CHAPTER 2. ANALYTICAL FRAMEWORK 

TABLE OF CONTENTS 

2.1	 INTRODUCTION ........................................................................................................... 2-1
 

2.2	 BACKGROUND ............................................................................................................. 2-3
 

2.2.1	 History of Standards Rulemakings for Fluorescent Lamp Ballasts and Regulatory
 

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

2.2.2	 Test Procedure ..................................................................................................... 2-5
 

2.2.3	 Standby and Off Mode Energy Consumption...................................................... 2-8
 

2.3	 SCOPE OF COVERAGE ................................................................................................ 2-9
 

2.3.1 Current Scope of Ballast Energy Conservation Standards .................................. 2-9
 

2.3.2 Additional Fluorescent Lamp Ballasts............................................................... 2-10
 

2.3.3 Rationale for Coverage ...................................................................................... 2-10
 

2.3.4 Analysis of Individual Ballast Types................................................................. 2-11
 

2.3.5 Summary............................................................................................................ 2-18
 

2.4	 MARKET AND TECHNOLOGY ASSESSMENT ...................................................... 2-19
 

2.4.1	 Market Assessment ............................................................................................ 2-20
 

2.4.1.1 Manufacturers of Fluorescent Lamp Ballasts ........................................ 2-20
 

2.4.1.2 Product Classes ...................................................................................... 2-21
 

2.4.1.3 Ballast Shipments................................................................................... 2-26
 

2.4.1.4 Regulatory and Non-Regulatory Programs............................................ 2-27
 

2.4.2 Technology Assessment..................................................................................... 2-28
 

2.5 SCREENING ANALYSIS ............................................................................................ 2-30
 

2.5.1 Technology Options Screened Out .................................................................... 2-31
 

2.6 ENGINEERING ANALYSIS........................................................................................ 2-32
 

2.6.1 Preliminary Engineering Analysis Approach .................................................... 2-33
 

2.6.2 Representative Product Classes ......................................................................... 2-36
 

2.6.3	 Baseline Ballasts and Candidate Standard Levels Analyzed............................. 2-37
 

2.6.4	 Results................................................................................................................ 2-40
 

2.6.5	 Scaling Between Product Classes ...................................................................... 2-44
 

2.6.6	 Price Analysis .................................................................................................... 2-44
 

2.6.7	 Other Key Issues................................................................................................ 2-47
 

2.7	 ENERGY USE AND END-USE LOAD CHARACTERIZATION ............................. 2-48
 

2.8	 MARKUPS ANALYSIS ............................................................................................... 2-49
 

2.9	 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .................................. 2-50
 

2.10	 SHIPMENTS ANALYSIS ............................................................................................ 2-52
 

2.11	 NATIONAL IMPACT ANALYSIS.............................................................................. 2-52
 

2.11.1 National Energy Savings Analysis..................................................................... 2-53
 

2.11.2 Net Present Value Analysis ............................................................................... 2-53
 

2.11.3 Efficiency Scenarios and Trends ....................................................................... 2-54
 

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS .......................................................... 2-54
 

2.13 MANUFACTURER IMPACT ANALYSIS.................................................................. 2-55
 

2.13.1 Sources of Information for the Manufacturer Impact Analysis......................... 2-55
 

2.13.2 Industry Cash-Flow Analysis............................................................................. 2-56
 

2.13.3 Manufacturer Subgroup Analysis ...................................................................... 2-56
 

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2.13.4 Competitive Impacts Assessment ...................................................................... 2-56
 

2.13.5 Cumulative Regulatory Burden ......................................................................... 2-56
 

2.13.6 Preliminary Results for the Manufacturer Impact Analysis .............................. 2-57
 

2.13.7 Impacts on Profitability...................................................................................... 2-57
 

2.13.8 Product Conversion Costs/Diminishing Returns to Consumers ........................ 2-57
 

2.13.9 Product Innovation............................................................................................. 2-58
 

2.14 UTILITY IMPACT ANALYSIS................................................................................... 2-58
 

2.15 EMPLOYMENT IMPACT ANALYSIS....................................................................... 2-59
 

2.16 ENVIRONMENTAL ASSESSMENT .......................................................................... 2-59
 

2.16.1 Carbon Dioxide.................................................................................................. 2-59
 

2.16.2 Sulfur Dioxide.................................................................................................... 2-60
 

2.16.3 Nitrogen Oxides................................................................................................. 2-60
 

2.16.4 Mercury.............................................................................................................. 2-61
 

2.16.5 Particulate Matter............................................................................................... 2-61
 

2.16.6 Monetization of Emissions Reduction Benefits................................................. 2-62
 

2.17 REGULATORY IMPACT ANALYSIS ....................................................................... 2-63
 

LIST OF TABLES 

TABLE 2.4.1 PRODUCT CLASSES FOR FLUORESCENT LAMP BALLASTS ... 2-26
 

TABLE 2.4.2 BALLAST MARKET SHARE IN 2005 ............................................... 2-27
 

TABLE 2.4.3 FLUORESCENT LAMP BALLAST TECHNOLOGY OPTIONS...... 2-30
 

TABLE 2.6.1 REPRESENTATIVE AND SCALED PRODUCT CLASSES FOR
 

FLUORESCENT LAMP BALLASTS.......................................................................... 2-37
 

TABLE 2.6.2 BASELINE BALLASTS FOR TWO-LAMP FOUR-FOOT AND TWOFOOT U-SHAPED MBP IS & RS NORMAL BF PRODUCT CLASS....................... 2-39
 

TABLE 2.6.3 SUMMARY OF PROPOSED CANDIDATE STANDARD LEVELS
 

FOR REPRESENTATIVE FLUORESCENT LAMP BALLAST PRODUCT CLASSES

 2-40
 

TABLE 2.6.4 TWO-LAMP FOUR-FOOT MBP RS AND IS PRODUCT CLASS WITH 

F32T8 BASELINE......................................................................................................... 2-42
 

TABLE 2.6.5 TWO-LAMP FOUR-FOOT MBP RS AND IS PRODUCT CLASS WITH 

F34T12 BASELINE....................................................................................................... 2-43
 

LIST OF FIGURES 

FIGURE 2.6.1 FULL PRODUCTION COSTS......................................................................... 2-45
 

FIGURE 2.8.1 BALLAST DISTRIBUTION CHANNELS..................................................... 2-49
 

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EERE-2007-BT-STD-0016 COMMENT 25
 

CHAPTER 2. ANALYTICAL FRAMEWORK
 

2.1 INTRODUCTION 

This chapter describes the analytical framework that the U.S. Department of 

Energy (DOE) is using to develop energy conservation standards for fluorescent lamp 

ballasts, including a description of the methodology, the analytical tools, and 

relationships among the various analyses that are part of this rulemaking. Chapter 2 also 

provides an overview of the preliminary activities DOE conducted and discusses the 

comments it received. In addition, chapter 2 provides additional detail on key issues 

identified in the executive summary. Finally, chapter 2 provides citations and crossreferences to the other chapters of the preliminary technical support document (TSD) that 

address DOE's analytical approach, inputs, and findings. 

The analyses presented in this preliminary TSD include: 

•	 a market and technology assessment that characterizes the fluorescent lamp 

ballast market, and reviews technologies and designs that improve ballast 

efficiency; 

•	 a screening analysis that reviews technology options to improve ballast efficiency 

and considers them according to four prescribed screening criteria; 

•	 an engineering analysis that determines the manufacturer selling prices (MSPs) 

associated with more energy efficient fluorescent lamp ballasts by estimating the 

manufacturing production cost (MPC) and applying a manufacturer markup; 

•	 an energy use characterization that generates energy use estimates for fluorescent 

lamp ballasts; 

•	 a markup analysis that converts average MSPs to consumer installed prices; 

•	 a life-cycle cost (LCC) analysis that calculates, at the consumer level, the 

discounted savings in operating costs throughout the estimated average life of the 

ballast, compared to any increase in the installed costs likely to result directly 

from imposition of the standard; 

•	 a payback period (PBP) analysis to estimate the amount of time it takes 

consumers to recover the higher purchase expense of more energy efficient 

ballasts through lower operating costs; 

•	 a shipments analysis that estimates shipments of fluorescent lamp ballasts over 

the time period examined in the analysis; 

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•	 a national impact analysis (NIA) that assesses the aggregate impacts at the 

national level of potential energy conservation standards as measured by the net 

present value (NPV) of total consumer economic impacts and national energy 

savings (NES); and 

•	 a preliminary manufacturer impact analysis (MIA) that begins to evaluate the 

effects on manufacturers that may result from a new efficiency standard. 

DOE may revise any of its analyses based on comments and new information 

received. The analyses DOE will perform in the subsequent notice of proposed 

rulemaking (NOPR) stage include those listed below: 

•	 an LCC subgroup analysis that evaluates the economic impacts on identifiable 

groups of customers of fluorescent lamp ballasts, including various categories of 

ballast purchasers or owners who may experience disproportionate impacts from a 

national energy conservation standard; 

•	 a manufacturer impact analysis that estimates the financial impact of standards on 

ballast manufacturers and calculates impacts on competition, employment at the 

manufacturing plant, and manufacturing capacity; 

•	 a utility impact analysis that estimates the effects of proposed standards on the 

installed capacity and the generating base of electric utilities; 

•	 an employment impact analysis that estimates the impacts of standards on net jobs 

eliminated or created in the general economy as a consequence of increased 

spending on the installed price of ballasts and reduced customer spending on 

energy; 

•	 an environmental assessment to provide estimates of the effects of amended 

energy conservation standards on emissions of carbon (CO2), sulfur dioxide 

(SO2), nitrogen oxides (NOX), and mercury (Hg); and 

•	 a regulatory impact analysis (RIA) that presents major alternatives to proposed 

standards that may achieve comparable energy savings at a reasonable cost. 

DOE developed this analytical framework and documented its findings in the 

Energy Conservation Standards Rulemaking Framework Document for Fluorescent Lamp 

Ballasts (January 14, 2008).a

 DOE presented the analytical approach to interested parties 

during a public meeting held on February 6, 2008. 

a

 The framework document is available at 

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

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In response to the publication of the framework document and the framework 

public meeting, DOE received comments from interested parties on its analytical 

approach. This chapter summarizes the key comments DOE received, describes DOE’s 

responses, and summarizes any significant changes in the analytical approach made since 

DOE published the framework document. Lastly, in the executive summary of the 

preliminary TSD, DOE identifies issues on which it seeks public comment, each of which 

is explained in the sections below. 

2.2	 BACKGROUND 

2.2.1	 History of Standards Rulemakings for Fluorescent Lamp Ballasts and 

Regulatory Authority 

Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) in the 

National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Pub. 

L.100-357, established energy conservation standards for fluorescent lamp ballasts.b

 (42 

United States Code (U.S.C.) 6295(g)(5)) These same amendments also required that DOE 

(1) conduct two rulemaking cycles to determine whether these standards should be 

amended; and (2) determine for each rulemaking cycle whether the standards for 

fluorescent lamp ballasts should be amended to be applicable to additional fluorescent 

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

On September 19, 2000, DOE published a final rule in the Federal Register (FR) 

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

conservation standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”).c 

65 FR 56740. This rulemaking established a consensus standard, representing an 

agreement between the fluorescent lamp ballast industry and energy efficiency advocacy 

organizations. The standard levels adopted replaced the ballast efficacy factors 

promulgated in NAECA 1988 for certain fluorescent lamp ballasts. These standards 

eliminated certain “magnetic” ballasts, which operate lamps at line frequency (60 Hertz) 

and are less efficient than electronic ballasts, which operate lamps at high frequency.d A 

table of the codified standards can be found in appendix 3A of the preliminary TSD 

under 10 Code of Federal Regulations (CFR) 430.32(m)(3). 

b

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

sectors, the consumer products section of EPCA grants authority to DOE to cover and regulate this product. 

In Title III of EPCA, “Part A – Energy Conservation Program for Consumer Products Other Than 

Automobiles” includes a range of consumer products, some which may be classified for use primarily in 

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

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

lamps, fluorescent lamp ballasts, and urinals. “Part A-1 – Certain Industrial Equipment,” includes products 

that are used primarily in the commercial and industrial sectors, such as electric motors and pumps, as well 

as packaged terminal air conditioners and heat pumps. 

c

 The final rule is available at 

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

 The standard level eliminated magnetic ballasts that operate one and two nominally 40W medium bipin 

lamps (F40T12) and for ballasts that operate two nominally 75W 8-foot T12 single pin slimline lamps 

(F96T12). 

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Congress then promulgated new energy conservation standards for certain 

fluorescent lamp ballasts under the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 

109-58. (EPACT section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)) On October 18, 

2005, DOE published a final rule in the Federal Register codifying those new fluorescent 

lamp ballast standards into the Code of Federal Regulations at 10 CFR 430.32(m)(5). 70 

FR 60407. These standards established minimum efficiency requirements for “energy 

saver” versions of full-wattage ballasts, such as the F34T12 ballast. A table of the 

standards promulgated by EPACT 2005 can be found in appendix 3A in the preliminary 

TSD. 

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

amended, include ballasts that are designed to operate 

• one and two nominally 40 watt (W) and 34W 4-foot T12 medium bipin 

(MBP) lamps (F40T12 and F34T12); 

•	 two nominally 75W and 60W 8-foot T12 single pin (SP) slimline lamps 

(F96T12 and F96T12/ES); and 

•	 two nominally 110W and 95W 8-foot T12 recessed double contact high 

output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 

277 volts with an input current frequency of 60 hertz. 

10 CFR 430.32(m). 

The following ballasts are excluded from current regulations: 

•	 ballasts designed for dimming to 50 percent or less of its maximum output; 

•	 ballasts designed for use with two F96T12HO lamps at ambient temperatures 

of -20 degrees Fahrenheit (°F) or less and for use in an outdoor sign or ballasts 

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

20°F or less and for use in an outdoor sign;e 

•	 ballasts with a power factor of less than 0.90 and designed and labeled for use 

only in residential building applications; and 

• replacement ballasts as defined in paragraph (m)(4)(ii).f 

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.110-140), which made numerous amendments to EPCA. 

EISA 2007 did not amend standards for fluorescent lamp ballasts. Instead, it directed 

e

 Note that in 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly 

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

with two F96T12HO/ES lamps at ambient temperatures of 20 degrees F or less and designated for use in an 

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

for ambient temperatures of negative 20 ° F or less. f

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

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

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

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

excluded. (10 CFR 430.32(m)(4)(ii)(A)) See appendix A for the exact language of the exclusion for 

replacement ballasts. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

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

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

published a NOPR for the standby and off mode test procedure on January 21, 2009. 74 

FR 3450. DOE is also directed to incorporate standby mode and off mode energy use in 

any amended (or new) standard adopted after July 1, 2010. (42 U.S.C. 6295(gg)(3)) 

Because this energy conservation standards rulemaking for fluorescent lamp ballasts will 

be completed in 2011, the requirement is applicable. 

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

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

whether the standards should apply to additional fluorescent lamp ballasts as stated under 

section 325(g)(7)(B) of EPCA. (42 U.S.C. 6295(g)(7)(B)) 

This rulemaking also addresses 42 U.S.C. 6295(gg)(3) in which DOE is directed to 

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

adopted after July 1, 2010 pursuant to 42 U.S.C. 6295(o). 

2.2.2 Test Procedure 

As mentioned above, DOE published a NOPR on January 21, 2009 to amend its 

test procedure for fluorescent lamp ballasts to incorporate a measure of standby mode and 

off mode energy consumption. 74 FR 3450.g In that NOPR, DOE proposed that 

fluorescent lamp ballasts do not operate in an off mode as defined by EISA 2007. (42 

U.S.C. 6291(gg)(1)(A)(ii)) DOE furthermore proposed that the only ballasts that 

consume power in a standby mode are those that are active components of lighting 

control systems, meaning the ballasts incorporate electronics that can receive a signal 

from a control system, and can respond to that signal by adjusting light output. 74 FR 

3450, 3452 (January 21, 2009). Thus, DOE proposed a test procedure to measure only 

standby mode energy consumption. Standby and off mode energy consumption is 

discussed in more detail in section 2.2.3. 

On February 6, 2008, DOE held a public meeting in Washington, DC, to discuss 

the framework document for the fluorescent lamp ballast energy conservation standards 

rulemaking. The comments from this meeting prompted DOE to initiate a separate 

rulemaking to revise the existing test procedure for active mode energy consumption. 

The section contains comments regarding the active mode test procedure that are also 

relevant to this energy conservation standards rulemaking. All other comments on the 

active mode test procedure can be found in the active mode test procedure NOPR. 

The National Electrical Manufacturers Association (NEMA) expressed concern 

that BEF measurements made in accordance with the current fluorescent lamp ballast test 

procedure (in appendix Q to subpart B of 10 CFR 430) can have a measurement 

uncertainty on the order of 5 percent, which is similar to the range of T8 ballast BEFs 

g

 EISA 2007 directed DOE to amend test procedures for fluorescent lamp ballasts to incorporate a measure 

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

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

observed on the market today. The measurement uncertainty would thus negatively affect 

DOE’s ability to set standards for ballasts. (NEMA, Public Meeting Transcript, No. 9 at 

pp. 11-12, 23, 35-36, 42, 56-58; NEMA, No. 11 at pp. 2, 6) NEMA stated that this level 

of measurement uncertainty comes from several sources, such as lamp manufacturing 

variations (as the test procedure requires photometric measurements), lamp filament 

heating, and differences between high-frequency and low-frequency ballasts. (NEMA, 

Public Meeting Transcript, No. 9 at pp. 26, 38-39, 43, 73-74, 76-77, 99, 124-125; NEMA, 

No. 11 at p. 6) Acuity Brands Lighting also commented that much of the marketplace 

does not use the BEF metric and may not have knowledge of it; the primary users of BEF 

values in ballast purchasing decisions are luminaire manufacturers. (Acuity Brands 

Lighting, Public Meeting Transcript, No. 9 at pp. 45-46) 

For these reasons, NEMA, the New York State Energy Research and Development 

Authority (NYSERDA), and a joint comment produced by the Appliance Standards 

Awareness Project (ASAP), the American Council for an Energy-Efficient Economy 

(ACEEE), the Alliance to Save Energy (ASE), the Natural Resources Defense Council 

(NRDC), the Northeast Energy Efficiency Partnerships (NEEP), and the Northwest 

Power and Conservation Council (NPCC) all recommended that DOE consider changing 

the metric from BEF to an alternate metric. (Joint Comment, No. 12 at p. 1) 

NEMA expressed support for a generic metric that would establish minimum 

efficiency standards for ballasts that do not have such standards. (NEMA, No. 11 at p. 3) 

The Joint Comment stated that any alternate metric implemented by DOE should account 

for all power loads served by the ballast, including arc current, cathode power, and 

standby power consumption. (Joint Comment, No. 12 at p. 1) NEMA suggested ballast 

efficiency (BE), which has lower measurement uncertainty (on the order of 1 to 2 

percent) and is the most appropriate metric for instant start ballasts. (NEMA, Public 

Meeting Transcript, No. 9 at pp. 25-27, 36-38, 76-77, 100-101; NEMA, No. 11 at p. 2) 

NEMA, NYSERDA, and the Joint Comment recommended the investigation of relative 

system efficiency (RSE) as a metric. (NYSERDA, Public Meeting Transcript, No. 9 at 

pp. 27-28; NEMA, Public Meeting Transcript, No. 9 at pp. 33, 100; Joint Comment, No. 

12 at pp. 6-7) Neither the BE nor the RSE metric would reflect individual lamp 

characteristics; thus, these metrics could be used to compare ballasts that operate 

different lamp types. NYSERDA supported a metric that could be normalized to allow 

for comparison among different ballast types. (NYSERDA, Public Meeting Transcript, 

No. 9 at p. 75) 

DOE understands the concerns expressed by interested parties about the BEF 

measurement method in the current fluorescent lamp ballast test procedure. DOE agrees 

that a number of factors, including the manufacturing variability of lamps used during 

ballast testing, can interact to produce measurement uncertainty. As discussed in the 

active mode test procedure NOPR, DOE is proposing to use the ballast efficiency metric 

to reduce measurement variation, and then to use transfer equations so that BEF can be 

reported for consistency with 42 U.S.C. 6295(g)(5), (g)(8). 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

DOE also understands the importance of the ability to fully characterize all power 

loads served by a fluorescent lamp ballast, as suggested by the Joint Comment. DOE 

believes that BEF does capture all power modes listed by the Joint Comment (arc current 

and cathode power). DOE does not believe, however, that it is feasible to incorporate 

standby power into the BEF metric. See section 2.2.3 for further discussion of this issue. 

NEMA suggested that if DOE cannot change the metric from BEF in the test 

procedure, DOE should develop a test procedure that requires the measurement of an 

alternate metric unrelated to lamp lumen output, along with a correlation to BEF that 

takes lamp filament effects into account. (NEMA, Public Meeting Transcript, No. 9 at pp. 

32, 37-38) DOE is investigating the implementation of an alternate metric and a set of 

correlation functions so that BEF values can be produced reliably and accurately during 

ballast testing. 

NEMA commented that it is studying the measurement uncertainty of BE through 

ballast testing and may eventually encourage the industry-wide usage of BE. Lamp 

manufacturers as well as technical coordinators from the American National Standards 

Institute (ANSI) are involved, and NEMA has already initiated the usage of BE in its 

Premium Ballast Program. NEMA invited DOE and other interested parties to participate 

in the investigation. (NEMA, Public Meeting Transcript, No. 9 at pp. 23-25, 32, 37-39, 

41-42, 45, 48-50, 53-55; NEMA, No. 11 at p. 3) ASAP encouraged DOE to partake in 

NEMA’s evaluation of a new metric. (ASAP, Public Meeting Transcript, No. 9 at pp. 47, 

49) DOE participated in NEMA’s technical committee on ballast efficiency to obtain 

additional data that DOE is now using to develop the active mode test procedure. 

Participants at the public meeting also discussed the lack of compliance and 

enforcement of efficiency standards. Two manufacturers, Acuity Brands Lighting and 

Osram Sylvania, stated that they have observed non-compliant ballasts that were labeled 

as compliant in the marketplace. (Acuity Brands Lighting, Public Meeting Transcript, 

No. 9 at pp. 88-89; Osram Sylvania, Public Meeting Transcript, No. 9 at p. 90) Acuity 

Brands Lighting suggested that DOE should share the legal responsibility for enforcing 

compliance with standards. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at 

pp. 88-89) 

Compliance with the fluorescent ballast standard has been required and 

enforceable since its effective year. Manufacturers, however, are not yet required to 

submit compliance certification reports under 10 CFR 430.62. Therefore, DOE is 

modifying reporting requirements for ballasts in the active mode test procedure NOPR. 

DOE believes that modifying these reporting requirements will aid in the certification and 

enforcement of energy conservation standards for ballasts. DOE requests comments on 

other ways that it can enhance the certification and enforcement procedures. 

More information about the active mode TP NOPR can be found on DOE’s 

website at 

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

_ballasts.html. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

2.2.3 Standby and Off Mode Energy Consumption 

EISA 2007, enacted December 19, 2007, requires DOE to amend test procedures 

to include standby mode and off mode energy consumption in the overall energy 

efficiency, energy consumption, or other energy descriptor for each covered product for 

which DOE’s current test procedures do not fully account for standby mode and off mode 

energy consumption. If that is technically infeasible, DOE must prescribe a separate 

standby mode and off mode energy use test procedure, if technically feasible. (42 U.S.C. 

6295(gg)(2)(A)) In January 2009, DOE prescribed a separate standby mode test 

procedure and determined that fluorescent lamp ballasts do not exhibit off mode energy 

use. In addition, DOE stated that the only ballasts subject to standby mode power 

measurements would be those that incorporate some electronic circuit enabling the ballast 

to communicate with and be part of a lighting control system (e.g., a digitally addressable 

lighting interface (DALI)). 74 FR 3450. 

The amendments to EPCA contained in section 310(3) of EISA 2007 direct that 

any final rule establishing or revising a standard for a covered product adopted after July 

1, 2010 incorporate standby mode and off mode energy use into a single amended or new 

standard if feasible or separate standard if not feasible. (EPCA section 325(gg)(3); 42 

U.S.C. 6295(gg)(3)) In addition, the single amended new or separate standard must 

achieve the maximum improvement in energy efficiency that is technologically feasible 

and economically justified. (42 U.S.C. 6295(o)(2)(A)) 

The Joint Comment argued that DOE should use an alternate metric to BEF that 

would account for all power loads served by the ballast, including standby power 

consumption. (Joint Comment, No. 12 at p. 1) The current active mode test procedure 

determines ballast efficiency, whereas standby mode test procedure reports energy 

consumption. Ballast efficiency is reported in terms of BEF for consistency with 42 

U.S.C. 6295(g)(5) and (g)(8), however, while energy consumption is expressed in watts. 

Because BEF is a measure of efficiency and standby mode power is a measure of energy 

consumption, DOE does not believe it is feasible to incorporate a measure of standby 

mode energy use into the BEF metric. Therefore, DOE intends to establish a separate 

metric for standby mode energy consumption as allowed by EPCA. (42 U.S.C. 

6295(gg)(3)(B)) 

As stated earlier, the only ballasts that exhibit standby mode energy use are those 

that incorporate an electronic circuit that enables the ballast to communicate with and be 

part of a lighting control interface (e.g., DALI-enabled ballasts). DOE believes that the 

only commercially available ballasts that incorporate an electronic circuit to 

communicate with a lighting control interface are dimming ballasts. With the exception 

of dimming ballasts, NEMA agreed that fluorescent lamp ballasts typically do not 

consume power in standby mode. (NEMA, Public Meeting Transcript, No. 9 at p. 69; 

NEMA, No. 11 at p. 2) In considering the preliminary scope of coverage discussed in 

section 2.3, DOE maintains the exclusion of dimming ballasts from energy conservation 

standards. Therefore, none of the ballasts under consideration for coverage exhibit any 

standby mode energy use. Because it is not technologically feasible to reduce standby 

mode or off mode energy use for any ballast currently being considered for amended 

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EERE-2007-BT-STD-0016 COMMENT 25
 

energy conservation standards, DOE tentatively concludes that it cannot establish a 

separate standard that incorporates standby or off mode energy use. If DOE chooses to 

revise the scope of coverage to include dimming ballasts and ballasts that exhibit a 

lighting control interface, DOE will re-evaluate whether standby mode standards are 

justified. 

2.3 SCOPE OF COVERAGE 

EPCA directs DOE to amend energy conservation standards for fluorescent lamp 

ballasts and to determine whether current standards should be made applicable to 

additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) After identifying 

additional ballasts for consideration, DOE conducted a preliminary assessment of 

whether a standard for these ballasts would have the potential to meet the criteria for 

prescribing new or amended standards⎯i.e., demonstrating the potential for energy 

savings and being technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) As discussed, DOE’s preliminary analysis has determined that certain 

ballasts meet the criteria for new or amended energy conservation standards. 

2.3.1 Current Scope of Ballast Energy Conservation Standards 

The current energy conservation standards for ballasts originate from two 

sources⎯an energy conservation standard promulgated in the 2000 Ballast Rule and 

EPACT 2005. The 2000 Ballast Rule set standards for 4-foot and 8-foot T12 lamps that 

took effect in 2005. These standards covered ballasts that operate F40T12, F96T12, and 

F96T12HO lamps, but included several exemptionsh

. Additional energy conservation 

standards from the 2000 Ballast Rule apply to replacement F40T12 ballasts and F34T12 

ballasts and take effect in 2010. EPACT 2005 prescribed energy conservation standards 

specific to ballasts designed for lower wattage applications that have an initial effective 

date of July 1, 2009. These prescribed standards cover ballasts designed to operate 

F34T12 lamps, F96T12/ES lamps, and F96T12HO/ES lamps. (See 10 CFR 

430.32(m)(4)(ii) and 430.32(m)(5)-(6)) In summary, current ballast standards cover the 

following ballasts with the exclusions previously noted: 

• F34T12 

• F40T12 

• F96T12 

• F96T12/ES 

• F96T12HO 

• F96T12HO/ES 

h

 Ballasts designed for dimming to 50 percent or less of its maximum output, ballasts for use with two 

F96T12HO lamps at ambient temperatures of −20 °F or less and for use in an outdoor sign, ballasts with a 

power factor of less than 0.90 and designed and labeled for use only in residential building applications, 

and replacement ballasts are excluded from the standards promulgated in the September 2000 fluorescent 

lamp ballast energy conservation standard final rule. 

2-9 

EERE-2007-BT-STD-0016 COMMENT 25
 

2.3.2 Additional Fluorescent Lamp Ballasts 

According to the definition set forth in 42 U.S.C. 6291(29)(A), “[t]he term 

‘fluorescent lamp ballast’ means a device which is used to start and operate fluorescent 

lamps by providing a starting voltage and current and limiting the current during normal 

operation.” In determining which fluorescent lamp ballasts would be suitable for 

consideration under 42 U.S.C. 6295(g)(7)(B), DOE intends to focus its inquiry on those 

ballasts that operate fluorescent lamps with generic physical and operational features 

closely matching the Illuminating Engineering Society of North America’s (IESNA) 

widely accepted definition of “fluorescent lamp,” as contained in The IESNA Lighting 

Handbook: Reference and Application” Ninth Edition, 2000, p. G-14: 

The definition of a fluorescent lamp is “a low-pressure mercury electricdischarge lamp in which a fluorescing coating (phosphor) transforms some of the 

UV energy generated by the discharge into light.” 

This IESNA definition is consistent with the general description of a “fluorescent 

lamp” in the introductory language of 42 U.S.C. 6291(30)(A).i

 Because the only lamps 

with these features are commonly understood to be fluorescent lamps, DOE would only 

consider standards for ballasts that operate such fluorescent lamps. Therefore, in 

considering whether to amend the standards in effect for fluorescent lamp ballasts so that 

they apply to “additional” fluorescent lamp ballasts as specified in section 325(g)(7)(B) 

of EPCA, DOE will consider all fluorescent lamp ballasts (for which EPCA does not 

prescribe standards) that operate fluorescent lamps, as defined by IESNA. 

ASAP commented that EPCA does not preclude DOE from considering 

previously exempt ballast types in this energy conservation standards rulemaking. 

(ASAP, Public Meeting Transcript, No. 9 at pp. 106-107) DOE has the authority to 

determine “whether to amend the standards in effect for fluorescent lamp ballasts, 

including whether such standards should be amended so that they would be applicable to 

additional fluorescent lamp ballasts.” (42 U.S.C. 6295(g)(7)(B)) Thus, Congress 

authorized DOE to consider setting standards for fluorescent lamp ballasts that had been 

excluded from the prescriptive standards set by EPCA, as amended. Accordingly, DOE 

has considered these ballast types in its preliminary assessment. 

2.3.3 Rationale for Coverage 

As mentioned in section 2.3, DOE considers potential energy savings, 

technological feasibility and economic justification when determining the scope of 

coverage. DOE assessed the potential energy savings from market share estimates, 

potential ballast designs that improve ballast efficiency, and other factors. For market 

share estimates, DOE obtained quantitative shipment information for many ballast types. 

In the absence of specific shipment data, DOE estimated shipments and market share 

using information obtained during manufacturer interviews. For example, based on 

i

 The introductory language of 42 U.S.C. 6291(30)(A) is as follows: “the term ‘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.” 

2-10 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

information from manufacturers, DOE was able to estimate the annual shipments for cold 

temperature outdoor sign ballasts as a percentage of a larger category reported in the U.S. 

Census. DOE invites comments on the shipment or market share data presented in this 

section. 

DOE also assessed the potential to achieve energy savings in certain ballasts by 

considering whether those ballasts serve as potential substitutes for other regulated 

ballasts. At the framework public meeting, ASAP suggested that DOE should anticipate 

market changes as a result of the ballast energy conservation standards. (ASAP, Public 

Meeting Transcript, No. 9 at pp. 63-64) DOE agrees that leaving potential substitutes 

unregulated runs the risk that regulation of one ballast type may lead to rapid increased 

sales of other, unregulated substitutes. This shift toward unregulated ballasts may result 

in decreased energy savings or even increased energy use. To avoid these consequences, 

DOE plans to consider coverage of ballasts that are potential substitutes for any ballast 

that has high energy savings potential and is likely to be regulated. Though the shipments 

of these substitute ballasts may not currently be high volume, energy savings could still 

be significant because these ballasts may capture increased market share if they are left 

unregulated. As long as efficiency improvements are technologically feasible, coverage 

of these additional substitute ballasts could not only yield energy savings, but also 

prevent potentially significant losses in energy savings through the substitution effect. 

In addition to independently conducting its preliminary determination analysis, 

DOE considered comments on the additional ballasts it should cover. The following 

subsections provide a discussion of the ballasts considered for coverage and related 

comments. DOE invites comments on the rationale for coverage presented in this 

preliminary determination. DOE also invites comments on the scope of coverage 

proposed in this preliminary determination. 

2.3.4 Analysis of Individual Ballast Types 

As stated in section 2.2.1, current ballast standards cover ballasts that operate 

F34T12, F40T12, F96T12, F96T12/ES, F96T12HO, and F96T12HO/ES lamps. Pursuant 

to its obligation to cover additional ballast types (42 U.S.C. 6295(g)(7)(B)), DOE 

considered various unregulated ballasts. At the framework public meeting, DOE stated it 

would consider expansion to unregulated ballasts that operate the fluorescent lamps 

covered under EPCA, which include: 

•	 4-foot medium bipin, rated ≥ 28 watts; 

•	 2-foot medium bipin U-shaped lamps, rated ≥ 28 watts; 

•	 8-foot recessed double contact rapid start high output (HO) lamps, 0.800 nominal 

amperes, as defined in ANSI C78.1–1991; and 

•	 8-foot single pin instant start slimline lamps, rated ≥ 52 watts, as defined in ANSI 

C78.3–1991. 

DOE noted that it was considering covering additional ballast types that operate the 

lamps covered in the recently published rulemaking for general service fluorescent lamps. 

2-11 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

The scope of coverage outlined in the energy conservation standards rulemaking for 

general service fluorescent and incandescent reflector lamps (hereafter “the 2009 Lamps 

Rule”)j

 included the following additional lamp types: 

•	 2-foot medium bipin U-shaped lamps with a rated wattage ≥ 25 and < 28; 

•	 4-foot medium bipin lamps with a rated wattage ≥ 25 and < 28; 

•	 4-foot T5 miniature bipin straight-shaped standard output (SO) lamps with rated 

wattage ≥ 26; 

•	 4-foot T5 miniature bipin straight-shaped HO lamps with rated wattage ≥ 49; 

•	 8-foot recessed double contact (RDC) rapid start HO lamps other than those 

defined in ANSI Standard C78.1–1991; 

•	 8-foot RDC rapid start HO lamps other than 0.800 nominal amperes defined in 

ANSI Standard C78.1–1991; and 

•	 8-foot single pin instant start slimline lamps with a rated wattage ≥ 52, not 

defined in ANSI Standard C78.3–1991. 

DOE selected lamps for coverage in the 2009 Lamps Rule using the same criteria 

as in this rulemaking for fluorescent lamp ballasts. Therefore, if a lamp was deemed to 

have the potential for significant energy savings (based on shipment volume and other 

factors), the ballasts that operate those lamps will likely also have significant potential 

energy savings. The Joint Comment supports DOE’s decision to consider a broader scope 

of coverage through the ballasts noted in the framework document and framework public 

meeting. (Joint Comment, No. 12 at pp. 2-3, 8) In addition, ASAP urged DOE to consider 

a broader scope of coverage than in previous rulemakings. (ASAP, Public Meeting 

Transcript, No. 9 at p. 61) 

The Joint Comment supports a scope of coverage limited to ballasts with input 

voltage to 120 to 277 volts. (Joint Comment, No. 12 at p. 5) DOE examined the ballast 

market and found input voltages of 120V to 277V to be common to the U.S. market. 

Ballasts outside this range are primarily designed for foreign markets, such as 347V 

ballasts for the Canadian market. DOE’s preliminary determination of scope includes 

ballasts designed only for operation within the range of 120 to 277 volts. 

At the framework public meeting, NEMA commented that the maturity of ANSI 

standards should be considered in the determination of technological feasibility for a 

ballast product. (NEMA, Public Meeting Transcript, No. 9 at p. 116) DOE understands 

that a product contained in a mature ANSI standard would likely belong to a welldeveloped product line, but believes that investigating product offerings currently sold by 

manufacturers is a better method to determine technological feasibility. DOE establishes 

technological feasibility by understanding the range of energy efficient products available 

in a particular product class. When products are available at multiple levels of efficiency, 

j

 The final rule for energy conservation standards for general service fluorescent and incandescent reflector 

lamps was published in the Federal Register on July 14, 2009. It is available at 

http://edocket.access.gpo.gov/2009/pdf/E9-15710.pdf. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

energy conservation standards are technologically feasible. DOE does consider maturity 

of a product in the rulemaking process, but does not plan to use the maturity of ANSI 

standards as criterion for technological feasibility. The following sections discuss each 

additional ballast type and determine whether each type should be extended coverage. 

Dimming ballasts. DOE received comments from ASAP at the framework public 

meeting and in the Joint Comment recommending expanding the scope of coverage to 

include dimming ballasts. (ASAP, Public Meeting Transcript, No. 9 at pp. 62, 69, 108; 

Joint Comment, No. 12 at pp. 2-3) The current energy conservation standards 

promulgated by the 2000 Ballast Rule exclude ballasts designed for dimming to 50 

percent or less of their maximum output. NEMA believes that dimming ballasts are 

beyond the scope of this rulemaking, although ASAP disagrees with this conclusion. 

(NEMA, Public Meeting Transcript, No. 9 at p. 69; ASAP, Public Meeting Transcript, 

No. 9 at p. 69; NEMA, No. 11 at p. 2) NEMA commented that it is premature to set 

requirements for dimming ballasts because dimming ballast compatibility with lamps is 

still being defined. NEMA argued that BEF values from today's commercially available 

products are inappropriate for use in this rulemaking analyses because BEF values will 

change once a lamp-ballast compatibility standard is developed. (NEMA, Public Meeting 

Transcript, No. 9 at pp. 108-109) NEMA also commented that the energy savings 

possible with dimming systems, using evidence from DOE's Commercial Lighting 

Initiative, can be on the order of 30 to 50 percent, and far outweigh any incremental gains 

of a few percent that can be realized by setting component standards on dimming ballasts. 

(NEMA, Public Meeting Transcript, No. 9 at p. 109) However, the Joint Comment stated 

that dimming ballasts exhibit a range of efficiencies. The Joint Comment urged DOE to 

consider setting an efficiency standard that removes the least efficient products from the 

market but allows flexibility for including features that affect total system efficiency, 

such as control systems. (Joint Comment, No. 12 at p. 4) 

As discussed in section 2.3.2, DOE has determined it is not precluded from 

considering previously exempt ballasts as “additional fluorescent ballasts.” Data from the 

2005 U.S. Census reveal that dimming ballasts have less than 1 percent market share.k 

Although some manufacturers do not report their shipments, after interviewing ballast 

manufacturers, DOE concluded the current market share is likely close to the market 

share indicated by the U.S. Census. Therefore, DOE has tentatively determined not to 

include these ballasts in the scope of coverage for this rulemaking because of their small 

market share and their use in existing energy-saving systems. 

After examining the potential for substitution from other ballast types, DOE also 

believes there is little risk of dimming ballasts becoming a substitute for other covered 

ballast types. Dimming ballasts are more expensive than comparable fixed-light output 

ballasts. Moreover, dimming ballasts require specialized control systems, resulting in 

additional upfront cost. For these reasons, DOE believes dimming ballasts are not a 

potential loophole for existing ballast standards and currently represent a small ballast 

market segment. Therefore, DOE does not plan to extend coverage to dimming ballasts. 

k

 Except when otherwise specified, DOE used data from the 2005 U.S. Census, available at 

www.census.gov/cir/www/335/mq335c.html. 

2-13 

EERE-2007-BT-STD-0016 COMMENT 25
 

Mini-ballasts. The Joint Comment requested that DOE consider mini-ballasts 

used in under-cabinet fixtures. (Joint Comment, No. 12 at p. 5) DOE found that while 

mini-ballasts could be made more efficient, they represent a tiny fraction of the ballast 

market and will likely lose additional market share to LED fixtures. There is little 

potential for substitution for this ballast type because the light output is too small for 

typical fluorescent lamp-and-ballast systems. Based on these findings, DOE does not plan 

to include this ballast type in the scope of coverage. 

Ballasts that operate straight and U-shaped lamps ranging in size from 2 to 8 feet 

and diameters from T5 to T12. The Joint Comment recommended that DOE cover 

ballasts that operate less common lamp types in addition to high volume ballasts. The 

comment suggested covering ballasts for straight and U-shaped lamps ranging from 2 feet 

to 8 feet and diameters from T5 to T12, as well as reduced-wattage lamps. (Joint 

Comment, No. 12 at p. 4) DOE’s research found that many of these lamps and ballasts 

have very small market shares. Though a ballast can operate lamps other than the one it is 

designed to operate, DOE believes there is low risk of substitution. There has been no 

substitution effect under current and previous energy conservation standards, when the 

impacts could have been even greater. The 2009 Lamps Rule did not cover lamps of 

alternate lengths, diameters, or bases for similar reasons⎯low market share with limited 

potential for growth. For these reasons, and because these ballasts are unlikely to be used 

as substitutes, DOE does not plan to include them in this rulemaking. 

Cold temperature ballasts for outdoor signs. The most recent standards exclude 

ballasts designed to operate two F96T12HO lamps at ambient temperatures of 20 °F or 

less and for use in an outdoor sign. (10 CFR 430.32(m)) As discussed earlier, DOE 

believes it has the statutory authority under 42 U.S.C. 6295(g)(7)(B) to consider these 

ballasts for the current energy conservation standards rulemaking. Cold temperature 

ballasts for outdoor signs were originally excluded because electronic sign ballasts were 

not available at the time of the 2000 Ballast Rule. Now, electronic sign ballasts are 

gaining acceptance in the market. DOE received multiple comments requesting that cold 

temperature ballasts be included in this rulemaking. (Joint Comment, No. 12 at pp. 2-3; 

ASAP, Public Meeting Transcript, No. 9 at p. 62) The Joint Comment suggested that low 

temperature ballasts, such as those used in outdoor signage and in refrigeration 

applications, should be covered. Otherwise, low temperature ballasts could become a 

substitute for regulated ballasts in standard applications. (Joint Comment, No. 12 at p. 5) 

DOE found that the market share of cold temperature ballasts was about 1 percent 

in 2005. Sales of LEDs in outdoor signage could rise in the future. However, DOE 

believes LEDs will have a more immediate impact in the neon sign market than in the 

market for large fluorescent outdoor signs. Though high output ballasts have a relatively 

small market share, the energy savings potential per ballast is substantial. Moving from a 

magnetic to an electronic sign ballast could reduce energy consumption by as much as 25 

to 35 percent. Given that sign ballasts exist at multiple efficiency levels, DOE has 

determined it is technologically feasible to cover sign ballasts. Preliminary results from 

2-14 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

the LCC and NIA analyses indicate that setting standards would be economically 

justified. 

Cold temperature ballasts for outdoor signs are typically designed to operate a 

range of lamp lengths and numbers of lamps. Based on product catalogs and 

conversations with manufacturers, DOE found that sign ballasts can be designed to 

operate HO lamps between 1.5 and 10 feet and between 1 and 6 lamps per ballast. DOE 

plans to include these ballasts in the scope of coverage. 

T5 ballasts. DOE received comments both for and against covering T5 ballasts. 

Both ASAP and the Joint Comment encouraged DOE to carefully consider additional 

ballast types such as T5 ballasts. (Joint Comment, No. 12 at p. 3; ASAP, Public Meeting 

Transcript, No. 9 at p. 108) Conversely, NEMA did not support including T5 ballasts 

because it believes T5 ballasts to be an immature technology that is not yet established in 

the marketplace. (NEMA, Public Meeting Transcript, No. 9 at p. 106; NEMA, No. 11 at 

p. 3) 

The U.S. Census reports that T5 ballasts comprised about 4 percent of the ballast 

market in 2005. Shipment data are available only for T5 high output ballasts, so the 

actual market share is likely larger than this. T5 ballast shipments have been steadily 

increasing since the shipments were first reported in 2002. Furthermore, DOE research 

indicates that T5 high output ballasts are rapidly taking market share from metal halide 

systems used in high bay industrial applications. DOE concluded that T5 ballasts are a 

growing market segment of significant size and represent significant potential energy 

savings. In its interviews, DOE learned that some ballast manufacturers are concerned 

that a low-cost, inefficient product could enter the market if T5 ballasts were not subject 

to standards. This inefficient T5 ballast could take market share from more efficient T5 or 

T8 ballasts, decreasing potential energy savings. If T5 lamps were subject to standards, 

the possibility of substitution would be eliminated. Because higher-efficiency versions of 

some of these ballasts are already present in the market, DOE tentatively concludes that 

standards for these ballasts are technologically feasible. Based on DOE’s preliminary 

analysis of these ballasts in the LCC and NIA, coverage of T5 ballasts would be 

economically justified. DOE believes T5 ballasts have a significant and growing market 

share, and also have the potential to become a loophole in ballast standards if not 

included. In addition, DOE believes the T5 ballast market is sufficiently established that 

it will not be adversely affected by energy conservation standards. 

DOE found that T5 ballasts and lamps exist in a variety of lengths and wattages. 

Although standard T5 lamps include wattages ranging from 14W to 80W, and lengths 

ranging from nominally 2 feet to 6 feet, the primary driver of T5 ballast and lamp market 

share growth is substitution for currently regulated 4-foot T8 MBP ballasts and lamps. 

Therefore, DOE proposes to cover only the ballasts designed to operate nominally 4-foot 

lengths of T5 miniature bipin (miniBP) lamps. These include one and two-lamp 4-foot T5 

miniBP SO ballasts and one through four-lamp 4-foot T5 miniBP HO ballasts. 

2-15 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

 

Low power factor ballasts. Low power factor ballasts have a power factor less 

than 0.9 and are typically used in residential applications. These ballasts are exempt from 

current energy conservation standards. DOE has the authority to consider previously 

exempted ballasts in this rulemaking and has received multiple comments on low power 

factor ballast coverage. 

The Joint Comment encouraged DOE to evaluate coverage of low power factor 

ballasts. (Joint Comment, No. 12 at pp. 2-3) It stated that the exemption for low power 

factor ballasts should be removed due to improvements in electronic ballast technology 

and reduced production costs. Additionally, the Joint Comment noted that the size of the 

residential ballast market should be large enough to warrant inclusion in the scope of 

coverage. At the framework public meeting, ASAP also noted that residential ballasts 

have significant market share and suggested that DOE consider low power-factor ballasts 

for coverage. (ASAP, Public Meeting Transcript, No. 9 at pp. 61, 108) 

Only magnetic residential ballast shipments are reported in the U.S. Census. The 

market for residential magnetic ballasts held steady at about 7 percent between 1995 and 

2002, and then decreased to about 1.5 percent in 2005. DOE believes the 2005 market 

share and total shipments to be much higher. Electronic ballasts are a common option for 

residential fluorescent lighting fixtures, but they are not reported in the Census data. 

Also, many residential ballasts are manufactured overseas by foreign companies that do 

not share shipment data with the U.S. Census. Because of these omissions, DOE believes 

residential ballasts represent a sizeable portion of the overall ballast market. 

Residential ballasts do exhibit variation in energy efficiency. Residential ballasts 

can be magnetic or electronic and also exist in both T8 and T12 diameters. Therefore, 

DOE believes standards for low power factor ballasts are technologically feasible. 

Preliminary analysis in the LCC and NIA indicates that standards for residential ballasts 

are economically justified. For these reasons, DOE plans to include residential ballasts 

that operate 4-foot medium bipin or 2-foot U-shaped lamps in the scope of coverage. 

Four-foot T8 MBP and 2-foot T8 U-shaped ballasts. At the framework public 

meeting, DOE stated its intention to expand the scope of coverage to include ballasts that 

operate 4-foot medium bipin and 2-foot U-shaped lamps with rated wattages greater than 

or equal to 25 watts. These lamps were subject to standards in the 2009 Lamps Rule. 

DOE received several comments in support of covering the T8 ballasts that operate these 

lamps, both from manufacturers and energy efficiency advocates (NEMA, No. 11 at p. 3; 

Joint Comment, No. 12 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 106) 

According to the U.S. Census, the market share of 4-foot T8 MBP and 2-foot T8 

U-shaped ballasts represented 55 percent of shipments in 2005. In addition, ballasts that 

operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps exhibit a range of efficiencies, 

thereby satisfying the technological feasibility requirement. Partly because of energy 

conservation standards promulgated for T12 ballasts, shipments of T8 ballasts have been 

increasing. T8 ballasts are being purchased and installed in applications previously 

popular for T12 systems. There is potential for significant energy savings by regulating 

2-16 

EERE-2007-BT-STD-0016 COMMENT 25
 

the 4-foot T8 ballast market. Furthermore, preliminary analysis in the LCC and NIA 

demonstrated the potential for significant economic savings. For these reasons, DOE 

proposes to include ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps in 

the scope of coverage. 

DOE received comments that ballasts designed to operate lower wattage lamps 

should be covered in addition to those designed to operate standard-wattage lamps. (Joint 

Comment, No. 12 at p. 3) After investigating the ballast market, DOE agrees. DOE does 

not want to create a potential loophole where the standard-wattage lamp-and-ballast 

systems that dominate the market can shift to reduced-wattage systems. Therefore, if 

DOE includes a ballast in its scope of coverage, it will also cover ballasts that can operate 

the same type of lamp (length, contacts, etc.) at reduced wattages. For example, DOE will 

not only cover the two-lamp ballast that operates the 32W T8 lamp, but also all ballasts 

that operate two straight-shaped lamps (commonly referred to as 4-foot medium bipin 

lamps) with medium bipin bases of nominal overall length of 48 inches and rated wattage 

of 25 or more. 

Eight-foot SP slimline T8 ballasts. At the framework public meeting, DOE 

announced its intention to expand the scope of coverage to include ballasts that operate 8­

foot single pin instant start slimline lamps with a rated wattage greater than or equal to 52 

watts, as defined in ANSI C78.3–1991, as well as 8-foot single pin instant start slimline 

lamps with a rated wattage greater than or equal to 52, not defined in ANSI Standard 

C78.3–1991. These lamps were included in coverage in the 2009 Lamps Rule. DOE 

received comments in support of covering the T8 ballasts from many interested parties, 

including manufacturers and energy efficiency advocates. (NEMA, No. 11 at p. 3; Joint 

Comment, No. 12 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 106) 

According to the U.S. Census, 8-foot SP slimline T8 ballasts had about 2 percent 

market share in 2005; 8-foot SP slimline T12 ballasts had about 3 percent. While the 

market share for 8-foot SP slimline T8 ballasts is relatively small, the 2009 Lamps Rule 

will eliminate all currently commercially available T12 lamps, further increasing demand 

for T8 lamp-and-ballast systems. In addition, while some 8-foot SP slimline T12 lamps 

are being replaced by two 4-foot T8 lamps, others are being replaced by 8-foot SP 

slimline T8 lamps. DOE believes there is potential for significant energy savings by 

regulating ballasts that operate 8-foot SP slimline T8 lamps and that these regulations are 

technologically feasible. Also, based on DOE’s preliminary analysis of these ballasts in 

the LCC and NIA, coverage of ballasts that operate 8-foot SP slimline T8 lamps would be 

economically justified. For these reasons, DOE plans to include ballasts that operate 8­

foot SP slimline T8 lamps in the scope of coverage. 

Eight-foot HO T8 ballasts. At the framework public meeting DOE announced it 

planned to cover ballasts that operate 8-foot recessed double contact rapid start high 

output lamps, 0.800 and other than 0.800 nominal amperes, as defined in ANSI C78.1– 

1991. These lamps were included in coverage in the 2009 Lamps Rule. Both T8 and T12 

HO ballasts can drive 8-foot RDC lamps, but the current ballast energy conservation 

standard only regulates F96T12HO and F96T12HO/ES ballasts. In addition, DOE has 

2-17 

EERE-2007-BT-STD-0016 COMMENT 25
 

received comments in support of covering the T8 ballasts from many interested parties, 

including manufacturers and energy efficiency advocates. (NEMA, No. 11 at p. 3; Joint 

Comment, No. 12 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 106) 

According to the U.S. Census, the market share of 8-foot HO (T8 and T12) 

ballasts (excluding cold temperature sign ballasts) was about 0.5 percent in 2005. 

Because shipments of 8-foot RDC HO lamps are mostly T12 lamps, DOE believes most 

of the 8-foot HO ballasts currently shipped are T12. The 2009 Lamps Rule will reduce 

the number of T12 RDC HO lamps shipped by promulgating more stringent T12 lamp 

standards. In addition, DOE received comments on the 2009 Lamps Rule that T8 RDC 

HO lamps are replacing T12 RDC HO lamps. DOE believes the associated fluorescent 

lamp ballasts will follow a similar trend toward increased T8 RDC HO ballast shipments. 

Because T8 HO ballasts are currently unregulated, DOE believes covering these ballasts 

will prevent potential negative substitution effects. There is a range of efficiency levels 

for 8-foot T8 HO ballasts currently in the market; therefore, energy conservation 

standards are technologically feasible. In addition, preliminary analysis in the LCC and 

NIA demonstrated the potential for significant economic savings. Based on these 

findings, DOE proposes to include 8-foot HO T8 ballasts in the scope of coverage. 

2.3.5 Summary 

In summary, DOE is considering extending coverage to the following list of 

fluorescent lamp ballasts: 

(1) ballasts that operate one, two, three, four, five, or six straight-shaped 

lamps (commonly referred to as 4-foot medium bipin lamps) with medium 

bipin bases, a nominal overall length of 48 inches, a rated wattagel

 of 25W 

or more, and an input voltage at or between 120V 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) with 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 contact 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 miniature 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; 

l

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

2-18 

EERE-2007-BT-STD-0016 COMMENT 25
(6) ballasts that operate one, two, three, or four straight-shaped lamps 

(commonly referred to as 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-shaped lamps 

(commonly referred to as 4-foot medium bipin lamps) 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 of 

less than 0.90, and 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 lamps) with recessed double 

contact bases, a nominal overall length of 96 inches, an input voltage at or 

between 120V and 277V, and operate at ambient temperatures 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 percent or less of the maximum 

output of the ballasts; 

(2) mini-ballasts designed for use in under-cabinet fixtures; 

(3) ballasts that operate lamps with lengths and wattages other than those 

described above; and 

(4) ballasts with input voltages outside of the covered range. 

2.4 MARKET AND TECHNOLOGY ASSESSMENT 

When DOE begins an energy conservation standards rulemaking, it gathers 

information that provides an overall picture of the market for the products concerned, 

including the nature and market characteristics of the products and the industry structure. 

This activity consists of both quantitative and qualitative analysis based primarily on 

publicly available information. The subjects addressed in the market and technology 

assessment for the preliminary TSD analysis include the major manufacturers, product 

classes, retail market trends, shipments of covered products, regulatory and nonregulatory programs, and technologies that could be used to improve the efficiency of 

fluorescent lamp ballasts. This information serves as a resource throughout the 

rulemaking. 

DOE reviewed existing literature and spoke with manufacturers to gain an 

understanding of the fluorescent lamp ballast industry in the United States. Industry 

publications (e.g., manufacturer catalogs, trade journals), government agencies, and trade 

organizations provided the bulk of the information. Using this information, DOE assessed 

the overall state of the industry, ballast manufacturing and market shares, shipments by 

ballast type, general technical information on ballasts, and industry trends. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

The discussion below summarizes the analytical approach and the comments 

DOE received in response to the framework document.m A more detailed discussion on 

DOE’s approach can be found in the market and technology assessment (chapter 3 of the 

preliminary TSD). 

2.4.1 Market Assessment 

The market assessment focuses on developing a qualitative and quantitative 

characterization of the fluorescent lamp ballast industry. It characterizes the market 

structure based on publicly available information and data supplied by manufacturers and 

other interested parties. The market assessment also includes information about 

manufacturers of fluorescent lamp ballasts, product classes, ballast shipments, and 

existing regulatory and non-regulatory efficiency improvement initiatives. 

2.4.1.1 Manufacturers of Fluorescent Lamp Ballasts 

The majority of the domestic market share of fluorescent lamp ballasts is held by 

four manufacturers: GE Consumer and Industrial of General Electric, Inc. (hereafter, 

“GE”); OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”); Advance 

Transformer of Philips Lighting (hereafter “Advance”); and Universal Lighting 

Technologies (hereafter “Universal”). In addition to ballasts listed under this rulemaking, 

the lighting divisions of several of these companies manufacture other products, such as 

fluorescent lamps, high intensity discharge lamps, and LED lighting. 

All four companies are members of NEMA, a trade association that represents 

fluorescent lamp ballast manufacturers. NEMA provides an organizational framework for 

manufacturers of lighting products to work together on projects that affect their industry 

and business. 

Although the fluorescent lamp ballast market is predominantly supplied by large 

manufacturers, DOE intends to conduct a study of small businesses that manufacture 

fluorescent lamp ballasts for the NOPR stage of this rulemaking analysis. The Regulatory 

Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an initial regulatory 

flexibility analysis for every rule that by law must be proposed for public comment, 

unless the agency certifies that the rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities. A regulatory flexibility 

analysis examines the impact of the rule on small entities and considers alternative ways 

of reducing negative impacts. The Small Business Administration defines small business 

manufacturing enterprises for fluorescent lamp ballasts under the North American 

Industry Classification System product code 33511, Power, Distribution, & Specialty 

Transformer Manufacturing, which has a size standard of 750 employees or fewer. This 

includes the total number of employees in the parent company, not only those in the 

division that produces fluorescent lamp ballasts. DOE invites interested parties to provide 

m For more information on the framework document, visit 

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

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names and contact information for any small businesses that manufacture fluorescent 

lamp ballasts and should be consulted before DOE publishes a NOPR. 

2.4.1.2 Product Classes 

In general, when evaluating and establishing energy conservation standards, DOE 

divides covered product into classes by (1) the type of energy used; (2) the capacity of the 

product; or (3) any other performance-related feature that affects energy efficiency and 

justifies different standard levels, considering factors such as consumer utility. (42 U.S.C. 

6295(q)) Different energy conservation standards may apply to different product classes. 

In the framework document, DOE considered amending the existing product 

classes for fluorescent lamp ballasts. DOE believed that the existing class divisions did 

not properly account for expected market changes due to existing standards or for a 

potentially expanded scope of coverage. DOE sought comments on prospective classsetting factors, specifically number of lamps, lamp length, lamp base, lamp wattage, lamp 

diameter, and input voltage. DOE received several comments on its approach to defining 

product classes. 

The Joint Comment argued that DOE should use relative system efficiency as a 

performance metric instead of BEF (section 2.2.2). Because BEF depends on total lamp 

wattage operated by the ballast, the Joint Comment remarked that a large number of 

product classes would be required to satisfy the proposed scope of coverage. The Joint 

Comment stated that by RSE as a performance metric instead of BEF, DOE could 

establish 30 product classes to cover a wide range of ballasts. Because RSE is BEF 

multiplied by total rated lamp power (a normalizing quantity), more comparisons are 

possible among ballasts that operate different lamp types. The Joint Comment proposed 

defining product classes for an RSE standard based on a combination of starting method, 

lamp length, lamp output, and lamp diameter. (Joint Comment, No. 12 at pp. 6-9) 

As discussed in section 2.2.2 and the active mode test procedure NOPR, for 

consistency with 42 U.S.C. 6295(g)(5), (g)(8), DOE has preliminarily determined that it 

cannot change the reported metric from BEF. For this reason, DOE is currently 

considering calculating BEF by measuring BE (using a resistor-based method) and then 

using transfer equations to correlate that measurement to a reported BEF value. Though 

DOE did not consider product classes for fluorescent lamp ballasts in the context of an 

RSE standard, DOE did consider the four product class criteria recommended by the Joint 

Comment. For this preliminary analysis, with BEF as the efficiency metric, DOE 

considered 10 potential class-setting factors: (1) lamp length, (2) the maximum number 

of lamps operated, (3) ballast factor, (4) lumen package (or lamp output), (5) lamp 

diameter, (6) starting method, (7) market sector, (8) cold temperature operation, (9) input 

voltage, and (10) universal voltage. In general, when considering the above 

characteristics, DOE identified three main factors as affecting consumer utility: (1) the 

lumen package of the lamp-and-ballast system; (2) the physical constraints of the lampand-ballast system; and (3) the use of the ballast in an application for which other ballasts 

are not suitable. The potential class-setting factors DOE considered for the preliminary 

analysis are addressed below. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

The fluorescent ballasts considered for coverage are designed to operate lamps with 

lengths of 4 or 8 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 length 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 lamps and 4-foot 

lamps are not always substitutable for each other. Therefore, DOE believes that lamp 

length affects consumer utility. Given the impact that lamp length has on both BEF and 

utility, DOE is establishing separate product classes for ballasts that operate different 

lamp lengths. 

DOE is considering covering ballasts that operate different maximum numbers of 

lamps (from one to six lamps). Increasing the number of lamps a ballast operates 

increases the input power, thus resulting in a corresponding decrease in BEF. DOE 

believes that operating multiple lamps offers the consumer a distinct utility because this 

capacity affects the space required by fixtures (a four-lamp fixture requires more physical 

space 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 lamps 

a ballast operates. 

The ballasts considered for coverage in this rulemaking are also available with a 

range of ballast factors. In applying DOE’s proposed amended 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.n

 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-andballast 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 in this preliminary TSD to establish separate product 

classes for low, normal, and high ballast factor ballasts. 

The tendency of consumers to use systems with different lumen packages for 

different applications was also observed for ballasts that operate certain types of lamps. 

For example, high output systems may be installed in certain high-ceiling or outdoor 

applications where large quantities of light are needed. Alternatively, standard output 

systems might be installed in lower-ceiling applications such as offices or hospitals, 

where, for example, the distance between the light source and the illuminated surface is 

not as large. Notable differences in the application of ballasts designed to operate SO 

lamps versus HO lamps indicate a difference in utility. This difference in utility is 

accompanied by a difference in BEF, often due to the differences in ballast input power.. 

Therefore, given the observed utility distinctions and notable efficiency differences, DOE 

n

 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. 

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has tentatively decided to establish separate product classes for ballasts that operate SO 

lamps and ballasts that operate HO lamps. 

With regard to ballasts that operate lamps of differing diameters, NEMA 

commented that DOE should not combine ballasts for T8 and T12 lamps in the same 

product class because T8 systems are inherently more efficient than T12 systems. 

(NEMA, No. 11 at p. 3) While DOE agrees with NEMA that T8 systems are generally 

more efficient than T12 systems and that T8 ballasts generally have higher BEFs than 

T12 ballasts, DOE does not believe that this alone justifies creating separate product 

classes for ballasts 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-andballast 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 have the same lengths and bases, offer comparable lumen output, and 

can fit within the same fixtures. DOE recognizes that the diameter of the lamp may affect 

ballast BEF, but the utility provided to the end-user is comparable and/or equivalent.o 

Therefore, DOE has tentatively decided to include ballasts that operate T8 and T12 lamps 

in the same product class. 

However, DOE has decided to establish a separate product class for ballasts that 

operate T5 lamps. All else being equal, 4-foot T5 ballasts 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 classes for ballasts that operate T5 lamps. 

DOE received several comments encouraging the consideration of more than just 

ballast efficiency when creating product classes. NEMA commented that DOE should 

consider the efficiency of the whole system instead of just the ballast efficiency. (NEMA, 

Public Meeting Transcript, No. 9 at pp. 57, 103-104, 124, 211-212; NEMA, No. 11 at p. 

5) NEMA advised DOE to create product classes and set standards so as not to prevent 

new technologies from entering the market that may be less efficient than existing 

ballasts but more efficient when considered as part of a system (with a lamp and fixture). 

(NEMA, Public Meeting Transcript, No. 9 at pp. 104, 124) Furthermore, NEMA 

commented that DOE should consider the application in which ballasts are used because 

this can affect total energy savings. (NEMA, Public Meeting Transcript, No. 9 at p. 104; 

o

 However, recognizing that different ballasts operate T12 and T8 lamps and in order to consider separately 

the impact of standards on consumers of both types of ballasts, DOE structured the analytical tools 

(including the LCC and NIA spreadsheets) so that each consumer subgroup could be analyzed separately. 

Thus, for example, the LCC results are reported separately for baseline ballasts that operate T8 and T12 

lamps. 

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NEMA, No. 11 at p. 5) For example, programmed start ballasts are commonly used with 

occupancy sensors and dimming ballasts are often used with control systems. Both of 

these combinations typically provide significant energy savings when compared to an 

installation of just a lamp and ballast. Programmed start and dimming ballasts, however, 

are generally less efficient than instant start ballasts. NEMA encouraged DOE to create a 

separate product class for programmed start ballasts. (NEMA, Public Meeting Transcript, 

No. 9 at pp. 41, 106) If extending coverage to dimming ballasts, the Joint Comment 

encouraged DOE to account for daylight harvesting when setting product classes because 

its benefits are not captured in the BEF metric. (Joint Comment, No. 12 at p. 4) 

In response, DOE agrees with NEMA that programmed start ballasts warrant 

separate product classes from instant start and rapid start ballasts. As discussed in chapter 

3 of the preliminary TSD, programmed start ballasts have inherently lower BEFs than 

instant start ballasts. However, programmed start 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. 

As DOE did not extend coverage to dimming ballasts in this preliminary analysis 

(section 2.3.4), DOE did not study how to incorporate daylight harvesting into a ballast 

efficiency metric. Should dimming ballasts be included in future coverage, however, 

DOE notes the Joint Comment’s suggestion that energy savings due to daylight 

harvesting be included in any efficiency metric. 

Regarding different market segments, Acuity Brands Lighting commented that if 

DOE were to cover residential ballasts, they should be addressed separately because the 

residential market and its consumers are very different from their commercial 

counterparts. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 110-111) 

As discussed in section 2.3, DOE has initially included them in its expanded scope of 

coverage. As discussed in chapter 3, separate minimum power factor and electromagnetic 

interference requirements exist for residential ballasts 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 minimum allowable) power factor requirements. These differing 

requirements between commercial and residential 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 applications. Therefore, DOE has 

tentatively decided to establish a separate product classes for ballasts that operate in the 

residential sector and commercial sector. 

Ballasts that are designed for use in cold temperature 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 environments – as 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

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 temperature 

environments and to be able to handle numerous lamp combinations, sign ballasts contain 

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 initially established separate product 

classes for cold temperature sign ballasts. 

In addition to the criteria discussed above, DOE also considered establishing 

product classes by input voltage of the ballast. 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 operate 

only at 277V, DOE found that there was not a significant difference in BEF. In addition, 

in its research, DOE found that the ballasts with the highest BEF allowed operation at 

both 120V and 277V. For this reason, DOE does not consider input voltage to be a factor 

in determining product classes. 

Universal voltage ballasts can operate at multiple input voltages (e.g., 120V and 

277V). To accommodate multiple voltages, 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 serve as 

replacements for multiple ballasts. This allows distributors to stock fewer types of 

ballasts and allows contractors to keep fewer on hand for maintenance. Consolidation of 

products creates economies of scale for manufacturers, which can lead to reduced 

production 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 difference in BEF between the two. Therefore, DOE does not consider 

operating at multiple voltages to be a factor in determining product classes. 

In summary, after considering all potential class-setting factors, DOE decided to 

define product classes based on lamp length, lumen package, maximum number of lamps 

operated, starting method, ballast factor, and market sector. These class-setting factors 

created 70 product classes, summarized in Table 2.4.1. DOE requests comments on these 

proposed product classes. A more detailed discussion of each class-setting factor that 

DOE considered can be found in chapter 3 of this preliminary TSD. 

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Table 2.4.1 Product Classes for Fluorescent Lamp Ballasts 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method 

Ballast 

Factor One Two Three Four Five Six 

High 1 2 3 4 5 6 

IS and RS Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18 

High 19 20 21 22 23 24 

Normal 25 26 27 28 29 30 

4-Foot MBP and 2-Foot 

U-Shaped 

PS 

Low 31 32 33 34 35 36 

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

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

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

4-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 

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

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 8-Foot RDC HO 

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

Residential Ballast, 4­ IS and RS All 57 58 59 60 N/A N/A 

Foot MBP, and 2-Foot 

U-Shaped PS All 61 62 63 64 N/A N/A 

Sign Ballast All All 65 66 67 68 69 70 

2.4.1.3 Ballast Shipments 

To calculate the national energy savings from an energy conservation standard for 

fluorescent lamp ballasts, DOE presents shipment estimates disaggregated by product 

class. In chapter 3 of the preliminary TSD, DOE prepared historical shipments data based 

on public shipment records from the U.S. Census. 

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). Second, DOE used the data to select the 

representative product classes and representative units for analysis (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). 

The Census data indicates that 83,440 ballasts were shipped in the United States in 

2005.p

 The U.S. Census data is organized into many subcategories, beginning with 

p

 The total number of shipments is likely higher than indicated because every manufacturer does not report 

ballast shipments to the U.S. Census. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

magnetic versus electronic type ballasts. Under each technology type, the shipments are 

categorized by a variety of characteristics including commercial versus residential sector, 

starting method, maximum number of lamps driven (1, 2, 3, or 4), lamp wattage, lamp 

diameter, and a few additional specific characteristics. The shipment data does not 

include specific information for every permutation of design characteristics, but it does 

indicate major trends in the market. Table 2.4.2 shows the market share of major ballast 

types in 2005. 

Table 2.4.2 Ballast Market Share in 2005 

Ballast Type 2005 Market Share (%) 

T8 56 

T12 18 

CFL 8 

T5 4 

Residential 2 

Linear Dimming 1 

Cold Temperature Outdoor Sign 1 

Other 10 

A total of 83,440 ballasts were shipped in 2005. 

The most significant trend in fluorescent lamp ballast shipments to date has been a 

shift away from magnetic T12 ballasts to electronic T8 ballasts. Magnetic ballasts 

commanded a majority of shipments in 1990 but were overtaken by electronic ballasts in 

2005. Part of this trend has been driven by energy conservation standards for T12 

ballasts. 

In addition, consumer demand is changing for some ballast subcategories. For 

example, 8-foot SP slimline T12 lamp-and-ballast systems are moving toward both 8-foot 

slimline SP T8 lamp-and-ballast systems and two 4-foot T8 MBP lamp-and-ballast 

systems. T5 ballasts have also seen an increase in shipments, partly because F54T5HO 

ballasts are being used as substitutes for high bay metal halide systems in industrial 

applications. 

2.4.1.4 Regulatory and Non-Regulatory Programs 

Several Federal and international regulatory programs affect the market for 

fluorescent lamp ballasts. U.S., Canadian, and European regulatory initiatives relevant to 

the ballasts covered by this rulemaking are currently in place. While the following 

summary is not exhaustive in describing all regulatory action related to fluorescent lamp 

ballasts, it indicates notable initiatives that characterize recent developments in the 

lighting market. Chapter 3 of the preliminary TSD discusses these programs and 

initiatives in additional detail. 

In the United States, EPCA established an energy conservation program for major 

household appliances. Subsequently, NAECA 1988 expanded DOE’s authority to 

regulate the energy efficiency of several products, including fluorescent lamp ballasts. 

NAECA 1988 prescribed standards and required DOE to conduct two rulemakings on 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

fluorescent lamp ballasts. The first of these two rulemakings was completed in 2000 (the 

2000 Ballast Rule); the second is this rulemaking. In addition, EPACT 2005 prescribed 

energy conservation standards for additional fluorescent lamp ballasts. 

In Canada, the Natural Resources Canada (NRCan) Office of Energy Efficiency 

regulates the energy efficiency of fluorescent lamp ballasts. In 1992, Parliament passed 

the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance 

levels for energy using products, effective in February 1995. Fluorescent lamp ballasts 

were included in the first set of energy efficiency regulations in 1994 and were amended 

in April 2003 to adopt the standards promulgated by DOE in the 2000 Ballast Rule. 

Finally, Amendment 9, published in the Canadian Gazette Part II on November 15, 2006 

further amended Canadian energy efficiency standards. 

In Europe, Directive 2005/32/EC of the European Parliament 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. 

2.4.2 Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to be 

a feasible means of improving product efficiency. This assessment provides the technical 

background and structure on which DOE bases its screening and engineering analyses. 

The following discussion provides an overview of the salient aspects of the technology 

assessment, including issues on which DOE seeks public comment. Chapter 3 of the 

preliminary TSD provides detailed descriptions of the basic construction and operation of 

fluorescent lamp ballasts, followed by a discussion of technology options to improve the 

ballast efficacy factor of a fluorescent lamp ballast. 

In the framework document, DOE requested comments on a list of preliminary 

technology options that DOE intended to study further. These technology options 

included cathode cutout or hybrid ballasts, electronic ballasts, integrated circuits, higher 

grade components, and improved circuit designs. NEMA provided comments on each of 

these technology options. 

NEMA recommended that cathode cutout technology be evaluated as a 

technology option. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 at 

p. 113) DOE agrees that cathode cut out technology can be used to increase the efficiency 

of a ballast by removing filament heating after the lamp has started. Therefore, DOE is 

considering this a method to improve a ballast’s BEF in the technology assessment. After 

reviewing this technology option further, DOE has determined that this technology is a 

type of improved circuit design. 

NEMA also recommended that DOE consider electronic ballasts as a technology 

option. NEMA stated that DOE should establish an electronic ballast efficiency level for 

all future rulemakings. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 

at p. 113) DOE considers electronic ballasts to be a technology option and will consider 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

NEMA’s comment about establishing an electronic ballast efficiency level for all ballasts 

when DOE proposes a standard in the fluorescent lamp ballast NOPR. 

NEMA commented that the use of integrated circuits by themselves do not 

directly influence ballast efficacy factor and thus should not be a factor in establishing 

energy conservation standards. (NEMA, No. 11 at p. 4; NEMA, Public Meeting 

Transcript, No. 9 at p. 113) DOE agrees that not all integrated circuits directly influence 

ballast efficacy factor. However, DOE believes that some do. For example, there is an 

integrated circuit that can increase ballast efficacy factor by replacing transistors in the 

direct current (DC) to alternating current (AC) inverter.q Therefore, DOE is maintaining 

integrated circuits as a technology option in the technology assessment. 

NEMA stated that higher grade components should be considered a technology 

option because these components can reduce energy loss. NEMA also noted that DOE 

should evaluate the cost impact of such improvements in determining energy 

conservation standards for fluorescent lamp ballasts. (NEMA, No. 11 at p. 4; NEMA, 

Public Meeting Transcript, No. 9 at p. 113) DOE agrees that higher grade components 

like improved transformers, diodes, capacitors, and resistors should be considered a 

technology option as these components can reduce energy loss. Once DOE determines if 

this technology option meets the screening criteria discussed in section 2.5, DOE will 

analyze the cost impact of the design option in the engineering analysis. More 

information on higher grade components can be found in chapter 3 of the preliminary 

TSD. 

In discussing improved circuit designs, DOE stated in the framework document 

that improving a ballast’s power factor could improve a ballast’s BEF. NEMA stated that 

raising the power factor is not an option for the majority of commercial ballasts and that 

increasing the power factor for residential ballasts would increase ballast losses. (NEMA, 

No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 at pp. 113-114) DOE agrees that 

increasing a commercial or residential ballast’s power factor may not necessarily increase 

the ballast’s BEF.r

 Therefore DOE is not considering this a technology option. DOE 

continues to believe that changing the circuit design of a ballast can increase a ballast’s 

BEF and therefore maintains improved circuit designs as a technology option. 

In discussing improved circuit designs, NEMA stated that it was unaware of any 

emerging technology that promises to lower ballast losses while maintaining the same 

level of performance as today’s state-of-the-art ballast designs. (NEMA, Public Meeting 

Transcript, No. 9 at pp. 114, 118; NEMA, No. 11 at p. 4) DOE appreciates NEMA’s 

comment on the existence of emerging technologies. DOE will only consider technology 

options in the engineering analysis that satisfy the screening criteria (i.e., technological 

feasibility; practicability to manufacture, install, and service; adverse impacts on 

q

 International Rectifier. International Rectifier Introduces Robust Self-Oscillating Electronic Ballast 

Lighting Control IC. November 22, 2005. (Last accessed March 19, 2009.) <http://www.irf.com/whatsnew/nr051122.html> 

r

 ANSI 82.77-2002 already requires commercial ballasts to have a power factor greater than or equal to 

0.90 and residential ballasts to have a power factor greater than or equal to 0.50. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

equipment utility or equipment availability; and adverse impacts on health or safety). 

DOE invites comments on all of the technology options it considered for fluorescent 

lamp ballasts (listed in Table 2.4.3), including any omissions or revisions necessary to 

have a more comprehensive technology assessment. In the context of commenting on 

technology options, DOE also requests information on the feasibility, performance 

improvement, and cost of the technology options, as well as any recent developments in 

their technical maturity. More information concerning these technology options can be 

found in chapter 3 of the preliminary TSD. 

Table 2.4.3 Fluorescent Lamp Ballast Technology Options 

Technology Option Description 

Magnetic Ballast Magnetic Ballast Design 

Electronic Ballast Electronic Ballast Design 

Lamp Diameter Vary the lamp diameter to improve system performance. 

Improved Components 

Transformers 

Use grain-oriented silicon steel or amorphous steel to reduce core 

losses. 

Laminated sheets of amorphous steel to reduce core losses. 

Litz Wire reduces winding losses. 

Diodes Diodes with lower losses. 

Capacitors Capacitors with a lower effective series resistance. 

Transistors Transistors with low drain-to-source resistance. 

Improved Circuit Design 

Cathode Cutout Remove filament heating after lamp has started. 

Integrated Circuits Substitute discrete components with an integrated circuit. 

Starting Method Use instant start instead of rapid start as a starting method for 

lamp operation. 

In the engineering analysis, DOE only considers technology options that meet the 

criteria in the screening analysis, discussed below. DOE was not able to identify working 

products or prototypes that have a distinguishably higher BEF than commercially 

available ballasts. Therefore, the most efficient ballasts in the engineering analysis are the 

most efficient tier of commercially available ballasts, and represent the “max-tech” level 

that DOE determined for this preliminary rulemaking. However, DOE presents additional 

research in appendix 5D of the preliminary TSD to explore whether technologies used in 

products similar to ballasts can be used to improve the efficiency of ballasts currently on 

the market. DOE requests comments on the feasibility, performance improvement, and 

cost of these technology options. 

2.5 SCREENING ANALYSIS 

After DOE identified the technologies that might improve the energy efficiency of 

fluorescent lamp ballasts, DOE conducted the screening analysis. The purpose of the 

screening analysis is to determine which options to consider further and which options to 

screen out. DOE consults with industry, technical experts, and other interested parties in 

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EERE-2007-BT-STD-0016 COMMENT 25
 

developing a list of design options. DOE then applies the following set of screening 

criteria to determine which design options are unsuitable for further consideration in the 

rulemaking (10 CFR Part 430, subpart C, appendix A at 4(a)(4) and 5(b)): 

•	 Technological Feasibility: DOE will consider technologies incorporated in 

commercial equipment or in working prototypes to be technologically feasible. 

•	 Practicability to Manufacture, Install, and Service: If mass production of a 

technology in commercial equipment and reliable installation and servicing of the 

technology could be achieved on the scale necessary to serve the relevant market 

at the time of the effective date of the standard, then DOE will consider that 

technology practicable to manufacture, install, and service. 

•	 Adverse Impacts on Equipment Utility or Equipment Availability: If DOE 

determines a technology to have significant adverse impact on the utility of the 

equipment to significant subgroups of consumers, or to result in the unavailability 

of any covered equipment type with performance characteristics (including 

reliability), features, sizes, capacities, and volumes that are substantially the same 

as equipment generally available in the United States at the time, it will not 

further consider this technology. 

•	 Adverse Impacts on Health or Safety: If DOE determines that a technology will 

have significant adverse impacts on health or safety, it will not further consider 

this technology. 

NEMA commented that DOE should not consider technology options with significant 

adverse impacts on health and safety. (NEMA, No. 11 at p. 5; NEMA, Public Meeting 

Transcript, No. 9 at p. 117) DOE agrees and maintains this as a screening criterion. 

For a complete discussion of the screening analysis, refer to chapter 4 of the preliminary 

TSD. The following section focuses on one technology option that was screened out due 

to its failure to comply with one or more of the screening criteria. 

2.5.1 Technology Options Screened Out 

In considering technologies in the screening analysis, NEMA stated that the only 

technologies that have been shown to be practical to manufacture, to have no adverse 

impacts on reliability, and to have no impact on the marketplace are used in 

commercially available products (which may not include all products that appear in 

manufacturer catalogs). Therefore, NEMA argued that only technologies used in 

currently commercially available products should be considered when setting standards 

for ballasts. NEMA noted that examining the ballasts listed in the NEMA Premium 

program could be one method of determining which products are actually used in the 

marketplace and therefore commercially available. (NEMA, Public Meeting Transcript, 

No. 9 at pp. 115-116; NEMA, No. 11 at p. 5) Acuity Brands Lighting agreed with 

NEMA, stating that data on reliability is available only for those products that have been 

commercially available. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 

118-119) ASAP disagreed, arguing that DOE should not screen out a technology based 

on whether that technology has gained market acceptance. (ASAP, Public Meeting 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

Transcript, No. 9 at p. 119) NYSERDA also noted that there may be some emerging 

technologies that should not be screened out as the lighting industry moves very fast and 

these standards are 7 years from application. (NYSERDA, Public Meeting Transcript, 

No. 9 at pp. 117-118) 

DOE agrees that technologies should not be screened out based on whether they 

are used in a commercially available product. The screening criteria define technological 

feasibility to include technology incorporated into working prototypes as well as 

commercially available products. It is possible that a technology that is not commercially 

available or simply has not gained noticeable market share could increase the efficiency 

of a ballast and meet all of the screening criteria. Therefore, DOE will not screen out a 

technology based on its presence in commercially available products. 

After considering all of the technology options identified in the technology 

assessment, DOE determined that improving ballast efficiency by employing an inductor 

composed of laminated sheets of amorphous steel did not meet the screening criteria. 

DOE screened out this technology option because this method increases the size and 

weight of the ballast. Therefore, DOE believes this option is not practicable to 

manufacture, install, and service. Employing this technology option may cause problems 

with installing and servicing ballasts because the ballasts could be too large to fit in a 

fixture. DOE also believes this technology option fails the screening criterion of adverse 

impacts on consumer utility. Specifically, increasing the size and weight of the ballast 

may limit the places a consumer could use the ballast in a building. DOE is unaware of 

available data on whether this technology option is technologically feasible or has 

adverse impacts on health or safety because it is not commercially available. 

In summary, after examining all of the options presented in the technology 

assessment, DOE screened out only one option (laminated sheets of amorphous steel) 

because it did not meet all of the screening criteria. All remaining technology options met 

the screening criteria, and therefore will be considered in the engineering analysis. 

2.6 ENGINEERING ANALYSIS 

DOE performed an engineering analysis to establish the relationship between the 

manufacturer production cost (MPC) and the energy efficiency of ballasts. The 

relationship between the MPC and energy efficiency serves as the basis of the costbenefit calculations for individual consumers, manufacturers, and the Nation. This 

section provides an overview of the engineering analysis, discusses the representative 

product classes, establishes baseline unit specifications for those product classes, 

discusses incremental efficiency levels, discusses the analysis and results for the 

representative product classes, and establishes a scaling methodology for those product 

classes DOE did not analyze. 

The primary inputs to the engineering analysis are the design options from the 

screening analysis (see chapter 4 of the preliminary TSD). Additional inputs include cost 

and efficiency data derived from the physical teardowns and test data from independent 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

labs. The primary output of the engineering analysis is a set of cost-efficiency curves. In 

a subsequent life-cycle cost analysis (chapter 8 of the preliminary TSD), DOE used the 

cost-efficiency curves to determine customer prices for each product by applying the 

appropriate distribution channel markups. 

2.6.1 Preliminary Engineering Analysis Approach 

DOE typically structures its engineering analysis around one of three 

methodologies: (1) the design-option approach, which calculates the incremental cost of 

adding specific design options to the baseline model; (2) the efficiency-level approach, 

which calculates the relative costs of achieving increases in energy efficiency levels, 

without regard to the particular design options used to achieve such increases; or (3) the 

reverse engineering cost-assessment approach, which involves a “bottom-up” 

manufacturing cost assessment based on a detailed bill of materials derived from 

teardowns of products being analyzed. 

At the framework document public meeting, DOE proposed using an efficiency 

level approach that included basing its determination of the end-user retail prices for 

ballasts off of marked-down manufacturer product price schedule lists.s

 DOE received 

several comments on this methodology. At the public meeting, manufacturers stated that 

the proposed approach would yield inaccurate and misleading end-user prices for ballasts 

as each manufacturer has a different method of deciding how to price products. (Osram 

Sylvania, Public Meeting Transcript, No. 9 at p. 138; GE Lighting, Public Meeting 

Transcript, No. 9 at pp. 140, 144; Acuity Brands Lighting, Public Meeting Transcript, 

No. 9 at pp. 140-141) One manufacturer stated that this method may work for lamps but 

not ballasts because lamps are primarily maintenance components and purchased in large 

volumes, whereas ballasts are mostly new construction components. (Acuity Brands 

Lighting, Public Meeting Transcript, No. 9 at pp. 140-141) The Joint Comment argued 

that DOE should instead give greater weight to reverse engineering cost estimates as this 

methodology has a better track record of estimating actual costs. (Joint Comment, No. 12 

at p. 13) 

In evaluating the most appropriate methodology for the engineering analysis, 

DOE determined that an efficiency level approach paired with reverse engineering cost 

estimates would yield the most realistic data. In this way, DOE would not rely on product 

lists or minimum cost data supplied by manufacturers. Because DOE was unable to 

reverse engineer some ballasts analyzed in the rulemaking due to potting (a tar-like fill 

material which inhibits the visual observation of the components), DOE conducted 

teardowns for only unpotted ballasts and ballasts removed from a manufacturing facility 

before the potting procedure. 

s

 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy Conservation 

Program for Consumer Products: Framework Document: Energy Conservation Standards for Consumer 

Products: Fluorescent Lamp Ballasts. January 2008. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ballast_framework_011408.p 

df> 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

DOE devised a scaling technique to estimate manufacturer product costs for 

additional ballasts types. Using online ballast supplier pricing, DOE developed ratios 

relating online prices to teardown-sourced MPCs. These ratios allowed DOE to estimate 

MPCs for additional ballasts by scaling from their online price. For more information on 

DOE’s pricing analysis, see section 2.6.6 or chapter 5 of the preliminary TSD. 

The following discussion summarizes the general steps of the engineering 

analysis: 

Representative product classes: DOE first reviews covered ballasts and the 

associated product classes. When a product has multiple product classes, DOE selects 

certain classes as “representative” and concentrates its analytical effort on these. DOE 

selects representative product classes primarily because of their high market volumes. For 

those product classes that are not analyzed, DOE extrapolates the candidate standard 

levels from representative product classes to other product classes. 

Baseline ballasts: For each representative product class, DOE establishes baseline 

ballasts. The baseline serves as a reference point for each product class, against which 

DOE measures changes resulting from potential amended energy conservation standards. 

To determine energy savings and changes in price, DOE compares each energy efficiency 

level with the baseline unit. Generally, a baseline ballast is a commercially available 

ballast that just meets existing Federal energy conservation standards and provides basic 

consumer utility. If no standard exists for that specific ballast type, the baseline ballast 

represents the typical ballast sold within a product class with the lowest tested ballast 

efficacy factor. NEMA recommended that only documented non-commercial information 

from accredited testing laboratories be used for the engineering analysis because 

commercially available data overstates ballast efficiency. (NEMA, No. 11 at p. 6; 

Advance, Public Meeting Transcript, No. 9 at pp. 125-126) DOE agrees with NEMA and 

therefore has not relied on information in product catalogs when determining the BEF for 

ballasts. 

To develop the engineering analysis, DOE purchased a range of commercially 

available ballasts and tested them at two accredited testing laboratories for ballast 

efficacy factor and ballast efficiency. All test results are presented in appendix 5C of the 

preliminary TSD. For the baseline ballast, DOE selected specific characteristics such as 

starting method, ballast factor, and input voltage to characterize the most common 

ballast. DOE also selected multiple baseline ballasts in some product classes to ensure 

consideration of different ballast types and their associated consumer economics. 

Candidate lamp-and-ballast designs: DOE selects commercially available ballasts 

with a higher BEF as replacements for each baseline ballast in the representative product 

classes by considering the design options identified in the technology assessment and 

screening analysis (preliminary TSD chapter 4). DOE is able to explicitly identify many 

of the distinguishing design options associated with each ballast. However, at some 

levels, these design options are considered to be implicitly used in the ballast to achieve a 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

higher BEF.t In identifying more efficient substitutes, DOE identifies ballasts using a 

database of commercially available ballasts. DOE then tests these ballasts to establish 

BEF and ballast efficiency. All test results are presented in appendix 5C. 

Because fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE 

pairs each ballast with the most common fluorescent lamp in its respective product class. 

DOE develops the engineering analysis based on two substitution cases. In the first case, 

the consumer is not allowed to change the spacing of their fixtures and therefore replaces 

one baseline ballast with a more efficacious ballast. In this case, light output is 

maintained to within 10 percent of the baseline system lumen output.u In the second case, 

the consumer is allowed to change the spacing of the fixture. Therefore, light output is 

normalized and the consumer either installs more or fewer ballasts to maintain light 

output. 

Candidate standard levels. After identifying the more efficient substitutes for 

each baseline ballast, DOE develops candidate standard levels (CSLs). DOE based its 

analysis on two factors: (1) the design options associated with the specific ballasts 

studied, and (2) the maximum technologically feasible efficiency level. Advance 

suggested that DOE should consider only commercially available systems when 

developing candidate standard levels due to time constraints. (Advance, Public Meeting 

Transcript, No. 9 at pp. 131-132) As stated in the screening analysis, DOE believes that 

all technologies that pass the screening criteria are used in commercially available 

ballasts or working prototypes and therefore based its engineering analysis on those 

technologies. 

DOE is required by section 325(o) of EPCA to determine the maximum 

improvement in BEF that is technologically feasible (“max-tech”) for fluorescent lamp 

ballasts. (42 U.S.C. 6295(o)). To determine this level, DOE conducted a survey of the 

fluorescent lamp ballast market and the research fields that support the market. DOE 

believes that within a given product class, no working products or prototypes exist that 

have a distinguishably higher BEF than commercially available ballasts. Therefore, the 

highest CSL presented, which represents the most efficient commercially available 

ballasts, is the max-tech level that DOE determined for this preliminary rulemaking. 

However, DOE presents additional research in appendix 5D of the preliminary TSD to 

explore whether technologies used in products similar to ballasts can be used to improve 

the efficiency of ballasts currently on the market. DOE requests comments on this 

analysis. 

NEMA argued that DOE should not establish a CSL that would require a 

proprietary technology, as this would give one company an advantage over another. 

(NEMA, No. 11 at p. 6; NEMA, Public Meeting Transcript, No. 9 at p. 130) DOE agrees 

t

 Ballast catalogs usually designate whether the ballast is magnetic or electronic and what diameter lamp it 

is designed to operate. The catalogs do not, however, specify the quality of components used or all aspects 

of the circuit design. 

u

 In some instances (e.g., when switching from T12 to T8 ballasts), light output goes slightly beyond these 

limits. These instances are discussed in more depth in chapter 5 of the preliminary TSD. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

and considers proprietary designs in its engineering analysis only if there are other 

technology pathways to meet that efficiency level. DOE does not regard a standard level 

that can be met by only one proprietary design to be economically justified. DOE 

believes, however, that no CSL in this rulemaking requires the use of a proprietary 

technology. DOE requests comments on its conclusions that no commercially available 

products use proprietary designs and that CSLs that require the use of proprietary designs 

are not economically justified. 

Price analysis. After identifying both the baseline ballast and the more efficient 

substitutes at each CSL, DOE generates a bill of materials (BOM) by disassembling 

multiple manufacturers’ ballasts that span a range of efficiency levels for each of the 

representative product classes. The BOMs describe the product in detail, including all 

manufacturing steps required to make and/or assemble each part. DOE then develops a 

cost model that converted the BOMs and efficiency levels into MPCs. By applying 

derived manufacturer markups to the MPCs, DOE calculated the manufacturer selling 

prices and constructed industry cost-efficiency curves. 

DOE was not able to generate a BOM for all ballasts in the engineering analysis. In 

this case, DOE evaluated retail prices and estimated a MSP for each ballast. For 

fluorescent lamps, DOE referenced the retail price in the 2009 Lamps Rule. 

2.6.2 Representative Product Classes 

As discussed in the market and technology assessment (preliminary TSD chapter 

3), DOE revised the existing product classes for ballasts to include 70 product classes, as 

shown in Table 2.6.1. Of these 70 product classes, DOE chose to analyze 10 as 

representative product classes. DOE chose to analyze at least one representative product 

class for each lamp type analyzed. For the most prevalent ballast type (e.g., for ballasts 

that operate two 4-foot MBP and 2-foot U-shaped lamps), DOE choose to analyze 

multiple representative product classes. DOE based the representative product classes on 

the most common lamp-and-ballast configurations. Although DOE did not create a 

separate engineering analysis for every product class, DOE established standards for 

these product classes based on the representative product classes directly analyzed. For 

instance, DOE extended its proposal for ballasts that operate two 4-foot T5 MiniBP HO 

lamps by observing the relationship between test data for ballasts that operate one, three, 

and four lamps and determining an appropriate scaling factor. Section 2.6.5 and chapter 5 

of the preliminary TSD provide more information on extending standards to the product 

classes DOE did not analyze. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

 

 

 

 

 

 

 

 

Table 2.6.1 Representative and Scaled Product Classes for Fluorescent Lamp 

Ballasts 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method 

Ballast 

Factor One Two Three Four Five Six 

High Scaled Scaled Scaled Scaled Scaled Scaled 

Normal Scaled Representative 

Product Class Scaled Representative Product Class Scaled Scaled

IS and 

RS 

Low Scaled Scaled Scaled Scaled Scaled Scaled 

High Scaled Scaled Scaled Scaled Scaled Scaled 

Normal Scaled Representative 

Product Class Scaled Representative Product Class Scaled Scaled 

4-Foot MBP and 2­

Foot U-shaped 

PS 

Low Scaled Scaled Scaled Scaled Scaled Scaled 

High Scaled Scaled N/A N/A N/A N/A 

Normal Scaled Representative 

Product Class N/A N/A N/A N/A

 4-Foot T5 MiniBP 

SO All 

Low Scaled Scaled N/A N/A N/A N/A 

4-Foot T5 MiniBP 

HO All All Scaled Representative 

Product Class Scaled Scaled N/A N/A 

High Scaled Scaled N/A N/A N/A N/A 

Normal Scaled Representative 

Product Class N/A N/A N/A N/A 8-Foot SP Slimline All 

Low Scaled Scaled N/A N/A N/A N/A 

IS and 

RS All Scaled Representative 

Product Class N/A N/A N/A N/A 8-Foot RDC HO 

PS All Scaled Scaled N/A N/A N/A N/A 

IS and 

RS All Scaled Representative 

Product Class Scaled Scaled N/A N/A Residential Ballast, 

4-Foot MBP, and 2­

Foot U-Shaped PS All Scaled Scaled Scaled Scaled N/A N/A 

Sign Ballasts All All Scaled Scaled Scaled Representative 

Product Class Scaled Scaled 

2.6.3 Baseline Ballasts and Candidate Standard Levels Analyzed 

For each representative product class, DOE selected a baseline model as a 

reference point against which to measure changes resulting from energy conservation 

standards. Typically, a baseline ballast is a unit that just meets current Federal energy 

conservation standards and provides basic consumer utility. To determine energy savings 

and changes in price, DOE compared each higher energy efficiency level with the 

baseline unit. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

DOE considered the ballast’s characteristics in choosing the most appropriate 

baseline ballast for each product class (the baseline ballast exhibits the characteristics of 

the least efficient and most common ballast.) These characteristics include the ballast’s 

starting method (e.g., rapid start (RS), instant start (IS), or programmed start (PS)), input 

voltage (277V vs. 120V), type (electronic vs. magnetic), power factor (PF), total 

harmonic distortion, ballast factor (BF), input power, BEF, and whether the ballast can 

operate at multiple voltagesv (universal voltage) or only one (single voltage). Finally, 

DOE considered whether the ballast just meets existing Federal minimum energy 

conservation standards. 

After choosing a baseline ballast, DOE surveyed and tested many of the 

manufacturers’ product offerings for BEF and ballast efficiency to identify the efficiency 

levels corresponding to the highest number of models. DOE identified the most prevalent 

BEF values in the range of available products and established CSLs based on those 

products. Because the baseline ballasts have different BEF values and represent various 

design options, CSLs affect only one of the two baseline lamps in some product classes. 

For example, CSL1 may require a more efficient T12 ballast than the baseline T12 

ballast, but not require a ballast more efficient than the T8 baseline. However, the full 

range of CSLs ultimately specifies requirements that are above the BEF values of all the 

baseline ballasts sold, and therefore affect all baseline ballasts. 

The following discussion outlines DOE’s choice of baseline ballasts and CSLs for 

the two-lamp normal BF IS and RS 4-foot MBP product class. For this product class, 

DOE chose to analyze two baseline ballasts. Census data indicates that 2001 shipments of 

4-foot and 2-foot U-shaped MBP T12 ballasts represented 14 percent of all shipments, 

while 4-foot and 2-foot U-shaped MBP T8 ballasts represented 86 percent of all 

shipments.w Therefore, DOE analyzed both a T12 and T8 ballast as a baseline ballast. 

Because F34T12 lamps are the most common T12 lamps, DOE chose to analyze only 

those ballasts that operate F34T12 lamps for this rulemaking. DOE also chose to analyze 

only those ballasts that operate F32T8 lamps because this lamp is the most common 4­

foot MBP T8 lamp. 

The Federal minimum energy conservation standards for ballasts that operate two 

F34T12 lamps became effective for ballasts manufactured on or after July 1, 2009. (10 

CFR Part 430.32 (m)(5)) This energy conservation standard effectively allowed only 

electronic F34T12 ballasts. Therefore, DOE chose an electronic ballast as the F34T12 

baseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple 

ballasts operating a reference F34T12 lamp. Table 2.6.2 shows the BEF, BF, and input 

power of the most common T12 ballast that just meets the minimum energy conservation 

standard of 1.35. The majority of T12 electronic ballasts in product catalogs are RS, are 

single voltage, have a high PF (around 0.98), and have a THD less than 20 percent. The 

ballast that just meets the energy conservation standard also exhibits these characteristics. 

v

 Universal voltage ballasts can operate at 120V or 277V. 

w More recent Census data for ballasts is available. However, shipments of T12 ballasts have not been
 

publicly released after 2001. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

DOE also chose a ballast that has an input voltage of 277V ballast because the majority 

of ballasts operate in commercial buildings at 277V. 

There is no Federal minimum energy conservation standard for ballasts that 

operate F32T8 lamps. Therefore, DOE chose the most common, least efficient ballast on 

the market as the baseline ballast for this lamp type. DOE tested a range of F32T8 

ballasts from multiple ballast manufacturers and found that the least efficient but most 

common ballast exhibited the characteristics shown in Table 2.6.2. The vast majority of 

T8 ballasts are IS, are electronic, and have a high PF (around 0.98). Furthermore, the 

least efficient T8 ballasts are single voltage and have a THD less than 20 percent. Finally, 

DOE chose a ballast that has an input voltage of 277V, because the majority of ballasts 

operate in commercial buildings at 277V. 

Table 2.6.2 Baseline Ballasts for Two-Lamp Four-Foot and Two-Foot U-Shaped 

MBP IS & RS Normal BF Product Class 

For 

operation 

of 

Starting Method, 

Input Voltage, Ballast 

Type, PF, THD 

Ballast 

Efficiency 

BF Input 

Power 

BEF Federal 

Energy 

Conservation 

Standard 

Two 

F34T12 

lamps 

RS, 277V, Electronic, 

Single Voltage 0.98 PF, 

<20% THD 

80.1%* 0.86 63.5 1.359 1.35 

Two 

F32T8 

lamps 

IS, 277V, Electronic, 

Single Voltage, 0.98 

PF, <20% THD 

85.4%* 0.88 60.4 1.450 N/A 

* DOE was unable to test the ballast efficiency of these particular ballasts. DOE estimates are 

based on a measured BEF value and the established relationship between BEF and ballast 

efficiency determined by the active mode test procedure. For the IS and RS representative product 

class, the BEF of a ballast is related to ballast efficiency in the following manner: 

BEF=1.697*BE. 

As discussed in the screening analysis (chapter 4 of the preliminary TSD), DOE 

used design options that achieve a higher BEF than the baseline ballast. Because the 

baseline ballast is an electronic ballast, improvements required the use of the following 

design options: lamp diameter, improved components, and improved circuit design. The 

following discussion outlines the candidate standard levels associated with the two-lamp 

normal BF IS and RS 4-foot MBP product class. 

CSL1. BEF: 1.450; Efficiency: 85.4 percent 

This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It 

requires the use of improved lamp diameters (T8 instead of T12). Therefore, no T12 

ballasts meet this level. In addition, ballasts must use improved circuit designs (a starting 

method that is IS rather than RS). 

CSL2. BEF: 1.535; Efficiency: 90.5 percent 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

 

 

 

 

 

This level affects both baseline ballasts. However, no T12 ballast that is commercially 

available can meet this level. Ballasts at this level use better components and more 

efficient circuit designs than those ballasts that just meet CSL1. 

CSL3. BEF: 1.561; Efficiency: 92.0 percent 

This level again affects both baseline ballasts and represents the maximum 

technologically feasible level. This level represents a modest improvement in efficiency 

over CSL2. Ballasts at this level again use slightly better components and circuit designs 

than those ballasts that just meet CSL2. 

Chapter 5 of the preliminary TSD provides a more detailed discussion on how 

DOE selected baselines and CSLs for all representative product class, which technologies 

they represent, and which design option lamps DOE used at these CSLs for each 

representative unit. Table 2.6.3 outlines the CSLs for all representative product classes: 

Table 2.6.3 Summary of Proposed Candidate Standard Levels for Representative 

Fluorescent Lamp Ballast Product Classes 

Representative Product Class 

CSL1 CSL2 CSL3 

BEF BEF BEF 

Two-Lamp Normal BF 4-Foot MBP IS & RS 1.450 1.535 1.561 

Two-Lamp Normal BF 4-Foot MBP PS 1.518 N/A N/A 

Four-Lamp Normal BF 4-Foot MBP IS & RS 0.781 N/A N/A 

Four-Lamp Normal BF 4-Foot MBP PS 0.755 N/A N/A 

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.441 1.482 N/A 

Two-Lamp 4-foot T5 MiniBP HO 0.791 0.837 N/A 

Two-Lamp Normal BF 8-Foot SP Slimline 0.807 N/A N/A 

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.500 0.549 N/A 

Two-Lamp Low BF 4-Foot MBP IS & RS Residential 1.457 1.492 N/A 

Four-Lamp Sign Ballasts 0.238 N/A N/A 

2.6.4 Results 

As discussed above, DOE evaluated multiple baseline ballasts for the relevant 

product classes to provide a comprehensive understanding of the consumer economics. 

DOE based its engineering analysis on two substitution cases. In the first case, the 

consumer is not allowed to change the spacing of their fixtures and therefore replaces one 

baseline ballast with a more efficacious ballast. In this case, light output is maintained to 

within 10 percent of the baseline system lumen output. Percentage change in mean lumen 

output is show in each table below. In the second case, the consumer is allowed to change 

the spacing of the fixture. To show how energy savings would change due to this change, 

DOE shows the normalized system input power. The following formula is used to 

normalize the system input power of the standards-case system to the mean lumen output 

of the baseline system: 

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EERE-2007-BT-STD-0016 COMMENT 25
MLOBaseline NormalizedInputPower = ∗ InputPower S tan dardsCase S tan dardsCase MLOS tan dardsCase 

Equation 2.6.1 

NormalizedInputPowerS = Input power of the standards-case system that tan dardsCase 

matches the light output of the baseline system 

MLOBaseline = Mean lumen output of the baseline system 

MLOS = Mean lumen output of the standards-case system tan dardsCase 

InputPowerS tan = Input power of the standards-case system dardsCase 

The results tables also present the retail price of the replacement lamps (e.g., if it 

is a two-lamp system the retail price is the price of two lamps). Table 2.6.4 presents the 

engineering characteristics of the ballast replacement options for the baseline F32T8 

system in the two-lamp 4-foot MBP normal BF RS and IS product class. Because the BFs 

of the standards-case systems are slightly lower than the baseline system, the normalized 

input power is slightly higher than the measured input power. If a direct substitution is 

made, mean lumen output does not change by more than 2 percent relative to the mean 

lumen output of the baseline system. 

For all F32T8 ballasts, DOE generated an MSP from teardowns. As shown in 

Table 2.6.5, physical teardown information suggests that the F32T8 ballast at CSL3 is 

less costly than the less efficient CSL2 ballast, but both CSL2 and CSL3 are more costly 

than CSL1. 

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EERE-2007-BT-STD-0016 COMMENT 25
Table 2.6.4 Two-Lamp Four-Foot MBP RS and IS Product Class with F32T8 Baseline 

Candidate Standard 

Level 

For Operation of

Ballast Type

Starting Method 

Input Voltage

Universal or Single

Voltage 

Power Factor

THD 

Ballast Factor 

Input Power 

BEF

Ballast Efficiency 

System Initial 

Light Output

System Mean

Light Output

V W lm lm 

Baseline 

/CSL1 

Two F32T8 

Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%* 5,250 4,988 

CSL2 Two F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 CSL3 Two F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 

*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and balla

active mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the fol

Table 2.6.5 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 sy4-foot MBP normal BF RS and IS product class. If a direct substitution is made, mean lumen output does not chapercent from that of the baseline system. For the F34T12 baseline ballast, DOE used the online price scaling techprice. DOE found that the MSP for the F34T12 ballast was higher than for any of the F32T8 ballasts. The F34T1sold at lower volumes than the electronic F32T8 ballasts represented by CSL1, CSL2, and CSL3. DOE attributes volume to its high cost relative to efficiency. 2-42 

EERE-2007-BT-STD-0016 COMMENT 25
Table 2.6.5 Two-Lamp Four-Foot MBP RS and IS Product Class with F34T12 Baseline 

Candidate Standard 

Level 

For Operation of

Ballast Type

Starting Method 

Input Voltage

Universal or Single

Voltage 

Power Factor

THD 

Ballast Factor 

Input Power 

BEF

Ballast Efficiency 

System Initial 

Light Output

System Mean

Light Output

V W lm lm 

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0.98 <20% 0.86 63.5 1.359 80.1%* 5,412 4,872 

CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%* 5,250 4,988 CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 

*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and balla

active mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the fol

BEF=1.697*BE. 

2-43 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

Chapter 5 of the preliminary TSD presents results for all other product classes. 

2.6.5 Scaling Between Product Classes 

As discussed earlier, DOE reduced the analytical burden associated with fluorescent lamp 

ballasts by identifying and studying select representative units for analysis. DOE then 

extrapolated the findings from those representative ballasts to other covered product classes that 

were not analyzed. 

At the public meeting, DOE discussed scaling to other product classes and requested 

comments. NEMA advised DOE to be careful when extrapolating efficiency metrics from one 

product type to another, particularly with respect to BEF as BEF is lamp dependent. (NEMA, 

No. 11 at pp. 5-6) Therefore, DOE is establishing a test procedure that requires manufacturers to 

use one type of load if operating a specific type of lamp (e.g., a 4-foot MBP T8 lamp). For more 

information on that test procedure, see section 2.2.2. DOE also recognizes that BEF depends on a 

variety of other factors, like the number of lamps a ballast operates. Therefore, in scaling product 

classes, DOE will examine test data to develop scaling relationships for all factors that affect the 

BEF of the ballast, including dependence on the lamp. Chapter 5 of the preliminary TSD 

presents detail on the scaling relationships between product classes and DOE’s methodology. 

DOE invites comments on the use of this scaling relationship to extrapolate findings from the 

representative product classes to other product classes. 

2.6.6 Price Analysis 

Developing the manufacturer selling price for different fluorescent lamp ballasts involved 

two main inputs, a teardown analysis to develop the manufacturer product costs and a markup 

analysis to arrive at the MSP. Figure 2.6.1 shows the general breakdown of costs and profit 

associated with manufacturing and selling a product. The full cost of production is broken down 

into two main costs, the full production cost or manufacturing production cost, and the nonproduction cost. The non-production cost is equal to the manufacturer markup minus profits. 

DOE totaled the cost of materials, labor, and direct overhead used to manufacture a product in 

order to calculate the MPC.x 

x

 When viewed from the company-wide perspective, the sum of all material, labor, and overhead costs equals the 

company’s sales cost, also referred to as the cost of goods sold (COGS). 

2-44 

EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

 

Figure 2.6.1 Full Production Costs 

The MPC is composed of direct labor, direct material, and overhead costs. Direct material 

costs represent the direct purchase price of components (resistors, connecting wires, etc.). To 

estimate direct material and labor costs for early 2009 (the time at which the ballast teardowns 

occurred), DOE obtained customized teardown analyses for certain fluorescent lamp ballasts. 

DOE estimated the manufacturer overhead from a representative electronic fabrication 

company’s U.S. Securities and Exchange Commission (SEC) 10-k’s aggregated confidential 

manufacturer selling prices. 

NEMA expressed concern that a change in commodity materials prices would affect 

payback calculations for ballasts. (NEMA, No. 11 at p. 6; Advance, Public Meeting Transcript, 

No. 9 at p. 133) DOE understands that prices for ballast components have fluctuated in the past. 

To establish the price for an average ballast, DOE determined the January 2009 commodity price 

index and a 5-year average commodity price index (spanning 2004 through 2008) for each 

component from the Bureau of Labor Statistics Producer Price Indices (PPIs).y

 DOE then 

evaluated how the January 2009 material costs for ballasts varied from the 5-year average price 

for all ballasts. Although there was a large difference in cost for some components, overall, the 

difference in ballast price between the 2009 index and the 5-year average was negligible. 

Therefore, DOE believes that the prices in the engineering analysis as estimated in 2009 reflect a 

long-term average for commodity prices. For more information on this analysis, see chapter 5 

and appendix 5A of the preliminary TSD. DOE requests comments on this analysis. 

DOE carefully selected ballasts for the teardown analysis to create useful data to estimate 

manufacturer production costs. DOE mapped out a matrix of product specifications and selected 

ballasts so that comparisons could be made among ballasts that differed by only one 

characteristic (such as starting method or input voltage). Ballasts are described by a long list of 

specifications, so DOE concentrated on the specifications that were expected to have the greatest 

impact on efficiency—high versus regular advertised efficiency, maximum number of lamps 

driven, starting method, and universal versus single input voltage. DOE submitted 13 ballasts for 

teardowns. For the CSLs that these ballasts just met, DOE assigned the MPC from the teardown 

directly to the CSL. 

y

 U.S. Department of Labor, Bureau of Labor Statistics, Producer Price Indices. Last accessed May 13, 2009. 

<http://www.bls.gov/ppi>. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

DOE was able to select only unpotted ballasts for the teardown analysis. Some ballast 

manufacturers add potting, a type of black pitch, to the ballast enclosure to improve durability 

and manage heat distribution. Because the sticky potting inhibits visual observation of the 

components, DOE was unable to reverse engineer many ballasts through a teardown analysis. 

To estimate MPCs for ballasts that were not submitted for teardowns, DOE used online 

ballast supplier pricing to develop ratios relating online prices to teardown-sourced MPCs. After 

developing a ratio specific to each manufacturer, DOE could then estimate the MPC for a 

particular CSL. DOE identified ballasts from multiple manufacturers that just meet the CSL and 

then marked down the online prices to the MPC using the manufacturer-specific MPC ratio. 

DOE averaged the MPCs for all the ballasts just meeting the CSL to calculate the MPC. 

Once MPCs were assigned to each CSL, DOE developed a markup to scale the MPC to 

the manufacturer selling price. DOE relied on income statements found in 10-K reports from 

publicly owned ballast manufacturing companies. Using multi-year average financial data, DOE 

used the ratio of net sales to cost of goods sold to mark up the MPC to the MSP. 

As NEMA suggested at the framework public meeting, DOE also contacted individual 

manufacturers for price data on a confidential basis. (NEMA, Public Meeting Transcript, No. 9 at 

p. 141) Using this confidential data, DOE was able to verify scaled prices and appropriate 

markup and overhead estimates. The Joint Comment recommended that when using 

manufacturer data, DOE should use the minimum cost data submitted rather than the average 

cost data because the low-cost manufacturer determines prices in a market in equilibrium. (Joint 

Comment, No. 12 at p. 13) Because DOE used a “bottom up” approach by generating MPCs 

from BOMs and marking up the MPC to an MSP, DOE did not need to choose between 

minimum cost and average cost data. When calculating the MPC through the BOM, DOE 

assigned prices to components based on high volume purchasing. DOE believes this method 

generated an accurate estimation of the MSP. 

The Joint Comment urged DOE to review revealed pricing for the 2000 Ballast Rule to 

calibrate the accuracy of DOE price predictions. In addition, the Joint Comment recommended 

that in developing a calibration of revealed prices, DOE should separate commodity price 

impacts from impacts associated with a new efficiency standard. (Joint Comment, No. 12 at p. 

13) 

DOE believes that it should not calibrate prices based on revealed historical pricing for 

two reasons. First, DOE is not using same pricing methodology as it used in the 2000 Ballast 

Rule. The methodology in the 2000 Ballast Rule relied on surveying distributors of magnetic and 

electronic ballasts to determine the appropriate distributor price and then using one markup to 

reflect the end user price.z

 Because DOE is using a different methodology to develop ballast 

prices (a reverse engineering cost estimate), DOE feels a calibration would be inappropriate. 

Second, DOE believes that conditions may be significantly different for the 2000 Ballast Rule 

z

 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for 

Consumer Products: Technical Support Document: Energy Conservation Standards for Consumer Products: 

Fluorescent Lamp Ballasts. Chapter 3: Engineering Analysis. September 2000. Washington, D.C. < 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf> 

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EERE-2007-BT-STD-0016 COMMENT 25
than they are today. For example, there have been substantial fluctuations in energy prices; 

pressure to move manufacturing facilities out of the United States; and changes in distribution 

channels, such as the dominance of “big box” retailers. For similar reasons, markups may not 

follow past behavior because numerous factors influence business costs and decisions on profit 

margins throughout the distribution chain. For these reasons, DOE does not believe it should 

calibrate the prices in this analysis according to historical pricing. For more information on 

DOE’s price analysis, see chapter 5 of the preliminary TSD. 

2.6.7 Other Key Issues 

NEMA expressed concern that several possible upcoming regulations would affect the 

engineering and LCC analysis for fluorescent lamp ballasts. Specifically, NEMA is concerned 

about four possible regulations: safety requirements for system interconnects, safety 

requirements for lamp end-of-life protection, electromagnetic field requirements, and hazardous 

material regulation. NEMA stated that these potential requirements could result in lower ballast 

efficiency and affect payback calculations (NEMA, No. 11 at p. 6; NEMA, Public Meeting 

Transcript, No. 9 at pp. 133-134) 

DOE agrees that safety requirements for system interconnects and lamp end-of-life might 

lower the efficiency of commercially available ballasts. However, DOE is not able to account for 

this lower efficiency until the requirements are established. For DOE to prepare for this possible 

regulation, DOE requests comments on how these requirements will affect the efficiency of 

commercially available ballasts. DOE also requests information on how safety requirements may 

affect the cost of both low and high efficiency ballasts so that DOE can assess how these 

requirements might affect payback calculations. 

NEMA also expressed concern about possible electromagnetic field regulations. 

Specifically, NEMA is concerned that current internationally accepted electromagnetic 

interference (EMI) levels may be modified. (NEMA, No. 11 at p. 6; Advance, Public Meeting 

Transcript, No. 9 at pp. 133-134) DOE believes that if EMI levels are modified, the efficiency of 

commercially available ballasts may be lowered. However, DOE is not able to account for this 

lower efficiency until the requirements are established. Again, to prepare for this potential 

regulation, DOE requests comments on how these requirements will affect the efficiency of 

commercially available ballasts. DOE also requests information on the cost of both low and high 

efficiency ballasts that meet these regulations so that DOE can assess how these requirements 

may affect payback calculations. 

Finally, NEMA expressed concern that hazardous material regulations may be 

implemented. If implemented, NEMA believes these regulations could affect component 

availability and payback calculations. (NEMA, No. 11 at p. 6; NEMA, Public Meeting 

Transcript, No. 9 at p. 133) DOE believes that if hazardous material regulations are 

implemented, the cost of ballasts may be higher. If costs increase more or less for higher 

efficiency ballasts than for lower efficiency ballasts, then payback calculations will be affected. 

As stated above, however, DOE cannot account for this effect unless regulations are established. 

DOE requests comments on when NEMA believes hazardous material regulations may be 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

 

adopted and how these requirements will affect the cost or efficiency of commercially available 

ballasts. 

2.7 ENERGY USE AND END-USE LOAD CHARACTERIZATION 

The energy use characterization provides estimates of annual energy use for 

representative lamp-and-ballast systems that DOE evaluates in the LCC and PBP analyses and 

the NIA. To develop annual energy use estimates, DOE multiplied annual usage (in hours per 

year) by the system input power (in watts). 

DOE selected the most common fluorescent lamp used with each analyzed ballast to 

develop representative lamp-and-ballast systems. Fluorescent lamps will not be regulated under 

the proposed ballast rulemaking; however, the input power of the complete lamp-and-ballast 

system is considered for the energy use analysis because ballasts are not intended to operate 

without lamps. DOE developed the system input power estimates in the engineering analysis 

(chapter 5 of the preliminary TSD). To characterize the country’s average use of lamp-andballast systems for a typical year, DOE developed annual operating hours by sector, using data 

published in the U.S. Lighting Market Characterization: Volume I (LMC), Residential Energy 

Consumption Survey (RECS), the Commercial Building Energy Consumption Survey (CBECS), 

and the Manufacturer Energy Consumption Survey (MECS). 

Lighting controls can reduce operating hours for affected lamp-and-ballast systems. At 

the public meeting, NYSERDA asked if DOE would consider lighting controls in its analyses 

(NYSERDA, Public Meeting Transcript, No. 9 at p. 151). With the exception of PS ballasts— 

which are often paired with occupancy sensors to maintain or extend lamp life—DOE did not 

modify the operating hour data from LMC for other ballast product classes in the preliminary 

analyses. While DOE recognizes that there probably are more lighting controls in use today, 

DOE does not believe the level of penetration would be significantly different from LMC, which 

was published in 2002. Further, DOE believes the overall national level of penetration of lighting 

controls at the individual level (i.e., those that would respond to one individual’s office) is still 

relatively low. Finally, DOE is unsure how it would account for lighting controls, as there is 

uncertainty about which control systems are being recommended, and DOE was not able to 

identify nationally representative data sources on the impact of lighting controls. However, DOE 

invites additional comments on this issue, particularly on the type, prevalence, and operating 

hour reductions due to lighting controls used separately in the commercial, industrial, and 

residential sectors. 

In the case of PS ballasts operating 4-foot MBP T8 lamps, DOE assumed these lamp-andballast systems are operated on occupancy sensors in the commercial sector. Based on the range 

of estimated energy savings from occupancy sensors, DOE assumed energy savings of 30 

percent and accounted for these energy savings with a 30 percent reduction in average operating 

hours for affected lamp-and-ballast systems.aa 

aa E Source. Purchasing Advisor Web Page – Lighting: Occupancy Sensors. 2009. (Last Accessed May 5, 2009.) 

<http://www.esource.com/BEA/demo/BEA_esource/PA_10.html> 

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EERE-2007-BT-STD-0016 COMMENT 25
See chapter 6 of the preliminary TSD for additional detail on the energy use 

characterization. 

2.8 MARKUPS ANALYSIS 

In this rulemaking, DOE performed teardown analyses and a manufacturer markup 

analysis to develop MSPs for representative ballast designs (chapter 5 of the preliminary TSD). 

DOE then applied distribution channel markups and sales tax to derive end-user prices. By 

combining the engineering analysis results and the distribution channel markups analysis, DOE 

derived typical inputs for use in the LCC analysis and the NIA. 

The end-user equipment price depends on how the end-user purchases the equipment. As 

illustrated in Figure 2.8.1, two types of distribution channels describe how most ballasts pass 

from the manufacturer to the end-user. The first distribution channel applies to ballasts installed 

in fixtures. In this distribution channel, the manufacturer sells the ballast to an original 

equipment manufacturer (OEM)—in this case, the fixture manufacturer—who in turn sells it to 

an electrical wholesaler (i.e., distributor), then to a contractor, and finally to the end-user. The 

second distribution channel applies to ballasts not installed in fixtures (e.g., replacement 

ballasts). In this distribution channel, the manufacturer sells the ballast to an electrical 

wholesaler, then to a contractor, and finally to the end-user. 

Figure 2.8.1 Ballast Distribution Channels 

Publicly owned companies are required to disclose financial information on a regular 

basis by filing different forms with the U.S. Securities and Exchange Commission (SEC). Filed 

annually, SEC form 10-K provides a comprehensive overview of the company’s business and 

financial conditions. To estimate OEM and wholesaler markups, DOE used financial data from 

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EERE-2007-BT-STD-0016 COMMENT 25
10-K reports from publicly owned lighting fixture manufacturers and electrical wholesalers, 

respectively. DOE assumed a contractor markup consistent with that used in the 2000 Ballast 

Rule, and developed sales tax values using current State and local sales tax data. Chapter 7 of the 

preliminary TSD provides details of the markups analysis. 

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

Energy conservation standards on equipment usually reduce operating expenses and 

increase end-user prices. DOE analyzed the net effect of amended standards on end-users by 

evaluating the net LCC using the cost-efficiency relationship derived in the engineering analysis, 

as well as the energy usage and costs derived from the energy use characterization. Inputs to the 

LCC calculation include the installed cost to the end-user (purchase price plus installation cost), 

disposal costs (ballast and lamp recycling), operating expenses (energy expenses and 

maintenance costs), the lifetime of the ballast, and a discount rate. Chapter 8 of the preliminary 

TSD describes these inputs. 

At the framework public meeting, Osram Sylvania commented that installation and 

maintenance costs should not differ between the baseline and standards-case ballast designs. 

(Osram Sylvania, Public Meeting Transcript, No. 9 at p. 165) DOE agrees, but distinguished the 

ballast replacement and new construction/renovation purchasing events by adding 2.5 minutes of 

labor time for installing a luminaire disconnect in the new construction/renovation case. This 

additional labor time and cost are not related to ballast design, but instead reflect current 

National Electric Code requirements for new fixture installations. 

When a ballast or fluorescent lamp fails, some consumers choose to recycle the system 

components. The cost of recycling the ballast or lamp is its disposal cost. Ballast recycling rate 

data were not available, so DOE conservatively assumed 5 percent of ballasts used in the 

commercial and industrial sectors were recycled, and that no ballasts are recycled in the 

residential sector. One commenter noted that DOE should address the energy consumption 

required for ballast disposal and recycling in its LCC and PBP analyses, (Farrior, No. 10 at p. 2) 

DOE was not, however, able to obtain sufficiently detailed information on ballast recycling rates 

or methods to estimate associated energy consumption and costs. 

DOE estimates electricity prices for commercial, industrial, and residential consumers by 

using Energy Information Administration (EIA) data. EIA’s Annual Energy Outlook (AEO2009) 

was the default source of projections for future electricity prices. DOE received a number of 

comments on the potential effects of energy-efficient ballast designs on electricity demand 

charges and how DOE accounts for these effects in its LCC and PBP analyses. (ASAP, Public 

Meeting Transcript, No. 9 at pp. 159, 161–162; Joint Comment, No. 12 at p. 12; NYSERDA, 

Public Meeting Transcript, No. 9 at p. 161; Osram Sylvania, Public Meeting Transcript, No. 9 at 

pp. 160, 162) Similarly, the Joint Comment discussed how DOE’s approach to forecasting 

energy prices does not consider impacts of amended standards on utility infrastructure, natural 

gas demand, or overall electricity costs. (Joint Comment, No. 12 at pp. 11–12) 

Factors such as infrastructure impacts and demand charge effects would primarily be 

addressed in the utility impacts analysis. DOE bases this analysis on the Buildings version of the 

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EERE-2007-BT-STD-0016 COMMENT 25
 

 

National Energy Modeling System (NEMS-BT), which does not have the capability to address 

demand load profiles (i.e., usage by time of day). Therefore, DOE is unable to quantify the 

potential impacts on peak demand for electricity from changes in product efficiency. DOE also 

considered reporting overall natural gas and electricity price impacts but found that the 

uncertainty of price projections, together with the fairly small anticipated impact of the amended 

standards relative to total electricity demand, makes these price changes highly uncertain. Given 

the current complexity of utility regulation in the United States (with significant variances 

among States), it does not seem appropriate to attempt to measure impacts on infrastructure costs 

and prices where there is likely to be significant overlap. As a result, DOE believes that they 

should not be weighed heavily in the decision concerning the standard level. 

Several commenters noted that DOE should consider whether energy-efficient ballasts 

have a longer lifetime, based on presumed cooler operating temperatures. (ASAP, Public 

Meeting Transcript, No. 9 at pp. 166–167; Joint Comment, No. 12 at p. 8; Philips, Public 

Meeting Transcript, No. 9 at pp. 167–168) Philips also commented on the trend toward compact 

design in the lighting industry and how this would result in higher operating temperatures. 

(Philips, Public Meeting Transcript, No. 9 at p. 168) DOE acknowledges the trend toward 

compact design in energy-efficient ballasts and fixtures, and assumes a compact format will 

result, on average, in ballast operating temperatures equal to or greater than those for current 

ballast designs. Consequently, DOE assumes no extended life for energy efficient ballast designs 

in this rulemaking. NEMA and Osram Sylvania commented that energy efficient ballast designs 

should not affect lamp life. (NEMA, No. 11 at p. 8; Osram Sylvania, Public Meeting Transcript, 

No. 9 at pp. 165–166) DOE agrees with these comments and did not assume any extended lamp 

life in its LCC and PBP analyses. 

DOE developed discount rates by estimating the cost of capital to end users that purchase 

the ballasts covered under this rulemaking. For commercial and industrial end users, DOE used 

the cost of capital to estimate the present value of cash flows to be derived from a typical 

company project or investment. Most companies use both debt and equity capital to fund 

investments, so the cost of capital is the weighted-average cost to the firm of equity and debt 

financing. This corporate finance approach is referred to as the weighted-average cost of capital. 

DOE used currently available economic data in developing discount rates and will update the 

data as appropriate for the NOPR stage of this rulemaking. 

For residential end users, DOE derived the discount rates from estimates of the interest or 

“finance cost” to purchase residential products. The finance cost of raising funds to purchase 

residential products can be interpreted as (1) the financial cost of any debt incurred to purchase 

residential products, principally interest charges on debt; or (2) the opportunity cost of any equity 

used to purchase residential products, principally interest earnings on household equity. 

Household equity is represented by holdings in assets such as stocks and bonds, as well as the 

return on homeowner equity. DOE obtained data required to determine the cost of debt and 

equity from the Federal Reserve Board’s triennial Survey of Consumer Finances. 

For more detail on the LCC and PBP analyses, see chapter 8 of the preliminary TSD. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

2.10 SHIPMENTS ANALYSIS 

Shipments of ballasts are key inputs to the national energy savings and net present value 

calculations in the NIA model. Shipments are also a necessary input to the MIA, which DOE will 

conduct for the NOPR stage of this rulemaking. DOE requested but was not able to obtain 

manufacturer historical shipments data for the preliminary analysis. Consequently, DOE 

followed a three-step process to forecast ballast shipments. First, DOE used historical shipment 

data from the U.S. Census Bureau to estimate the total historical shipments of each ballast type 

analyzed. Second, DOE calculated an installed stock for each ballast type based on the average 

service lifetime of each ballast type. Third, by modeling ballast purchasing events, such as 

replacement and new construction, and applying growth rate, replacement rate, and emerging 

technologies penetration rate assumptions, DOE developed annual shipment projections. 

At the public meeting, Philips and Osram Sylvania commented on anticipated impacts of 

emerging technologies (e.g., solid-state lighting), lighting controls, and daylight harvesting on 

future ballast shipments. (Philips, Public Meeting Transcript, No. 9 at pp. 176, 189–191; Osram 

Sylvania, Public Meeting Transcript, No. 9 at pp. 193–194) DOE addressed emerging 

technologies in its shipments analysis using assumptions and methodology from the 2009 Lamps 

Rule. To address lighting controls (e.g., occupancy sensors), DOE modeled the growing market 

for 4-foot T8 MBP systems using PS ballasts but lacked sufficient information to model the 

market effects of other control types, including those used for daylight harvesting. Acuity Brands 

Lighting commented that DOE should consider the effects of California energy efficiency 

regulations on future ballast shipments. (Acuity Brands Lighting, Public Meeting Transcript, No. 

9 at p. 200) For its preliminary analyses, DOE conducted manufacturer interviews to help 

identify future shipment trends, and assumes that these trends integrate various regulatory and 

non-regulatory initiatives in the lighting marketplace. 

To determine the cumulative NES and NPV of amended standards, DOE compared 

forecasted shipments of a base to a standards case over the NIA analysis period. Chapter 9 of the 

preliminary TSD provides details on the shipments analysis. 

2.11 NATIONAL IMPACT ANALYSIS 

The national impact analysis assesses the net present value of total end-user LCC and 

NES. DOE determined both the NPV and NES for the performance levels considered for the 

ballast product classes analyzed. To make the analysis more transparent to all interested parties, 

DOE prepared an NES spreadsheet model to forecast energy savings and the national economic 

costs and savings resulting from amended standards. The NES model does not use probability 

distributions for inputs or outputs. To assess the impact of input uncertainty on the NES and 

NPV results, DOE can conduct sensitivity analyses by running scenarios on input variables 

relevant to interested parties. DOE assessed the aggregate economic impacts at the national level 

for this preliminary analysis. 

The Joint Comment noted that DOE’s current NIA methodology does not sufficiently 

address energy price impacts, environmental externalities, or other broad consumer impacts. 

(Joint Comment, No. 12 at p. 11) DOE acknowledges that there may be certain “external” 

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EERE-2007-BT-STD-0016 COMMENT 25
 

benefits resulting from the improved efficiency of ballasts that are not captured by equipment 

users. These include both environmental and energy security-related externalities that are not 

already reflected in energy prices, such as reduced emissions of greenhouse gases and reduced 

use of natural gas and oil for electricity generation. DOE invites comments on the nature and 

magnitude of these impacts. 

2.11.1 National Energy Savings Analysis 

The inputs for determining NES are (1) annual energy consumption per unit; (2) 

shipments; (3) equipment stock; (4) national energy consumption (calculated from consumption 

per unit and equipment stock); (5) site-to-source conversion factors; (6) a heating, ventilation, air 

conditioning (HVAC) factor; and (7) rebound rates. 

DOE calculated the national energy consumption by multiplying the number of units, or 

stock, of lamp-and-ballast systems (by vintage, which represents the age of the ballasts) by the 

unit energy consumption (also by vintage). Then, DOE calculated national annual energy savings 

from the difference between national energy consumption in the base case (without amended 

efficiency standards) and in each higher-efficiency standards case. DOE estimated energy 

consumption and savings based on site energy, and converted the electricity consumption and 

savings to source energy. DOE also examined potential energy savings due to HVAC 

interactions, as well as rebound effects (an energy savings “take-back”) based on consumer 

usage patterns. Cumulative energy savings are the sum of the annual NES, which DOE 

determined over specific time periods. 

2.11.2 Net Present Value Analysis 

The inputs DOE used to determine the NPV were (1) total annual installed cost, (2) total 

annual operating cost savings, (3) discount factor, (4) present value of costs, and (5) present 

value of savings. DOE calculates net savings each year as the difference between total operating 

cost savings and increases in total installed costs (including equipment price and installation 

cost). DOE calculates savings over the life of the equipment, accounting for differences in yearly 

energy rates. DOE calculates NPV as the difference between the present value of operating cost 

savings and the present value of increased total installed costs. DOE discounts future costs and 

savings to the present with a discount factor. 

DOE calculated increases in total installed costs as the product of the difference in the 

total installed cost between the base case and standards case and the annual shipments in the 

standards case. Because purchase costs of the higher-efficiency equipment in the standards case 

are generally greater than the purchase costs of equipment in the base case, price increases 

appear as negative values in the NPV. DOE expressed operating cost savings as decreases in 

operating costs associated with the lower energy consumption of equipment in the standards case 

compared to the base efficiency case. Total operating cost savings are the product of savings per 

unit and the number of units of each vintage surviving in a particular year. 

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EERE-2007-BT-STD-0016 COMMENT 25
 

The Joint Comment urges DOE to give primary weight to NPV results based on the 3­

percent discount factor, citing academic research that indicates appropriate societal discount rates 

of 3 percent or less. (Joint Comment, No. 12 at p. 13) In its preliminary analyses, DOE estimated 

national impacts with both a 3-percent and 7-percent real discount rate, per OMB guidelines on 

discount factors used in regulatory analyses. (OMB Circular A-4 (September 17, 2003), 

particularly section E, “Identifying and Measuring Benefits and Costs”) Consistent with this 

guidance, DOE will use 3-percent and 7-percent real discount rates for relevant calculations in 

the NOPR stage of this rulemaking. 

2.11.3 Efficiency Scenarios and Trends 

Several of the inputs for the determination of NES (e.g., the annual energy consumption 

per unit) and NPV (e.g., the total annual installed cost and the total annual operating cost 

savings) depend on equipment efficiency. Thus, DOE developed base case and standards case 

efficiency trends. These trends specified the annual historical and forecasted shipment-weighted 

average equipment efficiencies. 

For ballasts, DOE developed two shipment scenarios: “roll up” and “shift.” The roll-up 

scenario represents a standards case in which all product efficiencies in the base case that do not 

meet the standard would roll up to meet the new standard level. Consumers in the base case who 

purchase ballasts above the standard level are not affected as they are assumed to continue to 

purchase the same base-case ballast or lamp-and-ballast system. The roll-up scenario 

characterizes consumers primarily driven by the first-cost of the analyzed equipment. 

In contrast, the shift scenario models a standards case in which the standard affects all 

base-case consumer purchases (regardless of whether their base-case efficiency is below the 

standard). In this scenario, any consumer may purchase a more efficient ballast. As the standard 

level increases, market share incrementally accumulates at the highest standard level because it 

represents max tech (i.e., moving beyond this efficiency level is not achievable with today’s 

technology). The shift scenario characterizes consumers primarily concerned with system energy 

consumption and reflects an upper bound scenario. 

Chapter 10 of the preliminary TSD provides additional details on the national impacts 

analysis. 

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS 

The LCC subgroup analysis evaluates economic impacts on selected groups of consumers 

who might be adversely affected by a change in the national energy conservation standards for 

the considered products. DOE evaluates impacts on particular subgroups of consumers in part by 

analyzing the LCC impacts and PBP for those particular consumers. 

DOE will use the LCC spreadsheet model to evaluate impacts on consumer subgroups. 

DOE can analyze the LCC for any subgroup by applying the LCC spreadsheet model to only that 

subgroup. DOE is particularly sensitive to increases in the consumer price of the considered 

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products as it wishes to avoid a negative economic impact on any identified consumer subgroup. 

See chapter 11 of the preliminary TSD for more information on the LCC subgroup analysis. 

2.13 MANUFACTURER IMPACT ANALYSIS 

The purpose of the MIA is to identify the likely impacts of higher energy conservation 

standards on manufacturers. The Process Rule provides guidance for conducting this analysis 

with input from manufacturers and other interested parties. DOE will apply this methodology to 

its evaluation of standards for fluorescent lamp ballasts. The Process Rule gives guidelines for 

considering financial impacts and a wide range of quantitative and qualitative industry impacts 

that might occur after adoption of a standard. For example, a particular standard level could 

require changes to manufacturing practices of fluorescent lamp ballasts. DOE will identify and 

discuss these impacts in interviews with manufacturers and other interested parties during the 

NOPR stage of the analysis. 

DOE will conduct the MIA in three phases, and will further tailor the analytical 

framework based on the comments it receives. In Phase I, DOE creates an industry profile to 

characterize the industry and identify important issues that require consideration. In Phase II, 

DOE prepares an industry cash-flow model and an interview questionnaire to guide subsequent 

discussions. In Phase III, DOE interviews manufacturers, and assesses the impacts of standards 

both quantitatively and qualitatively. DOE assesses industry and subgroup cash flow and NPV 

using the Government Regulatory Impact Model (GRIM). DOE then assesses impacts on 

competition, manufacturing capacity, employment, and regulatory burden based on manufacturer 

interview feedback and discussions. 

Until recently, DOE reported MIA results in its standards rulemakings only in the NOPR 

phase of the rulemaking. However, DOE is now evaluating and reporting preliminary MIA 

information at this preliminary analytical phase. DOE gathered the information for the analysis 

during the manufacturer interviews conducted after the engineering analysis. See chapter 12 of 

the preliminary TSD for more detail on the MIA. 

2.13.1 Sources of Information for the Manufacturer Impact Analysis 

Many of the analyses described above provide important information applicable to the 

MIA. Such information includes manufacturing costs and prices from the engineering analysis, 

retail price forecasts, and shipment forecasts. DOE will supplement this information with 

company financial data and other information gathered during interviews with manufacturers. 

The interview process plays a key role in the MIA. DOE aggregates information across 

manufacturers, creating a combined opinion or estimate for DOE. 

DOE conducts detailed interviews with manufacturers to gain insight into the range of 

potential impacts of standards. Typically, DOE solicits both quantitative and qualitative 

information during the interviews on the potential impacts of efficiency levels on sales, direct 

employment, capital assets, and industry competitiveness. DOE prefers an interactive interview 

process, rather than a written response to a questionnaire, because it helps clarify responses and 

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identify additional issues. Before the interviews, DOE will circulate a draft document showing 

estimates of the financial parameters based on publicly available information. DOE will solicit 

comments on these estimates during the interviews. See chapter 12 of the preliminary TSD for 

more detail on the methodology used in the MIA. 

2.13.2 Industry Cash-Flow Analysis 

The industry cash-flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of more stringent energy conservation standards on the industry. 

The GRIM analysis uses several factors to determine annual cash flows from an amended 

energy conservation standard: annual expected revenues; manufacturer costs, including cost of 

goods sold, depreciation, research and development, selling, and general and administrative 

expenses; taxes; and conversion capital expenditures. DOE compares the results against base 

case projections that involve no amended energy conservation standards. The financial impact of 

amended energy conservation standards is the difference between the two sets of discounted 

annual cash flows. Other performance metrics, such as return on invested capital, also are 

available from the GRIM. See chapter 12 of the preliminary TSD for more information on the 

industry cash-flow analysis. 

2.13.3 Manufacturer Subgroup Analysis 

Industry cost estimates are inadequate to assess differential impacts among subgroups of 

manufacturers because these subgroups may have different cost structures or regulatory 

frameworks that affect their respective business models. For example, small and niche 

manufacturers, or manufacturers whose cost structure differs significantly from the industry 

average, could experience a more negative impact. Ideally, DOE would consider the impact on 

every firm individually; however, because this usually is not possible, DOE typically uses the 

results of the industry characterization to group manufacturers exhibiting similar characteristics. 

During the interview process, DOE will discuss the potential subgroups and subgroup 

members it has identified for the analysis. DOE will encourage manufacturers to recommend 

subgroups or characteristics that are appropriate for the subgroup analysis. See chapter 12 of the 

preliminary TSD for more detail on the manufacturer subgroup analysis. 

2.13.4 Competitive Impacts Assessment 

Section 342 (6)(B)(i)(V) of EPCA directs DOE to consider any lessening of competition 

likely to result from imposition of standards. DOE will consider whether an amended energy 

conservation standard is likely to reduce industry competition and will ask the Attorney General 

to determine the impacts, if any. The assessment will be based on manufacturing cost data and 

information collected from manufacturer interviews. DOE will make a determined effort to 

gather and report firm-specific financial information and impacts. 

2.13.5 Cumulative Regulatory Burden 

DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or 

amended DOE standards and other regulatory actions affecting the same equipment. DOE will 

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analyze and consider the impact on manufacturers of multiple, equipment-specific regulatory 

actions. 

During the public meeting, several manufacturers raised concerns about existing 

regulations. Advance stated that California is very active and aggressive in writing legislation for 

energy efficiency for lighting products. Manufacturers look to the Federal government to keep 

the same standards across all 50 states. DOE should keep abreast of California's regulations to 

ensure that the same standards are in place across all States. (Advance, Public Meeting 

Transcript, No. 9 at pp. 200-201) Acuity Brands Lighting commented that section 3313(g) of 

EISA 2007 requires that the Administrator of General Services purchase more energy efficient 

lighting products that adhere to the Buy America Act. Because efficient electronics for lighting 

products are produced abroad, Acuity Brands Lighting suggested that DOE obtain an exemption 

from the Buy American provision of EISA 2007 for certain lighting equipment. (Acuity Brands 

Lighting, Public Meeting Transcript, No. 9 at pp. 93-94) 

In response to these comments, DOE investigated the regulations manufacturers 

mentioned in the market and technology assessment (chapter 3 of the preliminary TSD). In 

investigating the provisions in section 3313 (g) of EISA 2007, DOE agrees that the legislation 

may be burdensome for manufacturers but EPCA does not authorize DOE to allow for such an 

exemption. During the NOPR, however, DOE plans to further investigate overlapping burdens 

on the manufacturers of fluorescent lamp ballasts. 

2.13.6 Preliminary Results for the Manufacturer Impact Analysis 

DOE conducted a series of preliminary interviews with manufacturers to discuss impacts 

that may result from a regulatory standard for fluorescent lamp ballasts. In general, 

manufacturers and other parties identified three areas of concern: (a) impacts on profitability, (b) 

product conversion costs/diminishing returns to consumers, and (c) product innovation. 

2.13.7 Impacts on Profitability

 Some manufacturers commented that profit margins would decrease with the 

implementation of amended energy conservation standards, especially for the original equipment 

manufacturer (OEM) distribution channels. For example, a higher standard could cause 

consumers to switch from residential ballasts, which are more price sensitive, to less efficient 

lighting products. According to the manufacturers DOE interviewed, consistent profitability is 

not common across all types of fluorescent lamp ballasts. Manufacturers also noted that pricing 

is extremely variable depending on the application (commodities, old products, new products, 

niche, etc). Some products are sold at a loss, some are sold at cost to load overhead, and some 

are sold for a profit. 

2.13.8 Product Conversion Costs/Diminishing Returns to Consumers 

 Certain manufacturers commented that raising existing energy conservation standards 

would force them to purchase more expensive and energy efficient components to improve 

existing lines as well as design new product lines. The majority of those costs would be 

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attributed to engineering and education. Due to higher conversion costs associated with 

increasing energy conservation standards, consumers would eventually be confronted with more 

expensive products. 

2.13.9 Product Innovation 

 Manufacturers also expressed concern over the impact amended energy conservation 

standards would have on product innovation. Because personnel may be spending more time 

redesigning products to comply with standards, the resources available for the development of 

new products would significantly decrease. 

2.14 UTILITY IMPACT ANALYSIS 

The utility impact analysis includes an analysis of the effect of amended energy 

conservation standards on the electric and the gas utility industries. For this analysis, DOE will 

use a variant of NEMS, a large multi-sectoral, partial-equilibrium model of the U.S. energy 

sector that the EIA has developed throughout the past decade, primarily for preparing EIA’s 

AEO. In previous rulemakings, a variant of NEMS (currently termed NEMS-BT, BT referring to 

the DOE’s Building Technologies Program version of NEMS), was developed to better address 

the specific impacts of an energy conservation standard. 

Available in the public domain, NEMS produces a widely-recognized baseline energy 

forecast for the United States through 2030. The typical NEMS outputs include forecasts of 

electricity sales, prices, and electric generating capacity. DOE conducts the utility impact 

analysis as a scenario that departs from the latest AEO reference case. In other words, the energy 

savings impacts from amended energy conservation standards are modeled using NEMS-BT to 

generate forecasts that deviate from the AEO reference case. 

ASAP and the Joint Comment stated that DOE should address the impacts of amended 

standards on energy commodity prices. (ASAP, Public Meeting Transcript, No. 9 at p. 96; Joint 

Comment, No. 12 at pp. 9–11) For electric products such as fluorescent lamps and ballasts, DOE 

considered reporting gas and electricity price impacts but found that the uncertainty of price 

projections, together with the fairly small impact of the standards relative to total electricity 

demand, makes these price changes highly uncertain. As a result, DOE believes that changes to 

energy commodity prices should not be weighed heavily in the decision concerning the standards 

level. Given the current complexity of utility regulation in the United States, with significant 

variation among States, DOE did not believe it was appropriate to measure impacts on 

infrastructure costs and prices where there is likely to be significant overlap and uncertainty. 

DOE also received comments on the potential effects of amended standards on external 

benefits such as energy security (e.g., reduced natural gas usage), utility infrastructure, and 

pollution reductions. (ASAP, Public Meeting Transcript, No. 9 at pp. 95–96, 202–203; Joint 

Comment, No. 12 at pp. 9, 11–12) Historically, DOE’s approach to the utility impact analysis, 

based on NEMS, has been to evaluate the impact of standards only on utility energy sales. 

NEMS is not suited to characterizing impacts of standards on utilities other than those measured 

by sales, and DOE is unaware of any analytical tools that would enable an analysis of financial 

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impacts on utilities at a national level. Therefore, DOE plans to continue using NEMS for the 

utility impact analysis, but it invites input from interested parties on the potential use of other 

tools for such analysis. 

As discussed in section 0, DOE acknowledges external benefits of amended standards— 

such as energy security and pollution reductions—that are not captured solely by utilities or 

ballast end users, but also by the public. DOE invites comments on the nature and magnitude of 

these benefits. 

Chapter 13 of the preliminary TSD provides additional details on the utility impact 

analysis. 

2.15 EMPLOYMENT IMPACT ANALYSIS 

The imposition of standards can affect employment both directly and indirectly. Direct 

employment impacts are changes in the number of employees at the plants that produce the 

covered equipment and at affiliated distribution and service companies. DOE evaluates the direct 

employment impacts in the MIA. Indirect employment impacts may result from expenditures 

shifting between goods (the substitution effect) and changes in income and overall expenditure 

levels (the income effect). As part of the NOPR stage of this rulemaking, DOE will seek input 

from interested parties on the potential employment impact. and DOE will investigate the 

combined direct and indirect employment impacts in the employment impact analysis using the 

Pacific Northwest National Laboratory’s “Impact of Sector Energy Technologies” (ImSET) 

model. The ImSET model was developed for DOE’s Office of Planning, Budget, and Analysis to 

estimate the employment and income effects of energy-saving technologies on buildings, 

industry, and transportation. Compared to simple economic multiplier approaches, ImSET allows 

for more complete and automated analysis of the economic impacts of energy conservation 

investments. Details can be found in chapter 14 of the preliminary TSD. 

2.16 ENVIRONMENTAL ASSESSMENT 

The intent of the environmental assessment is to quantify and consider the environmental 

effects of amended energy conservation standards for fluorescent lamp ballasts. The primary 

environmental effects of these standards would be reduced power plant emissions resulting from 

reduced consumption of electricity. DOE will assess these environmental effects by using 

NEMS-BT to provide key inputs to its analysis. The portion of the environmental assessment 

that will be produced by NEMS-BT considers carbon dioxide (CO2), nitrogen oxides (NOX), and 

mercury (Hg). The environmental assessment also considers impacts on SO2 emissions. After a 

brief discussion of general methodology, this section will address each of the relevant emissions. 

This section then explains how DOE plans to monetize the benefits associated with emissions 

reductions. 

2.16.1 Carbon Dioxide 

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 emission 

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reductions likely to result from a standard will be estimated using NEMS-BT and national energy 

savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the 

difference between emissions estimated by NEMS-BT at each standard level considered and the 

AEO Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. 

2.16.2 Sulfur Dioxide 

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are 

likely to eliminate the standards’ impact on SO2 emissions. The costs of meeting such emission 

cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of 

the standards. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 emissions from 28 eastern States and the District of Columbia (DC) are also limited 

under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005. 

70 FR 25162 (May 12, 2005)), which creates an allowance-based trading program that will 

gradually replace the Title IV program in those States and DC. (The recent legal history 

surrounding CAIR is discussed below.) The attainment of the emissions caps is flexible among 

EGUs and is enforced through the use of emissions allowances and tradable permits. Under 

existing EPA regulations, any excess SO2 emission allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to permit 

offsetting increases in SO2 emissions by any regulated EGU. However, if the standard resulted in 

a permanent increase in the quantity of unused emission allowances, there would be an overall 

reduction in SO2 emissions from the standards. While there remains some uncertainty about the 

ultimate effects of efficiency standards on SO2 emissions covered by the existing cap and trade 

system, the NEMS-BT modeling system that DOE plans to use to forecast emissions reductions 

currently indicates that no physical reductions in power sector emissions would occur for SO2. 

Even if there is no significant reduction in the overall emissions of SO2 that results from 

the standard, there may still be some economic benefit from reduced demand for SO2 emission 

allowances that is not fully reflected in the cost savings experienced by individual consumers. 

Electricity savings that decrease the overall demand for SO2 emissions allowances could lower 

allowance prices and thereby result in some economic benefits for all electricity consumers, not 

just those that reduced their electricity use as a result of an efficiency standard. These lowered 

allowance prices were noted in ASAP’s comments. (ASAP, Public Meeting Transcript, No. 9 at 

pp. 206–207) DOE does not plan to monetize this particular benefit because the effect on the SO2 

allowance price from any single energy conservation standard is likely to be small and highly 

uncertain. 

2.16.3 Nitrogen Oxides 

NEMS-BT also has an algorithm for estimating NOX emissions from power generation. 

The impact of these emissions, however, will be affected by the CAIR, which the Environmental 

Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of 

NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005). 

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Much like SO2 emissions, a cap on NOX emissions means that the amended fluorescent 

lamp ballast standards may have little or no physical effect on these emissions in the 28 eastern 

States and the DC covered by CAIR. Although CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent with the Court’s July 11, 

2008, opinion in North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina 

v. EPA, 550 F.3d 1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce 

NOX emissions through participation in cap-and-trade programs for electric generating units, 

emissions from these sources are capped across the CAIR region. 

Standards may produce an environmental-related economic benefit in the form of lower 

prices for emissions allowance credits, as noted in ASAP’s comments. (ASAP, Public Meeting 

Transcript, No. 9 at pp. 206–207) As with SO2 allowance prices, DOE does not plan to monetize 

this particular benefit because the effect on the NOX allowance price from any single energy 

conservation standard is likely small and highly uncertain. 

Earth Justice requested that DOE quantify NOX emission reductions outside of areas 

where allowance trading occurs. (Earth Justice, Public Meeting Transcript, No. 9 at pp. 204–205) 

Accordingly, DOE plans to use NEMS-BT to estimate the emissions reductions from possible 

standards in the 22 States where emissions are not capped. 

2.16.4 Mercury 

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC 

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the DC 

Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the DC Circuit’s opinion on the CAMR. See 

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental 

Analysis. In the absence of CAMR, a DOE standard would likely reduce Hg emissions and DOE 

plans to use NEMS-BT to estimate these emission reductions. 

2.16.5 Particulate Matter 

DOE acknowledges that particulate matter (PM) impacts are of concern due to human 

exposures that can impact health. But impacts of PM emissions reduction are much more 

difficult to estimate than other emissions reductions due to the complex interactions between 

PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human 

exposure to particulates. Human exposure to PM usually occurs at a significant distance from the 

power plants that are emitting particulates and particulate precursors. When power plant 

emissions travel this distance, they undergo highly complex atmospheric chemical reactions. 

Although the EPA does keep inventories of direct PM emissions of power plants, in its source 

attribution reviews, the EPA does not separate direct PM emissions from power plants from the 

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sulfate particulates indirectly produced through complex atmospheric chemical reactions. The 

great majority of PM emissions from power plants are of these secondary particles (secondary 

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to assess the impact of these standards on particulate emissions. Further, even the 

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from 

other sources is unlikely to be significant. 

2.16.6 Monetization of Emissions Reduction Benefits 

Several commenters noted that there are also external benefits to pollutant emission 

reductions that should be monetized and weighed in DOE’s determination of maximum 

efficiency levels for ballasts. (ASAP, Public Meeting Transcript, No. 9 at p. 95; Joint Comment, 

No. 12 at pp. 9–10) For those emissions for which real national emission reductions are 

anticipated (CO2, Hg, and NOX for 22 states), only ranges of estimated economic values based on 

environmental damage studies of varying quality and applicability are available. Therefore, DOE 

plans on reporting estimates of monetary benefits derived using these values and plans to 

consider these benefits in weighing the costs and benefits of each of the standard levels 

considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2 emissions, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon 

(SCC) values developed and/or agreed to by interagency reviews. The SCC is intended to be a 

monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, 

including, but not limited to, net agricultural productivity loss, human health effects, property 

damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to 

monetize the harms associated with climate change will raise serious questions of science, 

economics, and ethics. But with full regard for the limits of both quantification and monetization, 

the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per 

metric ton in 2007 dollars. These values are then adjusted to 2009$ using the standard GDP 

deflator value for 2008 and 2009. For emissions (or emission reductions) that occur in later 

years, these values grow in real terms over time. Additionally, the interagency group determined 

that a range of values from 7 percent to 23 percent should be used to adjust the global SCC to 

calculate domestic effects, although preference will be given to consideration of the global 

benefits of reducing CO2 emissions. See appendix EA-SCC to the environmental assessment 

report in the preliminary TSD for the full range of annual SCC estimates from 2010 to 2050. To 

calculate a present value of the stream of monetary values, DOE will discount the values in each 

of the four cases using the discount rates that had been used to obtain the SCC values in each 

case. 

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

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DOE also intends to estimate the potential monetary benefit of reduced NOX, and Hg 

emissions resulting from the standard levels it considers. For NOX emissions, available estimates 

suggest a very wide range of monetary values for NOX emissions, ranging from $370 per ton to 

$3,800 per ton of NOX from stationary sources, measured in 2001$ (equivalent to a range of 

$442 to $4,540 per ton in 2008$). Refer to the OMB, Office of Information and Regulatory 

Affairs, “2006 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities,” for additional information. 

For Hg emissions reductions, DOE has previously determined that the impact of mercury 

emissions from power plants on humans is considered highly uncertain. However, DOE 

identified two estimates of the environmental damage of mercury based on two estimates of the 

adverse impact of childhood exposure to methyl mercury on intelligence quotient (IQ) for 

American children, and subsequent loss of lifetime economic productivity resulting from these 

IQ losses. The high-end estimate is based on an estimate of the current aggregate cost of the loss 

of IQ in American children that results from exposure to mercury of U.S. power plant origin 

($1.3 billion per year in year 2000$), which works out to $33.3 million per ton emitted per year 

(2008$). Refer to L. Trasande et al., “Applying Cost Analyses to Drive Policy that Protects 

Children,” 1076 Ann. N.Y. Acad. Sci. 911 (2006) for additional information. The low-end 

estimate is $0.66 million per ton emitted (in 2004$) or $0.745 million per ton in 2008$. DOE 

derived this estimate from a published evaluation of mercury control using different methods and 

assumptions from the first study but also based on the present value of the lifetime earnings of 

children exposed to mercury. See Ted Gayer and Robert Hahn, “Designing Environmental 

Policy: Lessons from the Regulation of Mercury Emissions,” Regulatory Analysis 05–01, 

American Enterprise Institute-Brookings Joint Center for Regulatory Studies, Washington, DC 

(2004). A version of this paper was published in the Journal of Regulatory Economics in 2006. 

The estimate was derived by back-calculating the annual benefits per ton from the net present 

value of benefits reported in the study. 

In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE will 

conduct two calculations of the monetary benefits derived using each of the economic values 

used for NOX and Hg, one using a real discount rate of 3 percent and another using a real 

discount rate of 7 percent.bb 

For more detail on the environmental assessment, refer to the environmental assessment 

report in the preliminary TSD. 

2.17 REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE expects to prepare a regulatory impact 

analysis (RIA) pursuant to Executive Order 12866, “Regulatory Planning and Review,” 58 FR 

51735 (October 4, 1993), which is subject to review under the Executive Order by the Office of 

Information and Regulatory Affairs at the Office of Management and Budget. The RIA addresses 

the potential for non-regulatory approaches to supplant or augment energy conservation 

bb OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

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standards to improve the energy efficiency or reduce the energy consumption of ballasts covered 

under this rulemaking. 

Voluntary and other non-regulatory efforts by manufacturers, utilities, and other 

interested parties can result in substantial improvements to energy efficiency or reductions in 

energy consumption. DOE intends to consider the likely effects of non-regulatory initiatives on 

ballast energy use, consumer utility, and LCCs. DOE will base its assessment on the actual 

impacts of any such initiatives to date, but also will consider information about the impacts that 

any existing initiative might have in the future. 

In the framework document, DOE identified two sources of market failures: lack of 

consumer information and/or information processing capabilities about energy efficiency 

opportunities in the lighting market, and asymmetric information and/or high transaction costs. 

The Joint Comment stated that DOE has accurately characterized some of the market failures in 

the framework document. However, the Joint Comment noted that other market failures 

characterized in a recent paper by ACEEE and ASAP might apply. The Joint Comment also 

emphasized that a market failure occurs when firms tend to consider capital costs and operating 

costs independently. For example, decision makers face more pressure to reduce capital costs 

than operating costs due to financial procedures or the time horizon of the current management. 

(Joint Comment, No. 12 at pp. 8-9) 

DOE agrees with many of the market failures identified in the recent paper by ACEEE, 

which the Joint Comment suggested DOE study.cc In the framework document, DOE addressed 

many of the demand-side barriers characterized in the paper. These barriers include lack of 

awareness and uninformed decision makers (both symptoms of lack of consumer information 

and/or information processing capabilities), and third-party decision makers (a type of high 

transaction cost). However, DOE did not address all barriers identified in the paper. These 

include financial procedures (or the time horizon of management) that over-emphasize initial 

costs and de-emphasize operating costs (as discussed in the Joint Comment), small per unit 

savings, limited stocking of efficient products, efficiency bundled into premium products only, 

and manufacturer price competition. DOE agrees that all of these are potential market failures for 

fluorescent lamp ballasts that warrant agency action. As ASAP noted, it is important to examine 

market data rather than rely on theoretical assumptions about the marketplace. (ASAP, Public 

Meeting Transcript, No. 9 at p. 93) DOE agrees and therefore is continuing to seek data that 

would enable it to conduct tests of these market failures. DOE requests comments and data on 

potential market failures for fluorescent lamp ballasts. For more information, refer to the 

regulatory impact analysis report in the preliminary TSD. 

cc S. Nadel, A. DeLaski, M. Eldridge, and J. Kliesch, “Leading the Way: Continued Opportunities for New State 

Appliance and Equipment Efficiency Standards,” 2006. <http://www.standardsasap.org/documents/a062.pdf>. 

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