlo simulation analysis to be used. – C haracterize the variability and uncertainty associated with the inputs using probability distributions. – Probability distributions will be used to characterize the uncertainty in operating cost inputs (e.g., discount rates, operating hours). – Correlate inputs where necessary (e.g., electricity price, sector).

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 41 81 Sales Tax Total Installed Cost End-User Direct Price

System Power Operating Hours Electricity Price 2014

Annual Electricity Cost Annual Energy Consumption Operating Cost Lifetime

Operating Cost Payback Period Life-Cycle Cost

Discount Rate Electricity Price Trend Input Value Output

Lamp Price Lamp Lifetime Maintenance and Repair Costs Analysis Period Ballast Lifetime

Lamp Installation Costs Ballast Installation Costs Life-Cycle Cost and Payback Period Analysis

82 

## Annual Energy Costs • DOE will develop electricity prices from DOE-Energy Information Ad ministration (EIA) Form 861 data. • DOE will use projections of national average energy prices for residential, commercial, and industrial consumers from EIA’s Annual Energy Outlook (AEO) as input for future energy prices. • DOE may conduct a sensitivity analysis using high and low electricity prices to determine the impact on economic feasibility.

Item 21 DOE welcomes input on the electricity prices used in this analysis. Life-Cycle Cost and Payback Period Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 42 83 

## Installation, Maintenance and Repair Costs • Installation costs: May not change with more energy-efficient fluorescent lamp ballast designs as new regulations may not change either the ballast lifetime or the labor costs for installing a standards-compliant ballast. • Maintenance costs: Could change with more energy-efficient ballast designs: – If a standard level results in a shift from T12 to T8 ballasts, the equipment cost of the replacement T12 and T8 lamp may be different. – Labor costs of installing a fluorescent lamp will not change with more efficient ballasts as more energy-efficient ballasts would not significantly impact the useful lifetime (i.e., shorter or longer) of the lamps operated by those ballasts. 

### • Repair costs: May not be a part of the LCC analysis because fluorescent lamp ballasts are not “repaired” as ballasts are generally replaced at the end of their useful life. Life-Cycle Cost and Payback Period Analysis

84 

## Request for Comment
Item 23 DOE welcomes comment on how to develop installation, maintenance, and (if applicable) repair costs for fluorescent lamp ballasts. In particular, will fluorescent lamp ballast energy conservation standards affect the useful lifetime of the ballasts and/or the fluorescent lamps operated by those ballasts? If the lamps operated by the more efficient ballasts would be impacted, then DOE invites stakeholder comment on whether re-lamping practices (i.e., group re-lamping and spot re-lamping) would change as a result of the standard. Item 24 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for the ballasts covered in this rulemaking. Life-Cycle Cost and Payback Period Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 43 85 

## Discount Rate • Discount rates are used to convert streams of annual operating expenses to present value in the LCC analysis. • DOE will derive a distribution of discount rates for the commercial and industrial sectors. – These distributions will be developed by estimating the weighted average cost of capital (or WACC) for commercial and industrial consumers of ballasts. 

### – WACC includes: • Financial cost of any debt incurred to purchase products. • Opportunity cost of any equity to purchase products. 

### Item 22 DOE welcomes input on the planned approaches for estimating discount rates for consumers of fluorescent lamp ballasts covered under this rulemaking. Life-Cycle Cost and Payback Period Analysis

86 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 44 87 

### Purpose • Quantify changes in product shipments due to potential new or amended energy efficiency standards. Method • The shipments model will rely on a range of data sources. • The model will only consider shipments of covered products. • Two Possible Approaches: – Shipment projections based on historical data. – Shipment projections based on modeling the installed base of fluorescent lamp ballasts nationally. Shipments Analysis



### DOE welcomes input on these two approaches or others for estimating fluorescent lamp ballasts shipments.

88 Shipments Analysis 

## Base-Case Shipments Forecast Approach • Depicts the situation where new or amended standards are not ad opted. • Depicts the current mix of ballast efficiencies sold in the absence of new regulation. • Shipments forecast by market segment: (1) new construction sales; (2) replacements for failed units; and (3) retrofits. • Data requirements: – Historical shipments – Breakdown of shipments by market segment (e.g., new construction, replacements, and retrofits), end-use sector, and product class

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 45 89 

## Request for Comment Item 25 DOE welcomes recommendations on the sources of data that would provide information on shipments of fluorescent lamp ballasts by product class and BEF distributions within those product classes. In addition, DOE welcomes comment or recommendations on how it might characterize long-term trends in efficiency of fluorescent lamp ballasts for the base-case shipments forecast. Item 26 DOE welcomes comment on the accounting methodology for each of the fluorescent lamp ballasts covered in this rulemaking. Shipments Analysis



### DOE welcomes comment on the breakdown of fluorescent lamp ballast shipments by market segment and sector.

90 Shipments Analysis 

## Standards Impacts on Ballast Shipments • DOE develops Standards-Case Forecasts from the same data it wi ll use to develop the Base-Case Forecast. • Standards-Case Forecasts may also use purchase price increases and operating cost savings to estimate shipments impacts. • DOE will also consider impacts from market-pull programs. • Impacts on the total amount of light produced by these ballasts in the commercial and industrial sector may also be considered. Item 27 DOE welcomes comment on how any new energy conservation standard for fluorescent lamp ballasts might impact shipments of these ballasts. DOE also invites information about market-pull programs that promote the adoption of more-efficacious ballasts.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 46 91 Framework Document ANOPR NOPR Final Rule Effective

Date

Market & Technology Screening Analysis Engineering

Analysis

Shipments Analysis National Impact Analysis Product Price Determination Life-Cycle Cost and Payback Period Analysis 

## Steps in the Standards Rulemaking: ANOPR

Preliminary Manufacturer Impact Analysis Energy Conservation Standards

Energy Use and End-Use Load Characterization

92 

## Purpose • Determine the projected national energy savings and consumer national net present value. 

## Method • Utilize the shipments model to estimate the total stock of fluorescent la mp ballasts in service each year. • Estimate cost and energy use per unit from LCC. • Aggregate the costs and energy use over the analysis period. • Report national energy savings (NES) in Quads of primary energy consumption. • Energy savings will take into account HVAC interactions and the rebound effect. • Report estimates for economic impact as change in consumer National Net Present Value (NPV) (in constant year dollars). • Account for the time-value of money though defined discount rates. National Impact Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 47 93 Base Case Annual Energy Consumption 2043 Base Case Annual Energy Consumption 2016 Base Case Annual Energy Consumption 2015 Base Case Annual Energy Consumption 2014 

## National Energy Savings Flow Diagram National Impact Analysis

Shipments Analysis StandardsCase Projection Base-Case Projection
Base Case Annual Energy Consumption 2043 Base Case Annual Energy Consumption 2016 Base Case Annual Energy Consumption 2015 Standards Case Annual Energy Consumption 2014

Base-Case Cumulative Energy Use Standards-Case Cumulative Energy Use Site to Source Energy Conversion National Energy Savings

94 

## National Consumer Net Present Value Flow Diagram National Impact Analysis

Shipments Analysis StandardsCase Projection Energy Cost (2014 – 2043) Base-Case Projection

Cumulative Operating Cost Savings Cumulative Total Equipment Cost Increase Discount Rate

Net Present Value Maint & Install Cost (2014 – 2043) Product

Cost (2014 – 2043) Energy Cost (2014 – 2043) Maint &

Install Cost (2014 – 2043) Product

Cost (2014 – 2043)

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 48 95 

### Item 28 DOE welcomes comment on the data sources it anticipates using to develop inputs for the national impact analysis. Item 29 DOE welcomes comment on the NES spreadsheet models it proposes to use for estimating national impacts of energy conservation standards for fluorescent lamp ballasts. National Impact Analysis 

## Request for Comment

96 

### 2 3 NOPR Analyses 1

ANOPR Analyses 4 Rulemaking Overview Introduction 2 Energy Conservation Standards Test Procedure 3 Introduction

NOPR Analyses 5 ANOPR Analyses 4

6 Closing Remarks 

## Public Meeting Agenda

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 49 97 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

98 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 50 99 

## Purpose • Analyze the economic impacts of standards on consumers, in cluding subgroups who may be disproportionately impacted compared with the general user population.



## Method • Extend the LCC analysis to examine the impacts for defined su bgroups. Life-Cycle Cost Subgroup Analysis



### Item 30 The Department welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fluorescent lamps ballasts.

100

Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 51 101 Manufacturer Impact Analysis 

## Legislative Requirements • The Manufacturer Impact Analysis (MIA) fulfills a legislative requirement to determine if a proposed standard is economically justified. – EPCA provides 7 factors to evaluate in determining whether an efficiency standard is justified. Two factors are addressed in the MIA: • Economic impact of standards on manufacturers • Impacts of any lessening of competition in the industry – MIA format changes described in the 2006 report to Congress, at: http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html 

### • DOE will collect, evaluate, and report preliminary MIA data in the ANOPR • Preliminary data includes: anticipated conversion capital expenditures by efficiency level and anticipated direct employment impacts

102 Manufacturer Impact Analysis 

## Purpose • Assess the impacts of standards on manufacturers. • Id entify and estimate impacts on manufacturer subgroups that may be more severely impacted than the industry as a whole. • Examine the impact of cumulative regulatory burden on the industry. 

## Method • Analyze industry cash flow and net present value through use of theGovernment Regulatory Impact Model (GRIM). • Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, and address qualitative issues.



## Output • Industry Net Present Value impacts • S ubgroup Net Present Value impacts • Other impacts

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 52 103 Manufacturer Impact Analysis 

## Methodology • In the NOPR phase, the MIA will consist of phases 2 and 3

Industry profile Develop straw-man GRIM* Develop

interview guide Interviews

& industrywide / subgroup analyses Assess direct

employment, competition, cumulative burden Phase 2

* Government Regulatory Impact Model (GRIM) Phase 3

Preliminary MIA Interviews Phase 1 ANOPR NOP R

104 Manufacturer Impact Analysis 

## Methodology: Phase 2 • Consists of the strawman GRIM and interview guide preparation

Strawman GRIM

» Starting point for discussion of i mpacts
» Inputs include:
» Manufacturer prices
» Shipment forecasts
» Manufacturing cost estimates
» Financial information » Starting point for discussion of impacts
» Inputs include:
» Manufacturer prices
» Shipment forecasts
» Manufacturing cost estimates
» Financial information 

### Interview Guide Preparation

» Interview topics include:
» Engineering analysis
» S hipments model
» Cost structure and financial parameters
» Conversion costs
» Cumulative burden
» Direct employment impacts
» Import / Export issues
» Consolidation / competitive impacts
» Replacement parts or refurbishments
» Impact of the standard’s effective date » Interview topics include:
» Engineering analysis
» S hipments model
» Cost structure and financial parameters
» Conversion costs
» Cumulative burden
» Direct employment impacts
» Import / Export issues
» Consolidation / competitive impacts
» Replacement parts or refurbishments
» Impact of the standard’s effective date

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 53 105 Manufacturer Impact Analysis 

## Methodology: Phase 3 • Consists of the manufacturer interviews, subgroup analyses, and assessment of industry impacts
Manufacturer Interviews

» Confidential discussion of potential i mpacts resulting from standards, including:
» Obsolescence of existing manufacturing assets
» Tooling
» Investment » Confidential discussion of potential impacts resulting from standards, including:
» Obsolescence of existing manufacturing assets
» Tooling
» Investment 

### Assessment of Impacts

» Assess competitive impacts on s maller, significant manufacturers
» Assess cumulative regulatory burden on manufacturers from amended DOE standards and other regulatory actions
» Assess impacts on industry employment levels
» Assess impacts on manufacturer subgroups » Assess competitive impacts on smaller, significant manufacturers
» Assess cumulative regulatory burden on manufacturers from amended DOE standards and other regulatory actions
» Assess impacts on industry employment levels
» Assess impacts on manufacturer subgroups

106 Manufacturer Impact Analysis 

## Cumulative Regulatory Burden • Regulations that could affect the industries impacted by this ru lemaking include: – DOE energy conservation standards for fluorescent lamp ballasts enacted on September 19, 2000 (65 FR 56740) and by EPACT 2005; – New EPCA standards, prescribed in EPACT 2005, for medium-base compact fluorescent lamps, and mercury vapor lamp ballasts; – New EPCA standards for incandescent lamps and metal halide lamp fixtures prescribed in EISA 2007; – Existing and/or proposed State standards for high intensity discharge ballasts, and/or under-cabinet luminaires; – State building energy codes lighting requirements (e.g. American Society of Heating, Refrigerating, and Air-Conditioning Engineers Standard 90.1); and – International standards, including Canada’s regulation on fluorescent lamp ballasts.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 54 107 Manufacturer Impact Analysis



### Item 31 If appropriate, what are potential subgroups of fluorescent lamp ballast manufacturers that DOE should consider in a manufacturer subgroup analysis? Item 32 DOE welcomes comment on what other regulations or pending regulations it should consider in its examination of cumulative regulatory burden.



## Request for Comment

108 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 55 109 

## Purpose • Assess the overall impacts on domestic energy supplies that wo uld result from the imposition of standards. Utility Impact Analysis



### • The Department proposes to use NEMS-BT, a variant of the NE MS (National Energy Modeling System) developed and used by DOE/EIA for their Annual Energy Outlook report, as the basis of the Utility Impact Analysis. • Outputs of the utility impact analysis include forecasts of electricity generation, sales, price, and avoided capacity resulting from a comparison of base and standards cases. • DOE will model the energy savings impacts from amended energy conservation standards using NEMS-BT to generate forecasts that deviate from the AEO reference case.



## Method

110 

## Request for Comment
Item 33 The Department welcomes input from stakeholders on its plans to use NEMS-BT to conduct the utility impact analysis. Utility Impact Analysis

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 56 111 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

112 

## Purpose • Assess the overall impact on national employment from the imposition of efficiency standards at differing levels. • Include both direct and indirect employment impacts. – Direct employment impacts are estimated in the manufacturer impact analysis. – Indirect employment impacts result from shifting consumer expenditures among goods and services ( “substitution effect”) and changing equipment and energy costs (“income effect”).



## Method • DOE intends to use the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts. (Note: ImSET is an update of IMBUILD.) Employment Impact Analyses



### Item 34 The Department welcomes feedback on its planned approach to assessing national employment impacts, both direct and indirect.

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 57 113 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

114 

## Purpose • Estimate national environmental impacts from new energy efficiency sta ndards for fluorescent lamp ballasts. 

## Method • DOE intends to use the environmental impacts predicted from the NE MS-BT modeling analysis used for the Utility Impacts Analysis. – Carbon dioxide (CO 2 

### ) will be the primary emissions reported. – Existing legislation caps SO 2 

### , NO x

### , and mercury emissons, so physical emission reductions will be zero or nearly zero from any single energy conservation standard. Environmental Assessment

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 58 115 

### Item 35 DOE welcomes feedback on its planned approach to assessing national environmental impacts, including other factors or approaches that should be considered.



## Request for CommentEnvironmental Assessment

116 Framework Document ANOPR NOPR Final Rule Effective

Date 

## Steps in the Standards Rulemaking: NOPR

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Life-Cycle Cost Subgroup Analysis Revise ANOPR Analyses Environmental Assessment Regulatory

Impact Analysis

Engineering Analysis Life-Cycle

Cost & Payback Period Analyses National

Impact Analysis Energy Conservation Standards

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 59 117 

## Purpose • Explore the potential for non-regulatory alternatives to new ma nufacturing efficiency standards. Regulatory Impact Analysis



## Method • Base the assessment on the actual impacts of any such initiatives to d ate, but will consider information presented regarding the impacts that any existing initiative might have in the future.

118



### 2 3 NOPR Analyses 1

ANOPR Analyses 4 Rulemaking Overview Introduction 2 Energy Conservation Standards Test Procedure 3 Introduction

Final Rule 5 ANOPR Analyses 4

6 Closing Remarks NOPR Analyses 5 

## Public Meeting Agenda

### Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008



## 60 119 Closing Remarks 

## How to Submit Written Comments In all correspondence, please refer to the Fluorescent Lamp Ballast ru lemaking by: – Fluorescent Lamp Ballast Rulemaking, – Docket Number EERE–2007–BT–STD–0016, and – Regulatory Identification Number (RIN) 1904-AB50 

### Email : Ballasts.Rulemaking@ee.doe.gov

Comment period closes: March 7, 2008 Mrs. Brenda Edwards U. S. Department of Energy Building Technologies Program, 6th Floor 950 L’Enfant Plaza, SW Washington, DC 20024 Tel: 202 586 2945 Mrs. Brenda Edwards U.S. Department of EnergyBuilding Technologies Program, Mailstop EE2J 1000 Independence Avenue, SW Washington, DC 20585-0121 

### Courier : Postal :