CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION

........................................................................................................... 3-1
3.1.1 Definitions

............................................................................................................ 3-1
3.1.2 Ballast Efficacy Factor

......................................................................................... 3-1
3.1.3 Fluorescent Lamp

................................................................................................. 3-2
3.1.4 Fluorescent Lamp Ballast

.................................................................................... 3-2
3.1.5 Replacement Ballast

............................................................................................. 3-4
3.2 MARKET ASSESSMENT

.............................................................................................. 3-4
3.2.1 Trade Associations

............................................................................................... 3-4
3.2.2 Manufacturers and Ma rket Share

......................................................................... 3-5
3.2.2.1 Small Businesses

...................................................................................... 3-5
3.2.3 Regulatory Programs

........................................................................................... 3-2
3.2.3.1 Federal Energy Conservation Standards

.................................................. 3-2
3.2.3.2 California Energy Commission

................................................................ 3-5
3.2.3.3 Canadian Energy Effici ency Standards

................................................... 3-5
3.2.3.4 European Energy Effici ency Standards

................................................... 3-7
3.2.4 Non-Regulatory Initiatives

................................................................................... 3-7
3.2.4.1 Federal Energy Management Program

.................................................... 3-7
3.2.4.2 Consortium for Energy Efficiency

........................................................... 3-8
3.2.4.3 NEMA Premium

...................................................................................... 3-9
3.2.4.4 ENERGY STAR

...................................................................................... 3-9
3.2.4.5 Energy Efficient Commercia l Building Deduction

.................................. 3-9
3.2.4.6 Northeast Energy Efficiency Partnerships

............................................. 3-10
3.2.5 Historical Shipments

.......................................................................................... 3-10
3.3 TECHNOLOGY ASSESSMENT

.................................................................................. 3-16
3.3.1 Basic Structure of Fluorescent Lamps

............................................................... 3-16
3.3.2 Electrical Characteristics of a Fl uorescent Discharge Lamp

............................. 3-17
3.3.3 Fluorescent Lamp Ballast Overview

.................................................................. 3-18
3.3.3.1 Starting Method

..................................................................................... 3-19
3.3.3.2 Ballast Factor

......................................................................................... 3-20
3.3.3.3 Ballast Efficacy Factor

........................................................................... 3-20
3.3.3.4 Power Factor

.......................................................................................... 3-20
3.3.3.5 Total Harmonic Distortion

..................................................................... 3-21
3.3.3.6 Electromagnetic In terferen ce

................................................................. 3-21
3.3.3.7 Safety

..................................................................................................... 3-22
3.3.4 Fluorescent Lamp Ballast Technology Options

................................................. 3-22
3.3.4.1 Magnetic Ballasts

................................................................................... 3-22
3.3.4.2 Electronic Ballasts

................................................................................. 3-23
3.3.4.3 Lamp Diameter

...................................................................................... 3-27
3.3.4.4 Improved Components

........................................................................... 3-27
3.3.4.5 Improved Circuit Design

........................................................................ 3-29
3.4 PRODUCT CLASSES

................................................................................................... 3-30

3-i3.4.1 Lamp Length

...................................................................................................... 3-31
3.4.2 Lamp Diameter

.................................................................................................. 3-31
3.4.3 Ballast Factor

..................................................................................................... 3-32
3.4.4 Lumen Package

.................................................................................................. 3-32
3.4.5 Maximum Number of Lamps Operated

............................................................. 3-33
3.4.6 Starting Method

................................................................................................. 3-33
3.4.7 Input Voltage

..................................................................................................... 3-33
3.4.8 Universal Voltage

.............................................................................................. 3-34
3.4.9 Residential Ballasts

............................................................................................ 3-34
3.4.10 Sign Ballasts

....................................................................................................... 3-34
3.4.11 Product Classes

.................................................................................................. 3-35
REFERENCES

..................................................................................................................... ..... 3-36

LIST OF TABLES

Table 3.2.1 EPCA Standards for Fl uorescent Lamp Ballasts

...................................................... 3-2

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and Lamps

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimli ne T12 Ballasts and

Table 3.3.2 Basic Building Blocks of a Fixed- Light Output Fluorescent Lamp Ballast and

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp Ballasts

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp Ballasts3­ Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

.................................... 3-3
Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts

........................................... 3-4
Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts

................................................. 3-6 Table 3.2.5 Federal Energy Management Pr ogram Efficiency Recommendation

...................... 3-8 Table 3.2.6 CEE High-Performance T8 Ballast Specifications

................................................... 3-8 Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications

.................................................... 3-9

and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps

................................... 3-13

Lamps

.......................................................................................................................... ............... 3-14 Table 3.2.10 T12 High-Output Ballast Market Share

................................................................ 3-15
Table 3.3.1 Common Linear Fluoresce nt Lamp Nomenclature

................................................ 3-17

Associated Characteristics

..................................................................................................... .... 3-25

............................................................................................................................... ..................... 3-30

30 Table 3.4.3 Preliminary Produc t Classes for Fluorescent Lamp Ballasts

.................................. 3-35

LIST OF FIGURES

Figure 3.2.1 2005 Ballast Market Share

.................................................................................... 3-11 Figure 3.2.2 Magnetic and Electroni c Ballast Market Share

..................................................... 3-12 Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps

................................. 3-13

3-iiFigure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP S limline T12 Ballasts . 3-14 Figure 3.2.5 Shipments of Re sidential Ballasts

......................................................................... 3-15 Figure 3.2.6 Shipments of T5 High-Output Ballasts

................................................................. 3-16 Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp

............................................... 3-18 Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast

................................... 3-23 Figure 3.3.3 Fluorescent Lamp Efficacy vs . Operating Frequency of Lamp

............................ 3-24 Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

............................................. 3-24 Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram

..................... 3-25

3-iiiCHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter details the market and technolog y assessment that the U.S. Department of Energy (DOE) has conducted in support of the on going energy conservatio n standards and test procedure rulemakings for fluorescent lamp ba llasts. These rulemakings are mandated by the Energy Policy and Conservation Act (EPCA), as amended, and are effective for ballasts manufactured during and after 2014.

This chapter consists of three sections: the market assessment, the technology assessment, and product classes. The market a ssessment provides an overall picture of the market for the products concerned, including the na ture of the products, industry structure, and manufacturer market shares; regulatory and non- regulatory efficiency improvement programs; and market trends and quantitie s of products sold. The tec hnology assessment identifies a preliminary list of technologies to consider in the screening analysis. The product classes section discusses the product classes DOE considered us ing for this rulemaking and how they were developed.

The information DOE gathers from the mark et and technology assessment serves as resource material for use throughout the ru lemaking. DOE considers both quantitative and qualitative information from publicly availa ble sources and interested parties.

3.1.1 Definitions

Section 321 of EPCA contains definitions for fluorescent lamp ballast and associated
terms. DOE codified in the Code of Federal Regulations (CFR) the statutory definitions and definitions of supplementary terms for fluor escent lamp ballasts in 10 CFR 430.2. Appendix 3A
lists these terms and their definitions.

As part of this energy conservation standa rds rulemaking, DOE is considering extending coverage to additional fluores cent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following
sections describe in more deta il the definitions in EPCA for fluorescent lamp ballasts and note DOE’s interpretation of the definitions. Please se e chapter 2 of this preliminary technical support document (TSD) for more discussion on DOE’s c onsideration of additional fluorescent lamp ballasts and its interpretati on of EPCA’s definitions.

3.1.2 Ballast Efficacy Factor

Section 321(30)(A) of EPCA (42 U.S.C. 6291( 30)(A)) defines ballast efficacy factor (BEF) as:

Ballast efficacy factor means the relative light output divided by the power input of a fluorescent lamp ballast, as measured under test conditions specified in ANSI Standard

C82.2–1984.

3-1DOE is conducting concurrent rulemakings fo r an active mode test procedure and a standby mode test procedure for fluorescent lamp ballasts. Information on these rulemakings can
be found on DOE’s website. a The test procedures specify how manufacturers measure and calculate ballast efficacy factor.

3.1.3 Fluorescent Lamp

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines a fluorescent lamp:

Fluorescent lamp means a low pressure mercury electric-discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, including only the following:

(1) any straight-shaped lamp (commonly referre d to as 4-foot medium bipin lamps) with medium bipin bases of nominal overa ll length of 48 inches and rated wattage of 25 or more; (2) any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium bipin bases of nomin al overall length between 22 and 25 inches and rated wattage of 25 or more; (3) any rapid start lamp (commonly referred to as 8-foot high output lamps) with recessed double contact (RDC) bases of no minal overall length of 96 inches; (4) any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; (5) any straight-shaped lamp (commonly referred to as 4-foot miniature bipin standard output lamps) with miniature bipin bases of nomin al overall length
between 45 and 48 inches and rate d wattage of 26 or more; and (6) any straight-shaped lamp (commonly re ferred to 4-foot miniature bipin high output lamps) with miniature bipin base s of nominal overall length between 45
and 48 inches and rated wattage of 49 or more.

This definition, codified at 10 CFR 430.2, reflects the version adopted in the final rule for general service fluorescent lamps (the 2009 Lamps Rule). b 74 FR 34080, 34176-77 (July 14, 2009).

3.1.4 Fluorescent Lamp Ballast

Fluorescent lamp ballast means a device that is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation.

a DOE’s website for fluorescent lamp ballasts can be found at http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

. b The 2009 Lamps Rule was published in the Federal Register on July 14, 2009 and is available at http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html

3-2As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is considering extending coverage to additional fluorescent lamp ballasts. In chapter 2 of the preliminary TSD, DOE considers extending energy conservation st andards coverage to the following list of fluorescent lamp ballasts:

(1) ballasts that operate one, two, three, fo ur, five, or six straight-shaped lamps (commonly referred to as 4-foot medium bi pin lamps) with medium bipin bases, a nominal overall length of 48 inches, a rated wattage c of 25 watts (W) or more, and an input voltage at or between 120 volts (V) and 277V; (2) ballasts that operate one, two, three, four, five, or six U-shaped lamps (commonly referred to as 2-foot U-shaped lamps) w ith medium bipin bases, a nominal overall length between 22 and 25 inches, a rated wattage of 25W or more, and an input voltage at or between 120V and 277V; (3) ballasts that operate one or two rapid start lamps (commonly referred to as 8-foot high output lamps) with recessed double c ontact bases, a nominal overall length of 96 inches and an input voltage at or between 120V and 277V; (4) ballasts that operate one or two instant start lamps (commonly referred to as 8­ foot slimline lamps) with single pin bases, a nominal overall length of 96 inches, a rated wattage of 52W or more, and an input voltage at or between 120V and 277V; (5) ballasts that operate one or two straight-shaped lamps (commonly referred to as 4­ foot miniature bipin standard output lamps) with miniatu re bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 26W or more, and an input voltage at or between 120V and 277V; (6) ballasts that operate one, two, three, or four straight-shaped lamps (4-foot miniature bipin high output lamps) with miniature bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 49W or more, and an input voltage at or between 120V and 277V; (7) ballasts that operate one, two, three, or four straight-sha ped lamps (commonly referred to as 4-foot medium bipin lamp s) with medium bipin bases, a nominal overall length of 48 inches, a rated wattage of 25W or more , an input voltage at or between 120V and 277V, a power factor (PF) of less than 0.90, and that are designed and labeled for use in residential applications; and (8) ballasts that operate one, two, three, four , five, or six rapid start lamps (commonly referred to as 8-foot high output lamp s) with recessed double contact bases, a nominal overall length of 96 inches, an input voltage at or between 120V and 277V, and that operate at ambient temperat ures of 20 °F or less and are used in outdoor signs.

DOE is considering exempting the following ballasts:

(1) ballasts designed for dimming to 50 percen t or less of the maximum output of the
ballasts.

c The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.

3-33.1.5 Replacement Ballast

Replacement ballast means a ballast that

(1) is designed for use to replace an existing fluorescent lamp ballast in a previously installed luminaire; (2) is marked “FOR REPLACEMENT USE ONLY”; (3) is shipped by the manufacturer in packages containing not more than 10 fluorescent lamp ballasts; and (4) has output leads that when fully extended are a total length that is less than the length of the lamp with which the ballast is intende d to be operated.

3.2 MARKET ASSESSMENT

The following market assessment identifies the manufacturer trade association and
domestic manufacturers of fluores cent lamp ballasts; discusse s manufacturer market share, regulatory programs, and non-regulatory initiatives ; defines product classes; provides historical shipment data, shipment projections, and equipment lifetime estimates; and summarizes market performance data.

3.2.1 Trade Associations

The National Electrical Manufacturers Association (NEMA) is the trade association for fluorescent lamp ballasts. NEMA’s Lighting Syst ems Division is one of eight product divisions. The division’s 47 member companies comprise 85-95 percent of the U.S. commercial and industrial market, as well as large portions of the institutional a nd educational markets. 1 In addition to ballasts, NEMA’s Lighting System s Division also oversees products such as fluorescent lamps, emergency lighting, lighting controls, luminaires, solid state lighting, and other emerging lighting technologies. NEMA provides an organization through which manufacturers of lighting equipment can work together on projects that affect their industry and business. NEMA’s activities relating to energy efficiency include 2

• “[a]dvising the DOE and executive agencies on lighting research and market transformation needs;

• engaging in legislative work on energy and lighting issues;

• monitoring energy-efficiency rulemakings a nd standards affecting lighting products by federal and state agencies;

• promoting the national voluntary luminaire rating and information program under the National Lighting Collaborative;

• supporting adoption of 1999 ASHRAE/IESNA 90.1 lighting provisions;

• working with market transfor mation and environmental groups to advance market use of energy-efficient lighting technologies;

3-4• advising DOE and the U.S. Environmenta l Protection Agency (EPA) on ENERGY STAR Buildings and ENERGY STAR voluntar y product labeling programs; and

• advocating market-based approaches to e nhance the use and penetration of energyefficient technologies.”

3.2.2 Manufacturers and Market Share

The following list contains the names of manuf acturers that produce fluorescent lamp ballasts:

•

•

• Acuity Brands Lighting
Advance Transformer
American Ballast •

• General Electric

Consumer &
Industrial
Hatch Transformer •

•

•

• PQL
Prescolite Progress Lighting
Radionic

•

•

•

•

•

•

•

•

•

• Antron Compact
Electronics Axis Technologies
Ballast Wise
Bodine

CEW Cooper Lighting
EBW Electronics Espen Technology,

Inc.
Etlin-Daniels
Fulham •

•

•

•

•

•

•

•

•

• Holophane
Howard Industries Iota Engineering Keystone Technologies Lamar Lighting
SOLA Ballasts Lighting Components Lightolier
Lutron Electronics Company, Inc.
MaxLite •

•

•

•

•

•

•

•

• Robertson Worldwide Sage Lighting Ltd. SLI Lighting Sunpark Electronics Corp. Superior Lamps, Inc.

TCP Ultrasave Lighting
Ltd. Universal Lighting Technologies

Ventex

• France •

• OSRAM Sylvania Pacific Lighting and
Electric •

• Venture Lighting
International
Wide-Lite

Four manufacturers hold the majority of the domes tic market share of fluorescent lamp ballasts

• GE Consumer and Industrial of Genera l Electric, Inc. (hereafter, “GE”)

• OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”)

• Advance Transformer of Philips Lighting (hereafter “Advance”)

• Universal Lighting Technologies (hereafter “Universal”).

The lighting divisions of some of these co mpanies also manufacture other products, such as fluorescent lamps, high intensity discharge lamps, light emitting diodes (LEDs), and compact fluorescent lamps (CFLs).

3.2.2.1 Small Businesses

Small businesses may be particularly affect ed by the promulgation of minimum energy conservation standards for fluorescent lamp ba llasts. The Small Business Administration (SBA)
lists small business size standards that are matc hed to industries as they are described in the North American Industry Classification System (NAI CS). A size standard is the largest that a

3-5for-profit concern can be and still qualify as a small business for Federal Government programs. These size standards are generally the average annual receipts or the average employment of a firm. For fluorescent lamp ballasts, the si ze standard is matc hed to NAICS code 335311, Power, Distribution, & Specialty Transformer Manufacturing , which has a size standard of 750 employees or fewer. 3

DOE will study the potential impacts on these small businesses in detail during the manufacturer impact analysis, which it will conduct as part of the notice of proposed rulemaking.

3.2.3 Regulatory Programs

Several Federal and international regulatory programs affect the markets for fluorescent lamp ballasts. The following section summarize s U.S., Canadian, and European regulatory initiatives relevant to the ballasts covered by this rulemaking. While the following discussion is not exhaustive in describing all regulatory acti on related to fluorescent la mp ballasts, it provides
detail on some notable initiatives that characterize recent developments in the lighting market.

3.2.3.1 Federal Energy Conservation Standards

EPCA (42 U.S.C. 6291–6309) established an energy conservation program for major household appliances. Additional amendments to EP CA gave DOE the authority to regulate the energy efficiency of several products, including certain fluorescent lamp ballasts. Amendments to EPCA in the National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Pub. L.100357, established energy conservation standards for fluorescent lamp ballasts. d (42

U.S.C. 6295(g)(5)) The standards promulgated by NAECA 1988 can be found in Table 3.2.1. These amendments also required that DOE (1) conduct two rulemaking cycles to determine whether these standards should be amended; a nd (2) for each rulemaking cycle, determine
whether the standards in effect for fluorescent lamp ballasts s hould be amended so that they would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B))

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts

d Although fluorescent lamp ballasts are typically understood to be used in the commercial and industrial sectors, it is the “consumer products” section of the statute that gran ts 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,” two parts cluster the group of products DOE regulates. “Part A – Energy Conservation Program for Consumer Products Other than Automobiles” 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 consum er 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 A1– 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.

3-2Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F40T12 Lamp 120 40 1.805

277 40 1.805

Two F40T12 Lamps 120 80 1.060

277 80 1.050

Two F96T12 Lamps 120 150 0.570

277 150 0.570 Two F96 T12 High Output 120 220 0.390 (HO) Lamps 277 220 0.390

On September 19, 2000, DOE published a final rule in the Federal Register that 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 a dvocacy organizations. The standard levels DOE adopted replaced the ballast efficacy factors promulgated in NAECA 1988 for certain fluorescent lamp ballasts. The standard levels were intended to eliminate certain magnetic ballasts, which operate lamps at a line frequency of 60 Hertz (Hz), and are less e fficient than electronic ballasts, which operate lamps at high frequency for ballasts that operate F40T12 and F96T12 lamps. e Table 3.2.2 shows the standards codified by DOE. 10 CFR 430.32(m)(3)

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F40T12 Lamp 120 40 2.29

277 40 2.29

Two F40T12 Lamps 120 80 1.17

277 80 1.17

Two F96T12 Lamps 120 150 0.63

277 150 0.63

Two F96 T12 HO Lamps 120 220 0.39

277 220 0.39

Due to the language in the consensus standard that DOE adopted in the 2000 Ballast Rule, it was still be possible for manufacturers to produce and sell magnetic ballasts for certain types of fluorescent lamps. In response, Co ngress promulgated new energy conservation standards for certain fluorescent lamp ballast s under the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 10958. (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 ba llast efficacy requirements for “energy

e The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40W medium bipin lamps (F40T12) and two nominally 75W 8-foot T12 single pin slimline lamps (F96T12).

3-3saver” versions of full-wattage ballasts, such as the F34T12 ballast. Table 3.2.3 shows the standards prescribed by EPACT 2005. 10 CFR 430.32(m)(5)

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F34T12 Lamp 120 34 2.61

277 34 2.61

Two F34T12 Lamps 120 68 1.35

277 68 1.35

Two F96T12/ES Lamps 120 120 0.77

277 120 0.77

Two F96 T12 HO/ES Lamps 120 190 0.42

277 190 0.42

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as amended, include ballasts that are designed to operate one and two nominally 40W and 34W 4­ foot T12 medium bipin lamps (F40T12 and F34T 12), 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 RDC high output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 277 volts with an input current frequency of 60 Hz and a power factor of 0.90 or greater. 10 CFR 430.32(m). Ballasts that are excluded from regula tion include (1) ballasts designed for dimming to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign or ballasts designed for use with two F96T12 HO/ES lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign, f (3) ballasts with a power factor of less than 0.90 and designed and labeled for use only in residen tial building applications, and (4) replacement
ballasts as defined in paragraph (m)(4)(ii). g 10 CFR 430.32(m)(2), (m)(4), and (m)(7).

On December 19, 2007, the President signed the Energy Independence and Security Act of 2007 (EISA 2007) (Pub. L. 110140), 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 amend its test procedure for fluorescent lamp ball asts to incorporate a measure of standby mode and off mode energy consumption by March 31, 2009. (42 U.S.C. 6295(gg)(2)(B)(ii)) In addition, pursuant to 42 U.S.C. 6295(o), DOE is di rected to incorporate standby mode and off

f 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°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°F
or less.

g The exclusion provided for replacement ballasts requires that they meet certain cr iteria 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 of this TSD for the exact language of the exclusion for replacement ballasts.

3-4mode energy use in any amended or new sta ndard 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.

DOE published a final rule test procedure to comply with the standby mode and off mode energy use provisions from EISA 2007 that apply to fluorescent lamp ballasts that are (or could be) covered by this rulemaking. DOE stated in that final rule that standby mode energy use, as defined in EISA 2007, h is nonexistent for typical ballasts that operate on a switch or a motion sensor. DOE also stated that standby mode ener gy use is only applicable to ballasts with a lighting control system. One example of these new ballast designs is a DALI i -enabled ballast. DALI-enabled ballasts exhibit standby power, as they have internal circuitry that is integral to the design of the ballast that remains on and ac tive, even when the ballast is not driving any lamps. DOE noted that fluorescent lamp ballast s never meet the definition of “off mode.”

Pursuant to EPCA section 325(gg)(2)(A), 42 U.S.C. 6295(gg)(2)(A), DOE is evaluating whether to incorporate standby mode into a single amended or new metric. DOE is also evaluating whether to include standby mode standa rds in this rulemaking. For more information, see chapter 2 of the preliminary TSD.

3.2.3.2 California Energy Commission

The California Energy Commission (CEC) specifies appliance standards that are “applicable as state law to the sale and offe ring for sale of appliances in California.” 4 The current standards took effect on December 29, 2007. The CEC is currently undergoing a rulemaking to revise the existing standards.

3.2.3.3 Canadian Energy Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the energy efficiency of fluorescent lamp ballasts in Canada. In 1992, Parlia ment passed the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using products, effective in February 1995. Fluorescent la mp ballasts were include d in the first set of energy efficiency regulations, published in November 1994. 5 An amendment published in April 2003 updated Canada’s regulations to the minimum le vels put forth in the 2000 Ballast Rule. It

h In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii) , section 310 of EISA 2007 defines “active mode,” “off mode,” and “standby mode” as follows: “The term ‘active mode’ means the condition in which an energy-using product—(I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main
functions.” “The term ‘off mode’ means the condition in which an energy-using product— (I) is connected to a main power source; and (II) is not providing any standby or active mode function.” “The term ‘standby mode’ means the condition in which an energy-using product (I) is connected to a main power source; and (II) offers 1 or more of the following user-oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous functions including information or status displays (including clocks) or sensor-based functions.”

i DALI stands for Digital Addressable Lighting Interface, which is a system that enables communication between a central lighting controls system and the individual components, including the ballasts.

3-5also proposed two effective dates: April 1, 2005 for new installations and April 1, 2010 for existing installations (replacement ballasts). 6 Amendment 9, published in the Canadian Gazette Part II on November 15, 2006, introduced standards for ballasts that operate energy-saving lamps and F32T8 lamps, modified the criteria for exempted ballasts, and repealed the effective date for fluorescent lamp ballasts. 7 Table 3.2.4 8 shows the current Canadian standards for fluorescent lamp ballasts.

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Wattage |

W Minimum Ballast Efficacy Factor

Level 1 j Level 2 k

One F40T12 Lamp * 120 40 1.805 2.29

277 40 1.805 2.29

347 40 1.750 2.22

One F34T12 Lamp 120 34 1.805 2.61

277 34 1.805 2.61

347 34 1.750 2.53

Two F40T12 Lamps 120 80 1.060 1.17

277 80 1.050 1.17

347 80 1.020 1.12

Two F34T12 Lamps 120 68 1.060 1.35

277 68 1.050 1.35

347 68 1.020 1.29

Two F96T12(IS) Lamps ** 120 150 0.570 0.63

277 150 0.570 0.63

347 150 0.530 0.62

Two F96T12(ES) Lamps 120 120 0.570 0.77

277 120 0.570 0.77

347 120 0.530 0.76

Two 110W F96T12 HO Lamps 120 220 0.390 0.390

277 220 0.390 0.390

347 220 0.380 0.380

Two F96T12 HO(ES) Lamps 120 190 0.390 0.42

277 190 0.390 0.42

347 190 0.380 0.41

Two F32T8 Lamps 120 64 1.250 1.250

277 64 1.230 1.230

347 64 1.200 1.200 *Also for use on 40W/48T10/RS lamps **Also for use on 60W/96T12/IS lamps

The Canadian standards listed above apply to residential as well as commercial ballasts.
Canadian standards consider an input voltage of 347V in a ddition to 120V and 277V, which is
consistent with the Canadian el ectrical distribution network. Cana dian standards also require a

j The Level 1 effective date is April 1, 2005 for replacement ballasts.

k The Level 2 effective date for new installation ballasts is February 3, 1995; the Level 2 effective date for replacement ballasts is April 1, 2010.

3-6minimum power factor of 0.9 (consistent with U.S. standards) fo r all ballasts except residential
ballasts.

3.2.3.4 European Energy Efficiency Standards

Directive 2005/32/EC of the European Parliame nt and the Council of the European Union
amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC to establish a framework for setting energy efficiency requirements for energy-using products. Energy efficiency standards for fluorescent lamp ballasts have yet to be published.

3.2.4 Non-Regulatory Initiatives

DOE reviewed several national, regional, a nd local voluntary programs that promote the use of energy efficient lighting in the United States. These include the Federal Energy Management Program’s (FEMP’s) program for energy efficient lighting, the Consortium for Energy Efficiency’s (CEE’s) High Performance Commercial Lighting Initiative, the ENERGY STAR Program, and the Northeast Energy Effici ency Partnership (NEEP). The following section summarizes some of these programs for the ballasts covered by this rulemaking. While it is not an exhaustive list, the discussion provides detail on some notable initiatives that characterize recent developments in the lighting market.

3.2.4.1 Federal Energy Management Program

FEMP helps Federal buyers identify and purchase energy efficient products including
certain fluorescent ballasts. Section 161 of EP ACT 1992 encourages energy efficient Federal procurement. Section 104 of EPACT 2005 require s that each agency incorporate energy efficiency criteria consistent with ENERGY ST AR and FEMP-designate d products for “...all procurements involving energy consuming products and systems, including guides specifications, project specifica tions, and construction, renovation, and service contracts that include provision of energy consuming products and systems, and into the factors for the evaluation of offers received for the procurement.” Executive Order 13123 and Federal Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency, including all models that qualify for the ENERGY STAR product labeling program. 64 FR 30851, 30854 (June 8, 1999). FEMP provides recommendations for how to buy energy efficien t fluorescent ballasts, including the products
shown in Table 3.2.5. 9 FEMP offers buyers support tools su ch as efficiency guidelines, costeffectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, demonstrations, and design assistance.

3-7Table 3.2.5 Federal Energy Management Pr ogram Efficiency Recommendation

Lamp Type Number of Lamps Recommended BEF Best Available BEF

Four-Foot and U-Tube Lamps

T8, 32 Watts 1 2.54 or higher 3.00

2 1.44 or higher 1.54

3 0.93 or higher 1.06

4 0.73 or higher 0.79

T12, 34 Watts 1 2.64 or higher 3.05

2 1.41 or higher 1.53

3 0.93 or higher 0.95 Eight-Foot Lamps T8, 59 Watts 2 0.80 or higher 0.81 T12, 60 Watts 2 0.80 or higher 0.80

3.2.4.2 Consortium for Energy Efficiency

CEE has both a Residential Lighting Initiative and a High-Performance Commercial Lighting Initiative. CEE launched its commercial lighting initiativ e in November 2004 to help identify and select energy efficient commercia l lighting products and practices. Initial efforts focused on designating high-performance T8 lighting products. In January 2007, the initiative was expanded to include redu ced-wattage T8 products. Ta ble 3.2.6 and Table 3.2.7 summarize CEE’s specifications for high-performance and reduced-wattage T8 ballasts.

Table 3.2.6 CEE High-Performance T8 Ballast Specifications 10

Instant Start Ballast

Lamps Low BF

BF ≤

0.85 Normal BF
0.85<BF<1.0 High BF

BF ≥ 1.01

1 ≥ 3.08 ≥ 3.11 n/a

2 ≥ 1.60 ≥ 1.58 ≥ 1.55

3 ≥ 1.04 ≥ 1.05 ≥ 1.04

4 ≥ 0.79 ≥ 0.80 ≥ 0.77 Programmed Rapid Start Ballast

1 ≥ 2.84 ≥ 2.84 n/a

2 ≥ 1.48 ≥ 1.47 ≥ 1.51

3 ≥ 0.97 ≥ 1.00 ≥ 1.00

4 ≥ 0.76 ≥ 0.75 ≥ 0.75 Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total Harmonic Distortion ≤
20%

3-8Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications 11

Instant Start Ballast, 28W Systems Lamps All BF Ranges

1 ≥ 3.52

2 ≥ 1.76

3 ≥ 1.16

4 ≥ 0.88 Instant Start Ballast, 25W Systems

1 ≥ 3.95

2 ≥ 1.98

3 ≥ 1.32

4 ≥ 0.99 Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total
Harmonic Distortion ≤ 20%

CEE created separate standards for normal wattage T8 ballasts ba sed on ballast factor, which compares the ratio of light output of la mps operated by a specific ballast to the light output of the same lamps operate d by a standard reference balla st. However, CEE chose not to create standards by ballast factor for reduced-wa ttage ballasts. A dditionally, CEE did not specify performance based on input voltage. CEE’s specifications state that multi-voltage ballasts must meet or exceed the listed BEF when operating on at least one of the intended operating voltages.

3.2.4.3 NEMA Premium

NEMA maintains a labeling program for “NEMA Premium” ballasts based on CEE’s specifications for high-efficiency 4-foot T8 ballasts. The program is intended to promote energy efficiency and assist end-users in identifying the most efficient ballasts on the market. 12 As of March 2009, NEMA’s website indicates that ballast s manufactured by Acuity Brands Lighting, Advance, American Ballast, Espen Technologies, GE, Osram Sy lvania, Robertson Worldwide, Technical Consumer Products, and Universa l all qualify for the NEMA Premium label.

The NEMA Premium label for fluorescent lamp ballasts is similar to NEMA’s existing program for motors. In November 2004, NEMA releas ed state-level shipment data that showed an increase in NEMA Premium motor shipme nts of 30 percent between 2001 and 2002 and 14 percent between 2002 and 2003. 13

3.2.4.4 ENERGY STAR

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency (EPA) designed to protect the environment by promoting energy efficient products and practices. 14 ENERGY STAR specifies criteria for resi dential lighting fixtures, which contain three parts: a lamp, a ballast, and the fixture th at holds the lamp and ba llast. Products that qualify for the ENERGY STAR label may not use magnet ic ballasts in indoor fixtures. The ENERGY STAR specifications also define criteria for lamp start time, power factor, lamp current crest factor, ballast operating temperature, electrom agnetic interference, frequency, transient protection, end of life prot ection, dimming, and safety. 15

3.2.4.5 Energy Efficient Commercial Building Deduction

3-9EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 179D), which establishes a tax deduction for building owners who incur expenses for energy efficiency upgrades. Effective for property in service from January 1, 2006 through December 31, 2008, the deduction allows partia l deductions for improvements in interior lighting. Though the statute does not specify required lamp types or efficacies, it does call for an overall reduction in lighting power density, encouraging the use of higher-performance and reduced-wattage fluorescent lamps. The Emergency Economic Stabilization Act of 2008 (HR-1424), approved and signed on October 3, 2008, extends the benefits of EPACT 2005 through December 31,

2013.

3.2.4.6 Northeast Energy Efficiency Partnerships

NEEP is a regional nonprofit organization that promotes energy efficiency in the Northeast. NEEP runs a High Efficiency Commercial Lighting Initiative to “achieve costeffective energy and demand by overcoming market barriers to the availability and widespread market adoption of advanced T8 fluorescent lighting systems.” 16 NEEP coordinates with multiple local and state governments, utilities, a nd other initiatives, such as Efficiency Vermont l
and the Long Island Power Authority, to promote efficient lighting products. 17, 18

3.2.5 Historical Shipments

Awareness of annual product sh ipment trends is an importa nt aspect of the market assessment and the development of the standards rulemaking. For this rulemaking, DOE used publicly available ballast shipments from the U.S. Census from 1990 to 2005. 19 DOE also obtained confidential shipments from NEMA for 2007.

DOE used this data for three main purposes. First, the shipment data and market trend information contributed to the shipments analysis and base-case forecast for ballasts (chapter 9 of the preliminary TSD). By using historical shipment data and expert opinion on market trends and calibrating forecast assumptions with recen t data, DOE believes it has based the shipments
model and base-case forecasts on a sound dataset. Second, DOE used the data to select the representative product classes and representative units for analysis. Generally, DOE selected product classes and units to reflect the highest volume, most common ballast types used in the United States today (chapter 5 of the preliminary TSD). Third, DOE used the data to develop the installed stock of ballasts for the national impact analysis (chapter 10 of the preliminary TSD). Based on its understanding of trends in the market, DOE estimated how the market would respond to various candida te standard levels.

The historical shipment data for ballast s is broken down into many subcategories beginning with magnetic versus electronic ty pe ballasts. Under each technology type, the shipments are categorized by a variety of characteristics. Commercial and residential ballasts are delineated by corrected versus uncorrected power factor (section 3.3.3.4). Ballasts are also

l Efficiency Vermont offers technical assistance and financial incentives to encourage energy efficiency in Vermont. This organization offers rebates ranging from $10 to $50 for the upgrade to or installation of High Performance T8
systems.

3-10defined by starting method (sec tion 3.3.3.1), maximum number of lamp s driven (one, two, three, or four), lamp wattage, lamp diameter, and a few additional specific characteristics. Based on
interviews with ballast manufacturers, DOE learned that the U. S. Census data represents about 90 percent of T8 and T5 shipments and about 70 percent of T12 electronic shipments. DOE also
learned that the U.S. Census does not include sh ipment data for major residential ballasts or dimming ballasts. The Census data also does not provide shipments for every permutation of ballast performance characteristics, but does provide data for establishing trends for the major categories. Ballasts that operate T8 lamps comprised the majority of shipments in 2005. These are followed (in order of 2005 unit sales) by T12 ba llasts, compact fluorescent lamp ballasts, T5 ballasts, and other small subsets.

Figure 3.2.1 depicts the ballast market based on shipments reported to the U.S. Census in

2005.

Figure 3.2.1 2005 Ballast Market Share

In 2005, corrected power-factor (commercial) magnetic ballasts were not broken out into smaller categories for shipments reporting. DOE used subcategory unit shipment proportions from the 2000 corrected power-factor magnetic balla st category to extrapolate the disaggregation of shipments for 2005. This estimation provided da ta points for 4- and 8-foot magnetic T12
ballasts as well as 8-foot HO ma gnetic T12 ballasts. The 2005 U.S. Census Data also did not report magnetic residential and linear dimming ballast shipments. To estimate magnetic residential ballast shipments, DOE extended the linear decline in magnetic residential ballasts from 2002-2004 to extrapolate a value for 2005. DOE used a similar approach to estimate linear dimming ballast shipments.

Electronic ballasts have slowly replaced magne tic ballasts, as seen in Figure 3.2.2. In 1990, magnetic ballasts repres ented about 96 percent of shipment s, while the 2005 ma gnetic ballast market share dropped to 27 percent. This trend was in part due to energy conservation standards

3-11for T12 ballasts. The most recent energy conservation standards for fluorescent lamp ballasts effectively eliminated the sale of 4-foot T12 medium bipin (MBP), 2-foot T12 U-shaped, and 8­ foot T12 slimline magnetic ballasts. The standard began to go into effect for certain 4-foot T12 MBP, 8-foot T12 slimline ballasts, and 8-foot HO ballasts in 2005. The final phase of the standard will be effective in 2010, when replacem ent 4-foot T12 MBP, 8-foot T12 single pin (SP) slimline, and 8-foot HO magn etic ballasts will no longer be sold. (10 CFR 430.32(m)(4)(ii) and 430.32(m)(5)-(6))

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Market Share

Magnetic

Electronic

1989 1991 1993 1995 1997 1999 2001 2003 2005

Year

Figure 3.2.2 Magnetic and Electronic Ballast Market Share

The vast majority of 4-foot T12 MBP and 2-foot T12 U-shaped ballasts are magnetic (about 77 percent of the T12 market in 2005), and th e vast majority of 4-foot T8 MBP and 2-foot T8 U-shaped ballasts are electronic (about 97 percent of T8 ballast shipments in 2005). Therefore, the decline in magnetic ballasts mirrors a decline in T12 ballast shipments. Similarly,
the increase in electronic ballasts mirrors an increa se in 4-foot T8 MBP and 2-foot T8 U-shaped ballast shipments. Figure 3.2.3 and Table 3.2.8 show these shipment trends. The trend in ballast shipments is followed by similar trends in 4-foot T8 MBP and 2-foot T8 U-shaped lamp shipments and 4-foot T12 MBP and 2-foot T12 U- shaped lamp shipments. DOE received general service fluorescent lamp historical shipments from NEMA from 2001 to 2005. 20 Based on conversations with manufacturers, DOE believes these trends continue beyond 2005.

3-12

### 0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

1994 1996 1998 2000 2002 2004 2006Shipments



### Year T8s

T12s

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U- Shaped Ballasts and Lamps and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps

Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Four-Foot

T12
Ballast (D) (D) 27,227 27,704 26,395 24,463 (D) (D) (D) (D) 11,218

Four-Foot
T8 Ballast 23,965 22,317 28,032 30,883 32,488 40,179 44,700 44,215 43,219 45,727 45,951

Four-Foot T8 Lamp (D) (D) (D) (D) (D) (D) 172,143 170,416 179,312 204,922 224,189

Four-Foot T12 Lamp (D) (D) (D) (D) (D) (D) 222,236 215,312 191,391 182,864 171,503

(D) indicates data not made public.

Table 3.2.9 shows similar trends for 8-foot T12 and T8 SP slimline ballasts and lamps. In general, 8-foot SP slimline T12 ballasts and lamps are experiencing a decrease in shipments, whereas 8-foot SP slimline T8 ballasts and lamps are experiencing an increase in shipments. The increase in shipments for 8-foot SP slimline T8 lamps is smaller than for 4-foot T8 shipments. According to manufacturers and lighting experts, this is because a portion of the 8-foot T12 SP slimline ballast market is being transferred to the 4-foot T8 ballast market.

3-13Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts and Lamps
Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 Eight-Foot
Slimline T12
Ballast 7,394 6,612 6,268 6,601 6,638 5,813 (D) (D) (D) (D) 2,599

Eight -Foot
Slimline T8
Ballast 932 847 961 959 1,020 1,160 1,547 1,560 1,218 1,214 1,224

Eight -Foot
Slimline T12 Lamp (D) (D) (D) (D) (D) (D) 43,2 65 41,443 37,170 36,263 33,636

Eight -Foot
Slimline T8 Lamp (D) (D) (D) (D) (D) (D) 4,405 5,300 5,183 5,727 5,176

(D) indicates data not made public.

Table 3.2.10 shows that T12 high-output ballast shipments decreased from 1995 to 2005. Data for high output ballasts were not repor ted in 1997 or from 2001 to 2005. DOE estimated the 2005 market share using the method described earlie r. A portion of the ballasts listed in Table

3.2.10 are rated for cold-temperature outdoor sign age applications, which were excluded from previous energy conservation standards. The Census data for high output ballasts are not exclusive to ballasts that operate 8-foot RD C HO lamps, but information from manufacturers indicates these ballasts represent most of the high output market. Discussions with lighting experts and lamp manufacturers indicate that th ey expect any migration of the 8-foot RDC HO market to go toward T5 HO fluorescent systems and metal halide systems. High output ballast shipments likely follow a similar trend to the 8-foot HO lamp shipments. Both ballast and lamp

3-14Unit Sales by Year*

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 Eight-Foot

T12 RDC
HO Ballast 3,538 3,322 (D) 2,305 3,089 2,682 (D) (D) (D) (D) 1,199

Eight-Foot

T12 RDC HO Lamp 23,887 24,398 24,206 24,591 25,442

Eight-Foot

T8 RDC HO Lamp 691 647 467 674 420

(D) indicates data not made public. shipments show the high output market share is much smaller than for 8-foot slimline T8 and T12 ballasts and lamps.

Table 3.2.10 T12 High-Output Ballast Market Share

* Data from 1995 and 1996 include electronic and magnetic ballast shipments. Data from 1997-2005 include only magnetic shipments. Lamps shipments are available for 2001-2005 only.

Based on public data, Figure 3.2.5 shows magne tic residential balla st shipments have
decreased from 1995 to 2004. m Shipments data for this category were unavailable for 2005. Because the major manufacturers in the residentia l sector are not members of NEMA, shipments in the residential sector are likely larger than t hose reported in the U.S. Census data. Residential ballasts have been excluded from energy conservation sta ndards to date.

14,000

12,000

10,000

8,000Shipments

6,000

4,000

2,000

0

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006

Year

Figure 3.2.5 Shipments of Residential Ballasts

m

U.S. Census data does not report shipments of electronic residential (low-power-factor) ballasts.

3-15T5 ballasts have been growing steadily si nce reported shipments began in 2002 (Figure 3.2.6). T5 normal output ballast shipments were not reported in the U.S. Census data.
Conversations with balla st manufacturers indicated some gr owth in normal output T5 ballasts due to replacements of 4-foot electronic T8 ballasts. In add ition, manufacturers indicated that significant growth in T5 ballast shipments has been driven by 4-lamp T5 high output ballast systems replacing high-bay metal halide systems in the industrial sector. Based on information from ballast manufacturers, DOE believes these trends continued beyond 2005.

Figure 3.2.6 Shipments of T5 High-Output Ballasts

3.3 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a preliminary list of technologies that could be used to improve the efficiency of fluorescent lamp ballasts. The following assessment provides a description of the basic co nstruction and operation of the fluorescent lamp and fluorescent lamp ballast, followed by technology options to improve efficiency.

3.3.1 Basic Structure of Fluorescent Lamps

The fluorescent lamp is a low-pressure gas discharge source. The lamps are tubular in shape and available in a variety of lengths, diameters, and wattages.

Lamp types are designated by a series of le tters and numbers. The letter “F” is used to designate a fluorescent lamp. It is followed by a two-digit number that identifies either the nominal lamp wattage for nominally 4-foot lamps or the lamp length in inches for 8-foot lamps. These digits are followed by the letter “T,” for tubular, which is followed by the lamp diameter

3-16in eighths of an inch. Additional designations are sometimes used: for example, “HO” if the lamp is high output or “/ES” if the lamp is an energy saver or reduced-wattage lamp. Table 3.3.1
shows the nomenclature that defines the diamet er, lamp length, and la mp wattage for some common fluorescent lamps.

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature

Lamp Nomenclature Nominal Lamp Length feet Nominal Lamp Wattage

W Lamp Diameter
inches

F32T8 4 32 1

F40T12 4 40 1 1⁄2

F54T5 HO 4 54 5/8

F96T12 8 75 1 1⁄2

F96T12 HO 8 110 1 1⁄2
F96T12 HO/ES 8 95 1 1⁄2

The fluorescent lamp consists of a glass bulb or tube, filled with low pressure mercury vapor and inert gas, with electrodes sealed onto both ends of the tube. The fluorescent lamp has five major components: bulb, el ectrodes, base, gas fill, a nd phosphors. Two electrodes are hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled tungsten wires coated with a mixture of alkalin e oxides. A base provides an electrical connection to these electrodes and also supports the lam p. Depending on the star t method and operational properties of the lamp ( e.g. , dimming, wattage, etc.), lamp designs may use different bases such as SP, MBP, and RDC. Once voltage is applied to the electrodes, the tungsten coil and coatings emit large quantities of electrons when the co ating is at the proper temperature (1,000–1,300 K). These electrons then collide with gaseous mercury atoms, exciting electrons within those atoms. As the electrons decay to their stable or gr ound state, they emit UV radiation primarily at 254 nanometers (nm). In addition to the mercury vapor, an inert gas or a combination of gases is added to the lamp primarily to moderate the collisions of mercury ions and minimize evaporation of the electrode coating. The UV radiation is then absorbed by the phosphors and reemitted as light.

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp

Regardless of shape, size, or type, all fluorescent lamps require a ballast to initiate and maintain the arc discharge.

To achieve arc formation, the gas plasma ha s to be excited, ionized, and broken down (to become a virtual negative resistance, almost a sh ort circuit). This requires an initial high cathode emission and a high electric field ( i.e. , voltage). Once the arc is achieved, current limiting has to be involved to prevent run-away and almost immediate lamp burnout. These two phenomena,

i.e. , ignition and current limiting/control, are required in all fluorescent lamps, regardless of shape, size, or type. Both functions constitute the major function of a ballast. Figure 3.3.1 shows a graphical representation of this relationship from ignition (Townsend, glow, and abnormal glow) through arc discharge.

3-17Current(I)



### Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

RegionCurrent(I)



### Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

Region

Figure 3.3.1 Electrical Characterist ic of a Gas Discharge Lamp Source: Adapted from Murdoch, Illuminating Engineering: From Edison’s Lamp to the LED , 2nd Edition, 2003.

A voltage pulse several times that of the lamp operating voltage may be required to initiate the arc discharge. During this process, the lamp’s operating point must pass through the Townsend, glow, and abnormal-glow as quickly as possible. Rapid star t (RS) and programmed start (PS) systems use tertiary cathode heating to catalyze this process, while instant start (IS) operation simply uses a higher starting voltage.

In general, tertiary cathode heating is believed to have a positive impact on lamp life. The reduction in filament heating caused by instant start operation increases the rate of loss of the low–work function coating due to reduced i on bombardment at the cathode (also known as sputtering). This causes the tungsten wire coating to deteriorate more rapidly over time, which contributes to higher failure rates. Therefore, lamps that operate on RS or PS ballasts can have longer lifetimes than lamps that operate on IS ballasts. Lamp life not only depends on the starting method of the ballast, but can also depend on the la mp current crest factor. For more information on starting method and lamp current crest factor, see section 3.3.3.

3.3.3 Fluorescent Lamp Ballast Overview

Fluorescent lamp ballasts are devices that by means of resistance, inductance, capacitance, or electronic elements, singly or in combination, control the current, voltage, and waveform to properly start and safely operate fluorescent lamps (ANSI C82.13-2002). The following sections discuss ba sic ballast operation and the tw o main ballast technologies: magnetic and electronic.

A ballast has four critical functions:

1. provide controlled cathode heating to aid in starting and maintaining the arc discharge,

2. deliver high voltage to st art and ignite the lamp,

3-183. regulate (limit) electric current flowing through the lamp after ignition to avoid current run-away and self-destruction, and

4. regulate (compensate) for variations in line voltage. Good regulation ensures that small variations in line voltage result in even smaller variations in lamp lumen output.

Ballast types can be subdivided into two ma in groups: magnetic (low frequency) and electronic (high frequency). Magnetic ballasts were the first technology used to operate ballasts. Electronic ballasts were developed later in the 1980s because of their high efficiency. Section

3.3.4 provides additional discussion on these and other technology options that can be used to increase the efficiency of fluorescent lamp ballasts.

There are many performance parameters used to describe the operation of a fluorescent lamp ballast. These include starting method, ballast factor, ballast efficacy factor, power factor, total harmonic distortion (THD), electromagnetic interference (EMI), and fluorescent system safety requirements. These performance pa rameters are briefly discussed below.

3.3.3.1 Starting Method

Fluorescent ballasts can be categorized by th e manner in which they operate the lamp, or more specifically, how the lamp is started. The most common ballasts use three different methods to start a fluorescent lamp: rapid start, programmed start, and instant start. These methods are all defined in ANSI C82.11-2002. The starting method primarily affects the ballast’s switching cycle capability ( i.e. , the number of times one can switch the lamp on and off before it expires) and the power consumption of the ballast.

Rapid start ballasts heat the electrodes for a set amount of time before lamp ignition. The coil heating reduces the open circuit voltage required to start the lamp, but coil heat remains constant after starting and consumes additional power. 21 The major benefit of this starting technique is that it leads to a longer lamp life th an the starting technique of an IS ballast. For example, if the lamp is switched on and off ev ery 3 hours, the fluorescent lamp life would be approximately 25 percent lower for an IS ballast than for a RS ballast. However, when the lamp is frequently switched on and off ( e.g. , every 15 or 30 minutes), the lamp life on instant start and rapid start ballasts can be similar. 23 In general, RS ballasts provide between 15,000 and 17,000 switching cycles. 22, 23

A more recent and advanced version of the RS ballast is the PS ballast. Like the RS ballast, the PS ballast heats the la mp filaments to a certain temp erature for a prescribed amount of time before applying a high-voltage pulse to ignite the lamp. Some programmed start ballasts remove all power to the electrodes after ign ition (also known as cathode cut-out), resulting in some energy savings over other PS systems. Ho wever, due to added in ternal circuitry, PS
ballasts cannot be as efficient as IS balla sts. PS ballasts can provide between 50,000 to 100,000 switching cycles depending on ballast design. 22, 24 A lamp operating on a PS ballast can last more than three times longer than it would on a RS or IS ballast. 22

Instant start ballasts rely on higher voltage to initiate the discharge rather than applying a steady filament voltage. These ballasts apply a very high voltage pulse to the lamp to rapidly ionize the gas in the lamp and initiate the ar c instantly, without the need for heating the

3-19electrodes. Because IS electronic ballasts do not provide lamp electrode heating, these ballasts are inherently more efficient, saving approximate ly 2 watts of energy per lamp compared to RS ballasts. However, due to the high applied voltage necessary to st art the lamp, the electrodes of a lamp operated by an IS ballast deteriorate more quickly than the heated electrodes of a lamp operated by a RS or PS ballast, resulting in decreased lamp life. IS ballasts can provide between 10,000 and 15,000 switching cycles depe nding on the ballast design. 22, 23

3.3.3.2 Ballast Factor

The ballast factor is defined as the output of a ballast delivered to a reference lamp in terms of power or light divided by the output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). To calculate the light output of a lamp-and-ballast system, one would multiply the light output of the lamp by both the number of lamps operated by the ballast
and its ballast factor. Because ba llast factor affects the light out put of the system, manufacturers design ballasts with a range of ballast factors to allow consumer s to vary the light output (and thus power consumed) of a fluoresce nt system. In general, ballasts designed with a ballast factor
of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor of 0.78 or less; high ballast fact or ballasts typically have a ballast factor of 1.10 or higher.

3.3.3.3 Ballast Efficacy Factor

Ballast efficacy factor (BEF) is a measure of ballast system performance or efficacy. According to Appendix Q to Subpart B of Part 430 in the CFR, this factor is defined as:

Relative Light Output BEF = Equation 3.1 Input Power

Where:

B

EF = ballast efficacy factor; Relative Light Output = the light output delivered through the use of a ballast divided by the light output delivered through the use of a re ference ballast, expressed as a percent; and InputPower = the power consumption in watts of a ba llast and fluorescent lamp or lamps.

3.3.3.4 Power Factor

The power factor (PF) is calculated by determining the ratio of the active power to the apparent power. PF depends on the current’s wa ve shape as well as the phase relationship between the current and the voltage. The power input is measured with a wattmeter capable of indicating the average power in watts. The ballast input voltage multiplied by the ballast input current is the ballast’s apparent power (ANSI C82.13-2002).

Power Input Power Factor = Equation 3.2 Ballast Input Voltage ∗ Ballast Input Current

Where:

PowerFactor = power factor,

3-20PowerInput = input power in watts to ballast, BallastInputVoltage = input voltage in volts to ballast, and BallastInputCurrent = input current in amps to ballast.

Power factors range between 0 and 1. A power fa ctor of 1 indicates that the voltage and current wave forms are in phase and not distorte d. Fluorescent ballasts can be characterized by two classes of power factor: high power factor (HPF) of 0.9 or greater, and normal power factor (NPF) of 0.6 or greater. HPF ballasts use about on e-half the current of NPF ballasts. The primary cause of low power factor in ma gnetic ballasts is the inductance of the ballast transformers. It can be corrected with the addition of the proper capacitor. In electronic ballasts, the primary cause of low power factor is due to total harmonic distortion (defined below) caused by a nonlinear load. According to ANSI C82.77-2002, comme rcial ballasts must have a HPF while residential fluorescent ballasts (with an input pow er below 120W) must have a power factor of

0.5 or greater.

3.3.3.5 Total Harmonic Distortion

Another important performance parameter is harmonic distortion. Line current harmonics are the components of the line current that osc illate at integer multiple s of the fundamental frequency of the power supply, e.g. , 60 Hz, 120 Hz, 180 Hz, etc. Harmonics of a fundamental frequency are an undesirable byproduct of any no n-linear system operation, generating noise and wasted power. Total harmonic distor tion refers to the ratio of the root mean square (rms) values
of the harmonic content to that of the fundamental current, expressed as a percentage. It may also
be called harmonic factor:

2 2 2 I + I + I +

...

2 3 4 THD ( fund ) = I 1 2 Equation 3.3

Where:

THD = total harmonic distortion; and

I

n = the rms current of harmonic n , where n=1 is the fundamental harmonic.

High THD figures are not acceptable and are detrimental to many kinds of electronic devices connected to the power line. They are also considered a “pollutant” to the environment because of radio frequency noise. Therefore, ANSI C82.11-2002 requires that the THD of electronic ballasts not exceed 32 percent. Electronic ballasts today are typically rated at less than 20 percent THD. Magnetic ballasts are typically rated in the 20 to 28 percent range.

3.3.3.6 Electromagnetic Interference

Many devices found in office environments, such as computers, photocopiers, facsimile machines, and fluorescent lighting systems, can generate electromagnetic waves. The effects of these waves vary based on their strength and the susceptibility of nearby equipment. Alternating
current in electronic devi ces produces a magnetic field, which in turn induces an AC voltage in a

3-21nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or
radiated. Conducted EMI occurs when electronic devi ces induce currents in the local power network that in turn negatively affect other devi ces on that network. Radiated EMI is associated with the electric and magnetic fi eld inherent in electronic devi ces. EMI can be minimized with proper grounding and wiring techniques. 25 EMI limits for both consumer and non-consumer lighting products sold in the United States are listed in 47 CFR 18 subpart C. These regulations require that consumer/residential (Class B) ballasts have lower maximum EMI requirements than non-consumer (Class A) products. The International Committee on Radio Interference has more stringent regulations concerning EMI. However, fluorescent lamp ballasts sold in the United States currently do not have to meet these regulations.

3.3.3.7 Safety

A ballast will continue to drive or reignite a lamp when the lamp reaches the end of its life. Usually, the failure of th e lamp will have no adve rse consequences. Occasionally, the ballast will continue to try to drive a failed lamp repeatedly until the temperature in the region of the electrode increases rapidly and causes overheati ng of the lamp electrodes. This can be avoided through additional circuitry that provides end-of-life (EOL) prot ection. Some ballasts in the United States are required to have EOL protection ( e.g. , ballasts that operate T5 lamps). However, the most popular T8 ballasts are not. International standards (IEC 600797-1 Ed. 4) require all fluorescent lamp ba llasts regardless of lamp diamet er to have EOL protection.

Another safety issue arises when a lamp is not inserted properly into the lamp holder, which can cause arcing. This problem can either be addressed through better design of the lamp holders, or by adding circuitry to the ballast that detects arcing and reduces the output voltage so
that the arc cannot be sustained.

3.3.4 Fluorescent Lamp Ballast Technology Options

The following section discusses the two ma jor technologies used in fluorescent lamp ballast design—magnetic ballasts and electronic ballasts— and additional technology options (lamp diameter, improved components, and improved circuit design) that can incrementally improve the efficiencies of a magnetic or electronic ballast.

3.3.4.1 Magnetic Ballasts

The main components of a magn etic ballast are a magnetic choke to limit the current, a step-up transformer to obtain a high starting voltage, and a capacitor that corrects for the ballast’s low power factor. Multi-lamp magnetic ballasts also have one or more additional capacitors to sequence the starting of the lamps. Magnetic ballasts opera te at an input frequency of 60 Hz and operate the lamp(s) at the same frequency.

The main core-and-coil assembly consists of a capacitor and laminated transformer steel wound with copper or aluminum magnet wire. The assembly is infused with a potting material ( e.g. , hot asphalt) containing fiber su ch as silica and housed in a steel case. Figure 3.3.2 presents a labeled graphic of the interior of a standard magnetic ballast.

3-22Figure 3.3.2 Cutaway View of a Typi cal Magnetic Fluorescent Ballast

The core and coil assembly functions as a voltage transformer and a current limiter (choke). A capacitor enables the ballast to use energy from the alternating current power line more efficiently, which is then referred to as a HPF or PF corrected ballast. The purpose of the insulating material is to conduct heat away fro m the transformer coils and ensure tightness of
transformer coils to eliminate vibrational noise.

Because of their low frequency operation, magnetic ballasts are less energy efficient than electronic ballasts (Figure 3.3.3). Magnetic ba llasts fail to optimize lumen output for a given wattage. These ballasts also release the energy not used to operate the lamp as heat in the transformer windings. This heat is dissipated to the environment by the ballast potting material and its metal or pl astic enclosures.

3.3.4.2 Electronic Ballasts

For equivalent light output, electronic ballasts consume about 10 to 30 percent less energy than magnetic ballasts. An electronic ballast starts and operates fluorescent lamps at frequencies greater than 20 kHz using electronic components rather than the traditional core and coil assembly. The electronic ballast takes the input 60 Hz power, r ectifies it, and converts it into a high frequency using an oscillator circuit.

Higher operating frequency generates great er lumen output. Figure 3.3.3 shows the increase in lumen output relative to 60 Hz operation as a function of frequency. The gain in light output by increasing operating frequency begins to plateau around 20 kHz. Therefore, electronic ballasts typically operate at frequencies above 20 kHz.

3-23Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp Source: Adapted from IESNA, 2002.

Not only is the lamp more efficient at higher frequencies but the ballasting action (current-limiting) at high frequency requires smaller components. This reduces ballast losses and makes the ballast more efficient. In addition, the ballast noise becomes inaudible at higher frequencies and there is no 60-cycle flicker like that associated with fluorescent lamps that operate with magnetic ballasts.

Whereas typical magnetic ballasts generally have three components ( i.e. , core, coil, and capacitor), electronic ballasts ha ve additional blocks of elect ronic components. Figure 3.3.4
shows the interior of an electronic ballast.

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

3-24Figure 3.3.5 presents an example of a func tional block diagram of a fixed-light output electronic ballast. Auxiliary functions performed by a typical electronic ballast include electromagnetic interference filtering to block ballast-generated noise, input rectification, PF
correction for sinusoidal i nput current, a direct-current (DC) filte r, a direct-current to alternatingcurrent (DC-AC) inverter, a feedback/controller fo r high-frequency operation, and a final output stage to power the lamp.

Figure 3.3.5 Fixed-Light Output Electroni c Fluorescent Ballast Block Diagram
Source: T. Ribarich, A Systems Approach to Ballast IC Design, El Segundo, CA, 1999, and Philips Semiconductor, Power Semiconductor Applications , 1994.

Table 3.3.2 provides a description of each component in a typical electronic ballast, the efficiency impact of these components, and the wa veform at each stage of the fluorescent lamp
ballast circuit.

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and
Associated Characteristics

Circuit Stage Function Efficiency Impact Waveform (not to scale)

EMI Filter Impedes EMI by providing a high impedance path to EMI and a low impedance path to the desired input. The circuit also protects against high voltage pikes. Very Low

t V

Begins to convert incoming AC to DC using diodes. A full-bridge rectifier, one type of input rectifier, is composed of four diodes, which “rectify” the full AC waveform as shown in the waveform on the right. The current is not in phase with the voltage. Low

t V, I

3-25Input Rectifier

Power Factor

Correction Corrects the current so it is in phase with the voltage. Power factor correction can be achieved through a buck or boost-converter circuit topology. Low-Medium

t V, I

DC Filter Reduces “ripple” of the DC current waveform using capacitors. The most common type of capacitor used is the electrolytic capacitor. Low

t V

DC-AC Inverter Converts incoming DC to high-frequency AC. The resonant half-bridge self-oscillating circuit is one type of circuit topology that can be used to accomplish this task. MediumHigh

t V

Output Stage When the lamp is not started, the circuit operates in resonance to increase output voltage to start the lamp. Once the lamp is started, the circuit operates at a frequency off of resonance to continue operating the lamp. A resonant filter topology is one type of circuit topology used in the output stage. High Starting:

t V

Operation:

t V

Feedback/Controller An integrated circuit (IC) that controls the frequency output of the DC-AC inverter. It can also protect against under voltage lockout Low N/A

3-26and lamp faults.

3.3.4.3 Lamp Diameter

Lamp diameter is another design parameter of a fluorescent lamp ballast that can affect the ballast efficacy factor. As discussed in section 3.4, product classes are not explicitly segregated by the lamp diameter operated by the ballast. When DOE determines that changes in lamp diameter offer a distinct utility, DOE may establish separate product classes. In general, however, DOE considers lamp diamet er to be a technology option.

The diameter of a lamp affects both the lamp efficacy and the ballast’s BEF. For lamps, an optimum design diameter exists for a specific fluorescent lamp type resulting from two opposing effects. First, in small diameter lamps, an increase in diameter decreases the number of electrons and mercury ions that recombine at the bulb wall and produce no light. This lessening
of non-radiative recombination results in an incr ease of optical power output and subsequently a rise in lamp efficacy. However, when the lamp diameter is sufficiently large as to result in minimal non-radiative recombination, a second oppos ing effect begins to influence the efficacydiameter relation. With these larger diameter lamps, a further enlargement in diameter causes a greater imprisonment of radiation within the lamp. As the total light output is reduced, the lamp efficacy declines as well. In general, T12 lamps are less efficient than T8 lamps.

For ballasts, lamp diameter affects the BEF of a ballast in the following manner. Because T12 lamps are less efficient than T8 lamps, lamp manufacturers can achieve similar light output using lower-wattage T8 lamps. Ballasts that operate lower-wattage T8 lamps use less power to operate the lamp at a similar ballast factor than higher-wattage T12 lamps. Therefore, the BEF of the ballast operating a T8 lamp is generally higher than that of a ballast operating a T12 lamp. Because the BEF and lamp efficacy of a T8 fluorescent system are higher than that of a T12 fluorescent system, T8 systems are more efficacious than T12 systems.

DOE only considered lamp diameter as a technology option for T12 and T8 lamps. DOE’s research indicates that ballasts that operate T8 lamps are common replacements for ballasts that operate T 12 lamps. Although the lumen packages for ballasts that operate T8 lamps are sometimes lower than that of ballasts that operate T12 lamps, in this situation, it does not seem to be significant enough to affect consum er utility. Conversely, DOE’s research indicates that ballasts that operate T5 lamps are not commonly used as substitutes for their T8 or T12 counterparts. T5 lamps require different lamp holde rs due to differences in lamp length and base type. In addition, because T5 lamps have sim ilar total lumen output as T8 and T12 lamps over a significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright for use in direct lighting fixtures. As such, balla sts that operate T5 lamps are not considered a technology option for improving the ballast efficacy factor of T8 and T12 ballasts.

3.3.4.4 Improved Components

3-27A common way to increase the efficiency of both magnetic and electronic ballasts is to improve the quality of their components. Transfor mers, diodes, capacitors, and transistors are the main components that affect efficiency.

Transformers : In electronic ballasts, transformers influence the efficiency of the EMI, power factor correction (PFC), a nd output stage of the ballast. In magnetic ballasts, transformers influence the efficiency of the output stage and current-limiting portion of the ballast.

There are two loss mechanisms associated with transformers: core losses and winding
losses. Core losses involve the ma gnetic properties of the core material, which exhibits power losses in the form of hysteresis and eddy currents within the core itself. Winding losses come from the resistance in the winding, typically copper. There are several technology options that can improve the efficiency of a transformer’s core losses. These include improved silicon steel, amorphous steel, or increased amounts of amorphous steel. Litz wire can be used as a technology option to improve a transformer’s winding losses.

One way to reduce transformer power loss at light loads is to select a transformer with higher quality core materials. There are two types of core materials that ballasts can use: silicon steel (thinly laminated steel alloyed with silicon) and amorphous steel. Core performance of silicon steel can be enhanced by magnetically orienting the grain structure in the metal. Even larger gains in efficiency can be achieved us ing amorphous materials. To further increase the efficiency of the ballast using amorphous material s, one can create the core of the inductor from laminated sheets of amorphous steel, insulated from each other. However, this method can increase the size and weight of the ballast.

Another way to reduce the transformer’s power loss is to select materials with lower winding losses. High-frequency operation (typical of electronic ballasts) can increase winding losses as two additional loss mechanisms, skin effect and proximity effect, become more prominent. One way to reduce both the skin effect and proximity effect is to use litz wire, which
consists of a number of individua lly insulated magnet wires twisted or braided into a uniform pattern. Skin effect refers to th e tendency of AC current to flow through a conductor’s surface or
“skin” rather than a conductor’s core. Because litz wire increases the amount of surface area current can flow through, overall winding losses can be reduced as the effective wire resistance is decreased. When conductors are close together, the magnetic field of one conductor will reduce the area that the current flows through in another conductor, increasing its winding losses. This effect, called the proximity effect, can be also be improved by using litz wire.

Diodes: In electronic ballasts, the input rectifier in verts the negative half of the AC sine wave and makes it positive. Several technology options can be used to improve the efficiency of this portion of the circuit. The power consumed by a diode is the product of the current flowing through the diode multiplied by the voltage drop across it. Conventional diodes have a voltage

3-28drop of about 0.6 V. Using Schottky diodes n reduces the voltage drop across the diodes by about

0.3 V to 0.4 V.

Capacitors: In both magnetic and electronic ballast s, capacitors are used in the PFC and output stage of the circuit design. In electronic ballasts, capacitors are also used in the DC Filter stage of the electronic circuit. One way to improve the efficiency of each portion of the circuit is to use capacitors with low effective series resistance (ESR). Capacitors with a low ESR are also more reliable because they are cooler than capacitors with a higher ESR.

Transistors: In electronic ballasts, transistors are used in both the power factor correction and the DC-AC inverter portion of the circuit. The transistor dissipa tes energy due to its drain-tosource resistance (R DS_ON ) when the current flows through the transistor to the transformer. Using transistors with low R DS_ON can reduce this loss. For example, the efficiency of electronic ballast’s bipolar transistors can be improved by using metal-ox ide-semiconductor field-effect transistors (MOSFETs), a transistor w ith a lower drain-to-source resistance.

3.3.4.5 Improved Circuit Design

Another method of increasing the efficiency of both magnetic and el ectronic ballasts is to improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout technology, integrated circuits, improved star ting method, and synchr onous rectification.

Cathode Cutout : Both rapid start and programmed st art ballasts provide heat to the filament while starting a lamp. As discussed in section 3.3.3.1, providing filament power while starting the lamp can increase its lifetime. Removing the power provided to the filament after the lamp has been started using an electronic circuit will increase the efficiency of both programmed start and rapid start ballasts. Rem oving this power can reduce the power the ballast consumes by as much as 2 watts per lamp.

Integrated Circuits : In certain cases, a ballast’s efficiency can be improved by substituting integrated circuits for discrete components. For example, some ballasts use bipolar transistors in a resonant half-bridge self-oscillating circuit to convert incoming DC to AC. The efficiency of this circuit can be improved by s ubstituting the components in that circuit with an integrated circuit. 26

Starting Method : RS and PS ballasts are inherently less efficient than IS ballasts, which use extra power to provide filame nt power to the ballast to increase its lifetime. Although these ballasts can cut out the filament power during lamp operation (using the cathode cutout technology option discussed above), the extra circuit to remove this power uses some amount of

power.

DOE only considered starting method as a t echnology option in case of the migration from RS to IS ballasts. DOE’s research indicates that IS ballasts are common replacements for

n A Schottky diode is a metal semiconductor diode with a smaller voltage drop than a conventional diode. Schottky diodes therefore consume less power.

3-29RS ballasts, and though the lamp lifetime is sometimes lower in IS ballasts than RS ballasts, it does not seem to be significant enough to affect consumer utility. As discussed in section 3.3.3.1, lamp lifetime in IS ballasts is approximately 25 percent less compared to RS ballasts when operated on a 3-hour start. Howeve r, lamps operated on RS ballast s have the same lifetime as lamps operated on IS ballasts when operated on short start cycles. This is typical when ballasts are used with occupancy sensors to save energy. Conversely, the lifetime of a lamp that operates on a PS ballast with occupa ncy sensors can be as much as three times longer than the lifetime of a lamp that operates on an IS or RS ballasts. Because IS ballasts have more limited utility as replacements for PS ballasts, IS ballasts are not considered a technology option for improving the efficiency of PS ballasts.

3.4 PRODUCT CLASSES

When evaluating and establishing energy conservation standards, DOE divides covered products into classes by the type of energy used , capacity, or other performance-related features that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C. 6295(q)) DOE then conducts its analysis and cons iders establishing or amending standards to provide separate standard levels for each product class. DOE applied the criteria of 42 U.S.C. 6295(q) to fluorescent lamp ballast s to develop product classes for this preliminary TSD. This section describes the pro duct classes DOE considers for this rulemaking.

In amending EPCA, NAECA 1988 established ei ght product classes for fluorescent lamp ballasts (Table 3.4.1).

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp

Ballasts
Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F40T12 Lamp 120 40

277 40

Two F40T12 Lamps 120 80

277 80

Two F96T12 Lamps 120 150

277 150

Two F96T12 HO Lamps 120 220

277 220

In further amendments to EPCA, EPACT 2005 established an additional eight product classes for fluorescent lamp ballasts (Table 3.4.2).

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp

Ballasts
Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F34T12 Lamp 120 34

277 34

Two F34T12 Lamps 120 68

277 68 Two F96T12/ES Lamps 120 120

3-30277 120

Two F96T12 HO/ES Lamps 120 190

277 190

In addition to the lamps and lamp ballasts id entified in Table 3.4.1 and Table 3.4.2, the fluorescent lamp ballast market today includes ballasts that operate smaller diameter lamps such as T8 and T5 lamps (section 3.3.1). These fluor escent lamp-and-ballast systems are gaining in market share, whereas T12 systems are becomi ng less popular and losing market share. This market shift is expected to accelerate in 2010, when the exclusion from the standard levels established by the 2000 Ballast Rule and EPAC T 2005 for replacement ballasts will expire. The standard levels established by the 2000 Balla st Rule and EPACT 2005 for fluorescent lamp ballasts are difficult to meet using magnetic ballast technology. Becau se magnetic ballasts comprise the large majority of T12 ballast sales, DOE believes that when the standards take effect, there will be an increase in shipments of electronic ballasts that operate T8 and T5 lamps.

Because of these market changes and because DOE is anticipating expanding its scope of covered product for fluorescent lamp ballasts, DOE is considering amending the product classes for these ballasts. The following sections summarize all of the factors that DOE considered as potential determinants of product class. In general, when consid ering the characteristics below, DOE considered three main factors as affecting consumer utility: (1) the lumen package of the lamp-and-ballast system; (2) the physical constrai nts of the lamp-and-ballast system; and (3) the use of the ballast in an application for which othe r ballasts are either not suitable. When referring to efficiency, DOE is referring to BEF.

3.4.1 Lamp Length

The fluorescent ballasts considered for coverage are designed to operate lamps with lengths of four or eight feet. Because BEF is a function of ballast input power, and input power is highly dependent on the length of the lamp operated by the ballast, all else being equal, a ballast operating a shorter lamp generally has a higher BEF than the same ballast operating a longer lamp. Furthermore, because consumers are often physically constrained by their building ceiling layout, systems operating 8-foot and 4-foot lamp s are not always substitutable for each other. Therefore, DOE believes that lamp length affects consumer utility. Given the impact on BEF and utility, DOE is establishing separate product classes for ballasts that operate different lamp lengths.

3.4.2 Lamp Diameter

T8 lamp-and-ballast systems are generally more efficien t than T12 lamp-and-ballast systems and T8 ballasts generall y have higher BEFs than T 12 ballasts. DOE does not, however,
believe that this alone justifies creating separate product classes for ballast s that operate T8 and T12 lamps. Consistent with its approach in past rulemakings (74 FR 16920, 16937 (April 13, 2009)), DOE maintains that T8 lamp-and-ballast systems are commonly used as substitutes for T12 lamp-and-ballast systems, suggesting that there is no unique utility associated with T12 systems. Manufacturer marketing literature and general guidance on lighting design and installation often promote T8 lamp-and-ballast systems as energy saving substitutes for T12 systems. Such substitute systems often have the same lengths and bases, offer comparable lumen

3-31output, and can fit within the same fixtures. DOE recognizes that lamp diameter may affect ballast BEF, but the utility provided to the end-user is comparable and/or equivalent. Therefore,
DOE has decided to include ballast s that operate T8 and T12 lamp s in the same product class.

However, DOE has decided to establish a separate product class for ballasts that operate T5 lamps. All else bei ng equal, 4-foot T5 balla sts generally have lower input power (due to the lower wattage of the test lamp), and therefore higher BEF than T8 or T12 ballasts. These systems, though often used to replace T8 and T12 systems, are not viable substitutes in all applications. Because T5 lamps have similar total lumen output as T8 and T12 lamps over a significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright for use in direct lighting fixtures. To prevent eliminating lamps appropriate for direct lighting applications, DOE has tentatively decided to establish separate product clas ses for ballasts that operate T5 lamps.

3.4.3 Ballast Factor

The ballasts considered for coverage in this rulemaking are available with a range of ballast factors. In applying DOE’s proposed am ended active mode test procedure (as presented in the active mode test procedure NOPR), DOE found that ballasts with high or low ballast
factors have lower BEFs than ballasts with a normal ballast factor. o Furthermore, ballast factor is typically used to adjust the lumen package of a lamp-and-ballast system. Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a consumer. DOE has observed that consumers tend to use systems with different lumen packages for different applications. For example, low BF ballasts (with smaller lumen packages) are commonly used in applications where less light is desired. In consideration of the effect that ballast factor has on both BEF and consumer utility, DOE has decided to establish separate product classes for low, normal, and high ballast factor ballasts.

3.4.4 Lumen Package

Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts that run the lamps at high currents. For exampl e, 8-foot RDC HO lamps and 4-foot miniature bipin (MiniBP) HO lamps tend to operate at higher currents than 8-foot SP slimline lamps and 4­ foot MiniBP standard output (SO) lamps, respec tively. This difference in operating design increases the quantity of light per unit of lamp length.

High output lamps generally operate at high er wattages than comparable (same length, diameter) standard output lamps. For example, for 4-foot miniature bipin lamps, the most common high output lamp has a wattage of 54 W whereas the most common standard output lamp has a wattage of 28 W. This difference in lamp wattage means that ballasts that operate high output lamps generally have lower BEFs than ballasts that operate comparable standard output lamps.

o DOE classifies a low BF as less than or equal to 0.78, a normal BF as greater than 0.78 but less than 1.1, and a high BF as greater than or equal to 1.1.

3-32In addition, consumers tend to use systems w ith different lumen packages for different applications. For example, high-lumen-output syst ems may be installed in certain high-ceiling or outdoor applications where large quantities of lightare needed. Alternatively, standard-lumenoutput systems might be installed in lower-ceiling applications such as offices or hospitals, where, for example, distance between the light source and the illuminated surface is not as large. Notable differences in the appli cation of ballasts designed to op erate SO lamps versus HO lamps indicate a difference in utility.

Therefore, given the observed utility distinctions and notable efficacy differences, DOE is establishing separate produc t classes for ballasts that opera te SO lamps a nd ballasts that operate HO lamps.

3.4.5 Maximum Number of Lamps Operated

Ballasts are designed to operate a certain maximum number of lamps. For example, ballasts designed to operate 4-foot MBP lamps ca n operate as few as one or as many as six lamps. DOE found that BEF decreased with each additional lamp operated by a ballast. This is because additional lamps increase the ballast’s input power, which appears in the denominator of Equation 3.1. DOE believes that the ability to operate different maximum number of lamps offers the consumer a distinct utility because this capacity affects the sp ace required by fixtures (a four-lamp fixture requires more physical spa ce than one-lamp fixture). Given this impact on both BEF and consumer utility, DOE has decided to establish separate product classes based on
the maximum number of la mps a ballast operates.

3.4.6 Starting Method

As discussed in section 3.3.3.1, the starting me thod of a ballast affects its efficiency. RS and PS ballasts are inherently less efficient than IS ballasts as these ballasts use extra power to provide filament power to the lamp to increase the lamp’s lifetime. Although these ballasts can cut out the filament power durin g lamp operation (using the ca thode cutout technology option discussed above), the extra circuit to remove this power uses some amount of power.

Whereas RS and IS ballasts are commonly used as substitutes for each other, programmed start ballasts are not. PS ballasts are commonly used in conjunction with occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. DOE’s research indicates that use of instant start ballasts with occupancy sensors can result in an 80 percent reduction in lamp lifetime. Because of the application in which they are used, programmed start ballasts offer the user a distinct utility. In consideration of its affect on both BEF and utility, DOE has tentatively decided to establish separate product classes for programmed start ballasts

3.4.7 Input Voltage

Fluorescent lamp ballasts are available at a variety of input voltages, but the two most common input voltages are 120V and 277V. In examining test data between ballasts that operate only at 120V and ballasts that ope rate only at 277V, DOE found that there was not a significant

3-33difference in BEF. In addition, in its research, DOE found that the ballasts with the highest BEFs allowed operation at both 120V and 277V. For this reason, DOE does not consider input voltage
to be a factor in de termining product class.

3.4.8 Universal Voltage

Universal voltage ballasts can operate at multiple input voltages ( e.g., 120V and 277V). To accommodate multiple voltage s, these ballasts contain more components than dedicated voltage ballasts (ballasts that operate only one input voltage). Universal ballasts are growing in popularity because they can be used in multiple applications and serv e as replacements for multiple ballasts. This allows distributors to stock fewer types of ballasts and allows contractors to keep fewer on hand for maintenance. Consolid ation of products create s economies of scale for manufacturers, which can lead to reduced produc tion costs. DOE compared test data between ballasts that operate only at one voltage and universal voltage ballasts operating at that voltage and found that there was not a significant differe nce in BEF between the two. Therefore, DOE does not consider operating at multiple voltages to be a factor in determining product class.

3.4.9 Residential Ballasts

Separate minimum power factor and electromagnetic interference requirements exist for residential as compared to commercial ballasts. Residential ballasts have more stringent (or lower maximum allowable) electromagnetic interference requirements than commercial ballasts; they also have less stringent (or lower mi nimum allowable) power factor requirements p . These differing requirements between co mmercial and residentia l products result in differing BEFs. In addition to their effect on BEF, these two requirements offer the consumer a unique utility in that they serve distinct market sectors and applica tions. Therefore, DOE has tentatively decided to establish a separate product cl asses for ballasts that operate in the resi dential sector and
commercial sector.

3.4.10 Sign Ballasts

Ballasts that are designed for use in cold te mperature outdoor signs have slightly different characteristics than those ballasts that operate in the commercial or residential sectors. First, sign ballasts are designed to operate in cold temperature environm ents – as low as -20 °F. Second, sign ballasts are classified by the total length (in feet) of lamps they can operate as well as the total number of lamps. To operate in cold temper ature environments and to be able to handle numerous lamp combinations, sign ballasts c ontain more robust components compared to ballasts in the commercial sector that operate 8-foot HO lamps and therefore sign ballasts are inherently less efficient. Regular 8-foot HO ballasts cannot be used as substitutes due to their inability to operate in cold temperature environments. For this reason, DOE believes cold temperature sign ballasts offer the consumer a distinct utility. Therefore, DOE has established a separate product class for cold temperature sign ballasts.

p ANSI C82.77-2002 requires residential ballasts to have a minimum power factor of 0.5 and commercial ballasts to have a minimum power factor of 0.9.

3-343.4.11 Product Classes

For all the reasons discussed above, DOE is considering the ballast product classes listed in Table 3.4.3. Although ballasts are designed to operate multiple wattages of lamps, energy conservation standards will only be specified for the most common lamp wattage in each product class. In addition, energy conservation standards will only be specified while a ballast is operating the maximum number of lamps it is designed to operate. Chapter 5 of this preliminary TSD provides detail on the selection of candidate st andard levels.

Table 3.4.3 Preliminary Product Classes for Fluorescent Lamp Ballasts

Number of Lamps Ballast and Lamp Type Starting

Method Ballast

Factor One Two Three Four Five Six

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12 IS and RS

Low 13 14 15 16 17 18

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30 Four-Foot MBP,
and Two-Foot UShaped

PS

Low 31 32 33 34 35 36

High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A Four-Foot T5
MiniBP SO All

Low 41 42 N/A N/A N/A N/A

Four-Foot T5
MiniBP HO All All 43 44 45 46 N/A N/A

High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A Eight-Foot SP
Slimline All

Low 51 52 N/A N/A N/A N/A

IS and RS All 53 54 N/A N/A N/A N/A Eight-Foot RDC

HO PS All 55 56 N/A N/A N/A N/A

IS and RS All 57 58 59 60 N/A N/A Residential Ballast,

Four-Foot MBP,
and Two-Foot UShaped PS All 61 62 63 64 N/A N/A

Sign Ballast All All 65 66 67 68 69 70

3-35REFERENCES

1 Ron Runkles. NEMA Premium Effici ency Electronic Ballast Program. NEMA Lighting Systems

Division . 2007. (Last accessed June 29, 2009). < http://www.cee1.org/cee/mtg/09

­ 07ppt/Wednesday/9%20NEMA_CEE%20Presentation.ppt >.

2 National Electrical Manufacturers Association. Lighting Systems Division . 2002. (Last accessed June 29, 2009). < http://www.nema.org/prod/lighting/upload/LightingSystemsDivision.pdf >.

3 U.S. Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes. 2008. (Last accessed June 29, 2009.)

< http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf >.

4 California Energy Commission. 2007 Appliance Efficiency Regulations . 2007. (Last accessed June 29, 2009). < http://www.energy.ca.gov/2007publications/CEC-400-2007-016/CEC-400

­ 2007-016-REV1.PDF >.

5 Natural Resources Canada, Office of Energy Efficiency. Proposed Regulations for Fluorescent Lamp Ballasts . 2001. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/Fluorescent.cfm?attr=0>.

6 Natural Resources Canada, Office of Energy Efficiency. Recent Amendments . 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/amendment6_part2.cfm?attr=0>.

7 Natural Resources Canada, Office of Energy Efficiency. Regulations Amending the Canada 's Energy Efficiency Regulations. 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/amendment9_part1.cfm?attr=0 >.

8 Natural Resources Canada, Office of Energy Efficiency. Canadian Energy Efficiency Regulations for Fluorescent Lamp Balla sts. 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/product/fluorescent_lamp_ballasts.cfm?attr=0>.

9 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Federal Energy Management Program. How to Buy Energy-Efficient Fluorescent Ballasts . 2000. (Last accessed June 29, 2009). < http://www1.eere. energy.gov/femp/pdfs/ballast.pdf >

10 Consortium for Energy Efficiency. CEE High Performance T8 Specification . 2008. (Last accessed June 29, 2009). < http://www.cee1.org/com/com-lt/com-lt-specs.pdf >.

11 Consortium for Energy Efficiency. CEE Reduced-Wattage T8 Specification . 2007. (Last accessed June 29, 2009). < http://www.cee1.org/com/com-lt/lw-spec.pdf >.

12 National Electrical Manufacturers Association. NEMA Premium Electronic Ballast Program

. (Last accessed June 29, 2009).

3-36< http://www.nema.org/gov/energy/efficiency/upload/nema_premium_electronic_ballast_progra m.pdf >.

13 National Electrical Manufacturers Association. NEMA Premium Motor Results Show Increase
in Sales. 2004. (Last accessed June 29, 2009.) < http://www.nema.org/media/pr/20041104a.cfm >.

14 U.S. Environmental Protection Agency and U.S. Department of Energy. About ENERGY STAR. (Last accessed June 29, 2009).

< http://www.energystar.gov/index.cfm?c=about.ab_index >.

15 U.S. Environmental Protection Agency and U. S. Department of Ener gy. Residential Light Fixtures Key Product Criteria. (Last accessed June 29, 2009).

< http://www.energystar.gov/index.cfm?c=fixtures.pr_crit_light_fixtures >.

16 Northeast Energy Efficiency Partnership. Commercial Buildings and Technologies Initiative

. 2009 (Last accessed June 29, 2009) <http:// www.neep.org/initiatives/buildings.html>

17 Efficiency Vermont. High Performance T8 Eligible Products & Fact Sheet . (Last accessed June 29, 2009.) < http://www.efficiencyvermont.com/stella/filelib/2008_HPT8FactSheet_FINAL1207.pdf >.

18 Efficiency Vermont. 2009 Rebate Applica tion. 2009. (Last accessed June 29, 2009).

< http://www.efficiencyvermont.com/stella/filelib/2009_LightingForm_FINAL.pdf >.

19 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics . Current Industrial Reports, Fluorescent Lamp Ballasts, MQ335C . 2008. (Last accessed June 29, 2009).

< http://www.census.gov/mcd />

20 National Electrical Manufacturers Association. 2006. No. 12 at p. 7. This written comment, document number 12, is available in Dock et # EE–2006–STD–0131. For more information, contact Brenda Edwards-Jones at (202) 586-2945.

21 Illuminating Engineering Society of North America. 2000. The IESNA Lighting Handbook: Reference and Application. 9th Edition. M.S. Rea. New York. 2000.

22 Philips. Smart T Bay . (Last accessed June 29, 2009).

< http://www.smartlightingtechnology.com/pdf/SmarTBay_608.pdf

.

23 Osram Sylvania. Ballast-Lamp Technology Update . 2000. (Last accessed June 29, 2009).

< http://www.lighthouseconsultingllc.com/Osram_S ylvania/Sylvania%20Ballast%20update.pdf >.

24 Osram Sylvania. Ballast Technology Applications and Specifications Guide . 2009. (Last accessed June 29, 2009.) < http://content.sylvania.com/app/display.aspx?docid=003699308 >.

3-3725 National Lighting Product Information Program. Lighting Answers: Electromagnetic Interference Involving Fl uorescent Lighting Systems . 1995. (Last accessed June 29, 2009).

< http://www.lrc.rpi.edu/programs/NLPIP/lightinganswers/pdf/view/LAEMI.pdf >.

26 International Rectifier. International Rectifier Introduces Robust Self-Oscillating Electronic Ballast Lighting Control IC . 2009. (Last accessed June 29, 2009.) < http://www.irf.com/whats

new/nr051122.html >.

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