Fluorescent Lamp Ballast Framework Document Public Meeting February 6, 2008

1

U.S. Department of Energy

Energy Conservation Program for Consumer Products

and Commercial and Industrial Equipment

Framework Document Public Meeting on

Energy Conservation Standards for 

Fluorescent Lamp Ballasts

February 6, 2008

Washington, DC

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

2

Welcome and Introduction

• Introductions

• Role of the Facilitator

• Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; 

state your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

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Morning Agenda

Welcome

Introductions and Agenda Review

Opening Remarks

Regulatory History and Scope of Coverage

Test Procedure and Energy Conservation Standard 

Overview

Break

Market and Technology Assessment and Screening 

Analysis

Engineering Analysis and Product Price Determination

9:00 – 9:05 am

9:05 – 9:20 am

9:20 – 9:40 am

9:40 – 10:00 am

10:00 – 10:30 am

10:30 – 10:45 am

10:45 – 11:30 am

11:30 – 12:00 pm

4

Afternoon Agenda

Break for lunch

Preliminary Manufacturer Impact Analysis

Energy Use and End-Use Load Characterization; and 

Life-Cycle Cost and Payback Period Analysis

Shipments Analysis, National Impact Analysis, and 

Life-Cycle Cost Subgroup Analysis

Break

Manufacturer Impact Analysis

Utility Impact Analysis, Employment Impact Analysis, 

Environmental Assessment, and Regulatory Impact 

Analysis

Other issues and comments; closing remarks

12:00 – 1:00 pm

1:00 – 1:15 pm

1:15 – 2:00 pm

2:00 – 2:30 pm

2:30 – 2:45 pm

2:45 – 3:15 pm

3:15 – 3:45 pm

3:45 – 4:30 pm

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Stakeholder Opening Statements

Stakeholders who contacted DOE and requested an 

opportunity to make an opening statement should speak now.

6

Public Meeting Agenda

2

3

NOPR Analyses

1

ANOPR Analyses

4

Test Procedures

Introduction

3

ANOPR Analyses

Energy Conservation Standards

4

Introduction

5 NOPR Analyses Final Rule

6 Closing Remarks

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Introduction

Purpose of the Framework Document Public Meeting

• Present the procedural and analytical approaches to 

evaluate energy conservation standards for fluorescent 

lamp ballasts.

• Provide a forum for public discussion of rulemaking issues.

• Encourage stakeholders to submit data, information, and 

written comments.

• Inform stakeholders and facilitate the rulemaking process.

8

Requests for Comment

Issue Box In the Rulemaking Framework Document for 

Fluorescent Lamp Ballasts, DOE welcomes comment. Throughout 

this presentation specific issues will be brought up for discussion 

on slides such as this, with identifying numbers corresponding 

to those in the Framework Document. Nonetheless, comments 

concerning any part of the document or presentation are welcome.

Introduction

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In all correspondence, please refer to the Fluorescent Lamp Ballast 

rulemaking by:

– Fluorescent Lamp Ballasts Rulemaking,

– Docket Number EERE–2007–BT–STD–0016, and

– Regulatory Identification Number (RIN) 1904-AB50

Email: Ballasts.Rulemaking@ee.doe.gov

Comment period closes: March 7, 2008

Feedback Is Requested 

Especially on Items Identified in Framework Document

Introduction

Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Postal: Courier:

10

Regulatory History

Regulatory History

• Energy Policy and Conservation Act (EPCA) of 1975, 

Pub. L. 94-163

– Established the energy conservation program.

• National Appliance Energy Conservation Amendments 

(NAECA) of 1988, Pub. L.100-357

– Prescribed test procedure, codified in 1989, 54 FR 6076 

– Prescribed standards, codified in 1989, 54 FR 6077 

– Directed DOE to review and amend standards –

“first cycle” (complete, Sept. 19, 2000)

– Directed DOE to review and amend standards –

“second cycle” (being initiated now)

• Fluorescent Lamp Ballasts Energy Conservation 

Standard published Sept. 19, 2000, 65 FR 56740 

– Standard adopted was a consensus agreement 

between industry and efficiency advocates.

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Regulatory History (continued)

• Energy Policy Act (EPACT) of 2005, Pub. L. 109-58

– Added definitions for T12 energy saver lamps

– Set standards for ballasts operating T12 energy saver 

lamps, codified October 18, 2005, 70 FR 60407.

• Energy Independence and Security Act (EISA) of 2007, 

Pub. L. 110-140

– Directs DOE to amend the fluorescent lamp ballast test 

procedure to incorporate standby and off mode.

– Directs DOE to incorporate standby and off mode in 

standards rulemaking of ballasts (i.e., final rule after July 

1, 2010).

– Defines ‘ballast’ and ‘electronic ballast’ (see next slide).

– Removes the requirement to conduct an ANOPR for 

certain products including fluorescent lamp ballasts.

Regulatory History

12

Fluorescent Lamp Ballast Definitions

• NAECA of 1988 defined fluorescent lamp ballasts:

– “fluorescent lamp ballast means a device which is used to start and 

operate fluorescent lamps by providing a starting voltage and current and 

limiting the current during normal operation.” (42 U.S.C. 6291 (29)(A))

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

– “Ballast. The term ‘ballast' means a device used with an electric discharge 

lamp to obtain necessary circuit conditions (voltage, current, and waveform) 

for starting and operating.” (42 U.S.C. 6291(58))

– “Electronic Ballast. The term ‘electronic ballast' means a device that uses 

semiconductors as the primary means to control lamp starting and

operation.” (42 U.S.C. 6291(60))

Scope of Coverage

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120/277V

Fluorescent Lamp Ballasts that Operate

One and Two 4-foot

Medium Bipin

60W

T12 

75W 

T12

95W

T12

40W

T12

34W

T12

110W

T12

• Exclusions:

– Dimming to 50 percent or less of maximum output

– Ballasts designed for use with two F96T12HO lamps at ambient temperatures of -20°F or 

less and for use in an outdoor sign; or ballasts designed for use with two F96T12HO/ES 

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

– Power factor of less than 0.90 and designed/labeled for residential building applications

– Replacement ballasts as defined in 10 CFR (m)(4)(ii) until June 30, 2010

Fluorescent Lamp Ballast Standards

Two 8-foot

Recessed 

Double Contact

High Output

Two 8-foot

Single Pin 

Slimline

Scope of Coverage

14

Additional Fluorescent Lamp Ballasts

• In this rulemaking, DOE will also be considering whether to 

extend coverage to apply standards to additional fluorescent lamp 

ballasts.

– The statute directs DOE: “After January 1, 1992, the Secretary shall 

publish a final rule no later than five years after the date of 

publication of a previous final rule. The Secretary shall determine in 

such rule whether to amend the standards in effect for fluorescent 

lamp ballasts, including whether such standards should be amended 

so that they would be applicable to additional fluorescent lamp 

ballasts.” (42 U.S.C. 6295(g)(7)(B))

Scope of Coverage

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Additional Fluorescent Lamp Ballasts (cont.)

• DOE is considering extending coverage to ballasts that operate all 

fluorescent lamps covered under EPCA, which are: 

• 4-foot, medium bi-pin, rated ≥ 28 watts

• 2-foot, medium bi-pin, U-shaped lamps, rated ≥ 28 watts

• 8-foot, recessed double-contact, rapid start, high output lamps, 0.800 

nominal amperes, as defined in ANSI C78.1–1991

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

ANSI C78.3–1991

• Note: DOE is also considering additional fluorescent lamps for coverage 

in the fluorescent lamp rulemaking (i.e., in addition to those listed above).

– DOE will consider coverage of ballasts that operate those additional 

fluorescent lamps as well.

Scope of Coverage

16

Fluorescent Lamps

which have Standards

4-foot 

Medium Bipin

≥ 28W

2-foot U-shaped 

Medium Bipin

≥ 28 W

60W

T12 

75W 

T12

95W

0.8-Amp

T12

110W

0.8-Amp

T12

DOE has standards for ballasts that 

operate these lamps.

In this rulemaking, DOE is 

considering establishing standards 

for ballasts that operate these 

lamps.

44W

T8

40W

T12

40W

T10

34W

T12

32W

T8

Other

lamps

e.g. T8 

30W, 28W

40W

6”

Center

T12 

40W

3-5/8”

Center

T12 

31W

1-5/8”

Center

T8

32W

6”

Center

T8

Other 

lamps

e.g. T12

34W 

Standards Map for Fluorescent Lamps and Ballasts

8-foot Recessed 

Double Contact

High Output

8-foot Single Pin

Slimline

≥ 52 W

Scope of Coverage

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Request for Comment

Item 1 DOE welcomes comment on the scope of this rulemaking, which 

implements the statutory requirement to consider additional fluorescent lamp 

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

Scope of Coverage

18

Introduction

Fluorescent Lamp Ballast Rulemakings

2006 ScheduleSetting Process

Fluorescent Lamp Ballast 

Test Procedure Rulemaking on

Standby Mode and Off Mode (EISA 2007)

Framework

Document

01/2008

ANOPR1

11/2009

Energy Conservation 

Standards for 

Fluorescent Lamp 

Ballasts

NOPR1

10/2010

Final

Rule

06/2011

1 ANOPR: Advance Notice of Proposed Rulemaking NOPR: Notice of Proposed Rulemaking

NOPR

7/2008

Final Rule

10/2010

NOPR

11/2009

Final 

Rule 

3/2009

Potential Additional Fluorescent 

Lamp Ballast Test Procedure

to Update and Amend

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2

3

NOPR Analyses

1

ANOPR Analyses

4

Test Procedures

Introduction

3

ANOPR Analyses

Energy Conservation Standards

4

Introduction

5 NOPR Analyses Final Rule

6 Closing Remarks

Public Meeting Agenda

20

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

Test Procedures

• EISA 2007 directs DOE to amend its fluorescent lamp ballast test

procedure to incorporate a measure of standby mode and off mode 

energy use by March 31, 2009.

• Off Mode 

– EISA 2007 defines “off mode” as the condition when a product is 

connected to the main power source and is not providing any 

standby or active mode function.

– DOE believes that when a fluorescent lamp ballast is not providing 

any standby or active mode function, the fluorescent lamp ballast is 

disconnected from the main power source. If the ballast is 

disconnected from the power source, it does not meet the definition 

of “off mode.”

– Therefore, DOE believes fluorescent lamp ballasts do not operate in 

“off mode” as defined by EISA 2007.

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

Test Procedures

• Standby Mode

– DOE may need to amend its test procedure to include standby mode

energy use.

– EISA 2007 defines standby mode as the condition in which a product is 

connected to a main power source and either:

• Facilitates the activation or deactivation of other functions (including 

active mode) by remote switch, internal sensor or timer; or

• Offers continuous functions including information or status-displays, 

or sensor-based function.

– DOE understands that new ballasts are now being designed with circuitry 

that adds new features, including intelligent operation. 

• These ballasts may use standby mode power (e.g., ballasts that 

employ a lighting controls system such as Digital Addressable 

Lighting Interface (DALI)). 

22

Request for Comment

Test Procedures

Item 2 DOE welcomes comment on the standby power provisions from 

EISA 2007 and issues arising therefrom, including: (a) How DOE should 

modify its test procedure for fluorescent lamp ballasts; (b) Which covered 

fluorescent lamp ballasts are subject to standby mode and off mode 

energy use?; and (c) How DOE should take standby mode and off mode 

energy consumption into its analysis for the energy conservation

standard?

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Potential Additional Test Procedure

Test Procedures

• NAECA of 1988 prescribed test procedures for fluorescent lamp ballasts, 

but only magnetic ballasts, not electronic.

• DOE is considering updating the magnetic ballast test procedure citations 

and adding test procedures for electronic ballasts.

• Reference documents DOE is considering:

– ANSI C82.2-2002, “For Lamp Ballasts- Method of Measurement of 

Fluorescent Lamp Ballasts,”

– ANSI C82.1-2004, “For Lamp Ballast- Line Frequency Fluorescent Lamp 

Ballast,” and 

– ANSI C82.11-2002, “For Lamp Ballasts- High Frequency Fluorescent Lamp 

Ballasts.”

• DOE notes that ANSI employs a different method to determine the ballast 

factor for rapid-start and instant-start ballasts.

• DOE notes that there are no ANSI test procedures for those ballasts that 

operate lamps that are not part of ANSI C78.81

24

Request for Comment

Test Procedures

Item 3 DOE welcomes comment on the issue of updating the fluorescent 

lamp ballast test procedure. DOE also invites comment on whether it should 

update the test procedure to include the industry standards ANSI C82.2-

2002, C82.1-2004, C82.11-2002 or any additional procedures that should be 

considered in its test procedure rulemaking for fluorescent lamp ballasts.

Item 4 DOE welcomes comment on the two different ANSI methods used to 

calculate ballast factor for rapid-start and instant-start ballasts. If the two 

methods are not comparable, DOE invites comment on any conversion 

factors necessary to make them comparable. Finally, DOE invites comment 

on whether manufacturers report the ballast factor for instant-start ballasts in 

their literature using the ANSI or DOE test procedure.

Item 5 DOE also welcomes comment on ballast factor calculation methods 

used for programmed-start ballasts, modified rapid-start ballasts and other 

types of fluorescent lamp ballasts not covered by ANSI C82.2-2002.

DOE welcomes comment on how to test fluorescent lamp ballasts when 

operating lamps that are not part of ANSI C78.81.

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2

3

NOPR Analyses

1

Energy Conservation Standards

4

Rulemaking Overview

Introduction

2

ANOPR Analyses

Test Procedure

4

Introduction

5 NOPR Analyses Final Rule

6 Closing Remarks

Public Meeting Agenda

26

Energy Conservation Standards

EPCA Factors

Environmental Assessment

Utility Impact Analysis

Employment Impact Analysis

7. Other factors the Secretary considers 

relevant

6. Need for national energy conservation National Impact Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

Engineering Analysis

Screening Analysis

4. Impact on utility or performance

3. Total projected energy savings National Impact Analysis 

2. Lifetime operating cost savings compared Life-Cycle Cost Analysis

to increased cost for the product

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

1. Economic impact on consumers and 

manufacturers

EPCA Factors DOE Analysis

• 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(a) direct DOE to 

consider seven factors when setting energy conservation standards 

for fluorescent lamp ballasts:

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Stages for the Energy Conservation Standard 

Rulemaking for Fluorescent Lamp Ballasts

Report to Congress

Framework Document

Framework 

Document 

Public Meeting

Points of Stakeholder Participation

Milestones for DOE

ANOPR

Public 

Meeting

NOPR

Public 

Meeting

2008 2009 2010 2011 2012 2013

Energy Conservation Standards

2007 2014

ANOPR Published*

NOPR Published

Final Rule Published

Standards Applicable

2006

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

28

Framework Document

Framework

Document ANOPR NOPR Final

Rule

Today

• Today’s public meeting covers the Framework Document for this product

• Federal Register Notice of Public Meeting, 73 FR 3653, Jan 22, 2008.

– Gives notice of the public meeting and availability of the Framework 

Document being discussed today

• Framework Document

– Provides an overview of the rulemaking process and encourages early 

stakeholder participation

– Encourages interested parties to submit comments by March 7,2008

– The Framework Document and materials from today’s public meeting are 

available online:

http://www.eere.energy.gov/buildings/appliance_standards/residential/ballast

_framework_mtg.html

Energy Conservation Standards

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Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use and 

End-Use Load 

Characterization

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination 

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

30

Analyses for the ANOPR 

Energy Conservation Standards

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Shipments

Analysis

• Product Classes

• Technology Options

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maint. & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Advance Notice of Proposed Rulemaking (ANOPR)

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy 

Use Data

Technology Options

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

• Analysis of Market Data

• Analysis of Product Data

• Installation

Costs

• Maint. Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• Product Prototypes

Energy-Efficiency 

Levels Product Designs

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Purpose of the ANOPR Public Meeting

• To present methodologies for the ANOPR analyses, and 

characterize results

• To discuss specific issues related to the ANOPR analysis

• To seek input from attendees on methodologies, assumptions, data

sources

• To describe upcoming analyses and next steps, and seek further 

input

Energy Conservation Standards

32

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Environmental 

Assessment

Regulatory

Impact 

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

Revise 

ANOPR 

Analyses

Engineering

Analysis

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Analyses for the NOPR and Final Rule

Energy Conservation Standards

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Revise ANOPR

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact 

Analysis

Employment Impact

Analysis 

Revise Analyses

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• National Employment Impacts

• Revised Results

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Advance Notice of Proposed Rulemaking (ANOPR)

Environmental

Assessment

Regulatory Impact

Analysis

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

Direct Employment 

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Department of Justice Review

• Efficiency-Level Approach

• Design Option Approach

34

Purpose of the NOPR Public Meeting

• To hear the views of stakeholders on DOE’s proposed standard 

levels

• To obtain input on any remaining issues relating to the Notice of 

Proposed Rulemaking 

DOE will consider all verbal and written 

comments in preparing its Final Rule.

Energy Conservation Standards

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Framework

Document ANOPR NOPR Final

Rule

Analyses for Final Rule

Final 

Energy Conservation Standards

Revise NOPR 

Analyses

36

2

3

ANOPR Analyses

1

ANOPR Analyses

4

Rulemaking Overview

Introduction

2

Energy Conservation Standards

Test Procedure

3

Introduction

5 NOPR Analyses Final Rule

6 Closing Remarks

Public Meeting Agenda

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Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use and 

End-Use Load 

Characterization

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

38

Purpose

• Characterize the markets, the fluorescent lamp ballast industry,

and the measures to improve efficiency

Method

• Identify and characterize manufacturers of fluorescent lamp 

ballasts;

• Estimate shipments and trends in the market;

• Identify regulatory and non-regulatory initiatives intended to 

improve the efficiency of the products covered under this 

rulemaking; 

• Study market failures or other specific problems that may warrant 

agency action; and 

• Identify technologies that could improve efficiency.

Market and Technology Assessment

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Relationship of Market and Technology Assessment 

to other Analyses

Market and 

Technology 

Assessment

Product Classes

Technology Options to improve efficiency

Screening Analysis

Design Options to improve efficiency

Engineering Analysis

Market and Technology Assessment

40

Request for Comment

Item 6 DOE welcomes input on shipments, manufacturing costs, 

product-feature and efficiency trends, distribution channels, and 

estimates of market shares for the fluorescent lamp ballasts 

covered in this rulemaking. For DOE to be able to use the data to 

conduct energy savings calculations, a degree of disaggregation 

(e.g. by product class) is desirable. 

Item 7 DOE is seeking stakeholder comment and data on potential 

market failures that could apply to fluorescent lamp ballasts.

Market and Technology Assessment

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• DOE establishes separate energy conservation standards for 

each product class.

• DOE divides covered product into classes by:

– The type of energy used

– Capacity of the product or other performance-related features 

that justify different standard levels, such as features affecting 

consumer utility (42 U.S.C. 6295(q))

Market and Technology Assessment

Product Classes

42

Market and Technology Assessment

Fluorescent Lamp Ballast Product Classes 

and Standards

220

220

150

150

80

80

40

40

Total Nominal 

Lamp Watts

277 0.39

277 0.63

277 1.17

277 2.29

Ballast 

Efficacy 

Factor

Ballast Input 

Voltage Ballast for the Operation of

0.39

0.63

1.17

2.29

120

120

120

120

Two F96 T12HO lamps

Two F96 T12 lamps

Two F40T12 lamps

One F40T12 lamp

10 CFR 430.32 (m)(3)(ii)(C)

• Standards became effective to ballast manufacturers on July 1, 2005.

• Product classes used by NAECA 1988 and DOE Final Rule, 2000.

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Market and Technology Assessment

Fluorescent Lamp Ballast Product Classes and 

Standards (continued)

190

190

120

120

68

68

34

34

Total Nominal 

Lamp Watts

277 0.42

277 0.77

277 1.35

277 2.61

Ballast 

Efficacy 

Factor

Ballast Input 

Voltage Ballast for the Operation of

0.42

0.77

1.35

2.61

120

120

120

120

Two F96 T12HO/ES lamps

Two F96 T12/ES lamps

Two F34T12 lamps

One F34T12 lamp

10 CFR 430.32 (m)(5)(ii)(C)

• Standards will become effective to ballast manufacturers on October 1, 2009.

• Product Classes used by EPACT 2005.

44

Considerations for Fluorescent Lamp Ballast 

Product Classes

• DOE is considering amending product classes for fluorescent 

lamp ballasts. 

• DOE is considering subdividing product classes by:

– Lamp Length (e.g., 4-foot vs. 8-foot)

– Base Type (e.g., High Output vs. Normal Output)

– Number of Lamps Operated (e.g., 1 lamp vs. 2 lamps)

• DOE may also subdivide product classes by:

– Lamp Diameter (e.g., T8 vs. T12)

– Lamp Wattage (e.g., 34W vs. 40W)

– Starting Method (e.g., rapid start vs. instant start)

– Total Harmonic Distortion (e.g., <10% vs. <20%)

– Able to operate at multiple input voltages (e.g., universal)

– Able to operate multiple # of lamps (e.g., 2 or 3 lamps)

Market and Technology Assessment

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45

Sample of Today’s Market: Electronic Ballasts for 

Two 4-foot Medium Bipin Lamps

Market and Technology Assessment

1

1.2

1.4

1.6

1.8

2

2.2

26 28 30 32 34 36 38 40 42

Lamp Wattage of One Lamp (Watts)

Ballast Efficacy Factor (BEF)

Average BEF of Sample

EPCA Standards

T8 T12

46

Difference in Ballast Efficacy Factor By 

Lamp Wattage

Market and Technology Assessment

• DOE could recognize the variance in Ballast Efficacy Factor by 

lamp wattage by either:

(1) Setting a different product class at each wattage (e.g., 

40W, 34W, 32W, 28W); or

(2) Have a single product class for a given lamp length, base 

type, and number of lamps, and set the BEF requirement 

based on an equation that varies with wattage.

EERE-2007-BT-STD-0016 COMMENT 07
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47

Possible Product Classes for Discussion

Ballast Efficacy Factor

ƒ(WL

)

ƒ(WL

)

ƒ(WL

)

1 lamp

ƒ(WL

)

ƒ(WL

)

ƒ(WL

)

2 lamps

ƒ(WL)

3 lamps

8-foot recessed double contact high output 

fluorescent lamp

8-foot single pin slimline fluorescent lamp

ƒ(WL

)

4-foot straight-shaped or 2-foot U-shaped 

medium bipin fluorescent lamp

4 lamps

Fluorescent Lamp Ballast 

for the Operation of

Market and Technology Assessment

• Ballast Efficacy Factor requirements would be an equation that varies 

with lamp wattage.

• Standards would be applicable to all ballast input voltages.

Item 8 DOE welcomes comment on product classes for fluorescent 

lamp ballasts and approaches to defining classes in accordance with 

the requirements of 42 U.S.C. 6295(q).

48

Initial Technology Options for Fluorescent Lamp Ballasts

• Cathode Cutout or Hybrid Ballast

– Removes electrode power (thereby reducing system energy use) after the 

discharge has been initiated for rapid-start lamps.

• Electronic Ballast

– Allows for high-frequency operation which decreases losses near the lamps 

electrode and reduces other ballast losses by allowing for smaller components.

• Integrated Circuits

– Integrated circuits reduce conductive energy losses. 

• Higher Grade Components

– Higher-grade magnetic materials and improved semiconductor materials reduce 

conductive energy losses.

• Improved Circuit Design

– Better circuit design can increase a ballast’s efficiency and reduce conductive 

losses.

Market and Technology Assessment

EERE-2007-BT-STD-0016 COMMENT 07
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49

Request for Comment

Item 9 DOE welcomes comment on the preliminary technology 

options identified in this section. DOE welcomes comment on 

whether there are other technology options that it should also 

consider. In commenting on design options, please discuss their 

impacts on safety, performance, and consumer utility (if any).

Market and Technology Assessment

50

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

EERE-2007-BT-STD-0016 COMMENT 07
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26

51

Screening Analysis

Impacts on health or safety

Impacts on product utility or availability to consumers

Practicability to manufacture, install and service

Technological feasibility

Purpose

• Screen out technology options that DOE will not consider in the 

engineering analysis for fluorescent lamp ballasts.

Approach

• DOE will evaluate each technology option based on the following 

criteria:

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

52

Request for Comment

Item 10 DOE welcomes comment on how the four screening 

criteria might apply to any additional technology design option(s) 

that a stakeholder recommends to DOE.

Screening Analysis

EERE-2007-BT-STD-0016 COMMENT 07
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27

53

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

54

Downstream Rulemaking 

Analyses

• Life-Cycle Cost and 

Payback Period Analysis

• Manufacturer Impact 

Analysis 

• National Impact Analysis

Purpose

• The purpose of the engineering analysis and the product price 

determination is to determine the relationship between fluorescent 

lamp ballast efficiency and end-user price. 

Engineering Analysis

Engineering 

Analysis

Product Price 

Determination

EERE-2007-BT-STD-0016 COMMENT 07
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55

 Choose product classes to be analyzed in the engineering and 

life-cycle cost analysis. 

 Define characteristics of models in each representative 

product class which will serve as reference points to assess 

changes due to energy conservation standards. 

 Identify more-efficient substitutes from a database of 

commercially-available ballasts. Maintain light output and have 

the same or better performance than the baseline system. 

 Develop candidate standard levels that span the range of 

BEFs from the baseline to the maximum technologically 

feasible. 

 Scale analyses conducted on baseline ballasts to other 

ballasts and other product classes.

Develop

Candidate 

Standard 

Levels

Engineering Analysis Methodology

Engineering Analysis

Scale 

Results

Identify

Efficient 

Substitutes

Choose 

Representative 

Product 

Classes

Choose 

Representative 

Product 

Define 

Baseline 

Models

56

Engineering Analysis

Choose Representative Product Classes

• There are many potential product classes for which standards must 

be set.

• DOE will choose a subset of product classes to analyze in the 

engineering analysis and life-cycle cost analysis.

• These are called “representative product classes.”

• Representative product classes are generally based on high volume 

product.

EERE-2007-BT-STD-0016 COMMENT 07
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57

Engineering Analysis

Define Baseline Models

• Baseline models will be selected from each representative product 

class.

• Typically the baseline model just meets the current energy 

conservation standard.

• For any baseline ballast where DOE is considering expanding 

coverage, DOE will select baseline models typical of the least-efficient 

ballast sold. 

58

Engineering Analysis

Example Showing Potential for Scaling from 

Baseline Ballasts

28W

1-lamp 2-lamp 3-lamp 4-lamp

40W

34W

32W

30W

• Once baseline models and product classes are chosen and analyzed, 

DOE will scale the results to other fluorescent lamp ballasts.

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

EERE-2007-BT-STD-0016 COMMENT 07
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59

Engineering Analysis

Item 11 DOE welcomes comment on representative product 

classes and selection of baseline models from those 

representative product classes.

Item 14 DOE welcomes comment on how BEF varies with 

lamp wattage.

Item 12 DOE welcomes comment on the scaling of findings 

from representative product classes to other product classes 

that DOE may not analyze.

Request for Comment

60

Engineering Analysis

Identify More Efficient Substitutes

• In identifying more-efficient substitutes, DOE will utilize a database 

of commercially-available ballasts.

• Ballast system substitutions will be made so that either: 

(1) Light output is maintained from the baseline system’s light output.

(2) Light output and fixture watts are normalized to the baseline 

system.

• Ballast system substitutions will be selected to have the same or 

better performance characteristics (e.g., THD).

EERE-2007-BT-STD-0016 COMMENT 07
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61

Engineering Analysis

Develop Candidate Standard Levels

• DOE is required to analyze maximum technologically feasible 

(“max tech”) efficiency levels

– In some cases, DOE defines the highest efficiency level based on

maximum available efficiency currently on the market.

– “Max available” may not correspond to “max tech” if some design 

options are not yet commercially available.

– DOE will seek stakeholder comment to resolve this discrepancy.

62

Example of Draft Engineering Analysis for Discussion

Engineering Analysis

64

64

64

68

Total

Lamp

W

49

53

54

63

Fixture 

Watts

CSL3 IS T8 1.600 0.88 3,956 0%

CSL2 IS T8 1.492 0.88 3,956 0%

CSL1 RS/PS T8 1.443 0.88 3,956 0%

Baseline RS/PS T12 1.365 0.86 3,956 0%

% 

Diff

Mean 

Lumen

System 

Mean 

Lumen 

BEF BF Output

Lamp 

Diam.

Start 

Method

Candidate 

Standard Level

64

64

64

Total 

Lamp 

W

CSL3 IS T8 1.600 0.88 55 5,016 0%

CSL2 IS T8 1.492 0.88 59 5,016 0%

Baseline/CSL1 RS/PS T8 1.443 0.88 61 5,016 0%

% 

Diff

Mean 

Lumen

System 

Mean 

Lumen 

Output

Fixture 

BEF BF Watts

Lamp 

Diam.

Start 

Method

Candidate 

Standard Level

34W T12 Baseline

32W T8 Baseline

EERE-2007-BT-STD-0016 COMMENT 07
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63

Item 13 DOE welcomes comment on commercially-available 

fluorescent lamp ballasts for each of the baseline models with 

incrementally increasing BEF, all the way to the max tech 

ballast.

DOE welcomes comment on the proposed approach to the 

engineering analysis.

Engineering Analysis

Request for Comment

64

Engineering Analysis

Proprietary Designs

• DOE will evaluate all design options that are commercially 

available or present in a working prototype, including proprietary 

designs and technologies.

• Proprietary designs will only be considered if they do not present 

a unique path to a given efficiency level.

• The confidentiality of manufacturers will be maintained.

Item 15 Are there proprietary designs of which DOE should 

be aware for any of the fluorescent lamp ballasts under 

consideration in this rulemaking? If so, how DOE should 

acquire the cost data necessary for evaluating these designs? 

EERE-2007-BT-STD-0016 COMMENT 07
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33

65

Engineering Analysis

Outside Regulatory Changes

• DOE takes into consideration the effects on manufacturers of 

other regulatory changes outside of the standards rulemaking 

process.

Item 16 DOE welcomes comment on regulatory burdens or 

changes that should be considered in the engineering 

analysis of fluorescent lamp ballasts.

Item 17 DOE welcomes comment on any other engineering 

issues that could impact the engineering analysis.

66

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

EERE-2007-BT-STD-0016 COMMENT 07
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34

67

Product Price Determination

Purpose

• Provide an analysis of the relationship between the end-user 

price and efficiency for fluorescent lamp ballasts.

Method

• Product price determination for ballasts will be based on available 

pricing lists (e.g., manufacturer price lists, state procurement

price lists)

• DOE could develop high-range, medium-range, and low-range 

end-user retail prices. 

– Low-range prices could be developed to be consistent with prices 

found in State procurement contracts and other sources which have 

a single high-volume discount for all products. 

– Medium-range prices could be developed to be consistent with the 

typical discount provided by distributors for commercial institutions 

on high-volume ballasts, incorporating a contractor mark-up.

– High-range prices could be developed for small quantity purchasers 

by observing Internet prices and obtaining distributor quotes. These 

prices could also incorporate a contractor mark-up. 

68

Product Price Determination

Item 19 DOE welcomes comment on final end-user prices for 

high-range, medium-range, and low-range fluorescent ballasts.

Item 20 DOE welcomes comment on typical contractor and 

distributor markups associated with the purchase and 

installation of fluorescent lamp ballasts.

Request for Comment

EERE-2007-BT-STD-0016 COMMENT 07
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35

69

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

70

Preliminary Manufacturer Impact Analysis

Legislative Requirements

• The Manufacturer Impact Analysis (MIA) fulfills a legislative 

requirement to determine if a proposed standard is economically 

justified.

– EPCA provides 7 factors to evaluate in determining whether an 

efficiency standard is justified. Two factors are addressed in the MIA:

• Economic impact of standards on manufacturers

• Impacts of any lessening of competition in the industry

– MIA format changes described in the 2006 report to Congress, at:

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html

• DOE will collect, evaluate, and report preliminary MIA data in the 

ANOPR, if manufacturers can supply the requisite information.

• Preliminary data include: anticipated conversion capital 

expenditures by efficiency level and anticipated direct employment 

impacts.

EERE-2007-BT-STD-0016 COMMENT 07
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36

71

Methodology

• The MIA consists of three main phases. In the ANOPR, the 

preliminary MIA focuses on Phase 1 

Industry 

profile

Develop 

straw-man 

GRIM*

Develop 

interview 

guide

Interviews

& industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 3

Preliminary 

MIA 

Interviews

Phase 1

ANOPR

NOPR

Preliminary Manufacturer Impact Analysis

72

Purpose

• Provide initial discussion on any potential impacts of energy 

conservation standards on manufacturers of fluorescent 

lamp ballasts.

• Provide an opportunity to verify DOE market information 

and engineering design options.

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0016 COMMENT 07
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37

73

Methodology: Phase 1

• Consists of the industry profile and preliminary manufacturer 

impact analysis interviews

Industry Profile

» Evaluate current and past industry 

structure and market 

characteristics

» Produce an industry profile report 

with aggregated findings and 

characteristics

» Identify critical issues that require 

special consideration in the MIA, 

for example:

» Types or groups of manufacturers

» Access to technology

» Potential regulatory scenarios

» Evaluate current and past industry 

structure and market 

characteristics

» Produce an industry profile report 

with aggregated findings and 

characteristics

» Identify critical issues that require 

special consideration in the MIA, 

for example:

» Types or groups of manufacturers

» Access to technology

» Potential regulatory scenarios

Preliminary MIA Interviews

» Occurs during the engineering 

analysis

» Topics include:

» Shipment projections

» Conversion costs

» Product mix and profitability

» Market shares and industry 

consolidation

» Cumulative regulatory burden

» Occurs during the engineering 

analysis

» Topics include:

» Shipment projections

» Conversion costs

» Product mix and profitability

» Market shares and industry 

consolidation

» Cumulative regulatory burden

Preliminary Manufacturer Impact Analysis

74

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

EERE-2007-BT-STD-0016 COMMENT 07
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75

Purpose

• Develop annual energy use data for the life-cycle cost and payback 

period analyses to calculate annual operating costs.

Method

• Obtain data to develop a distribution of operating hours for fluorescent 

lamps by sector and census division. Data sources include: 

– 2002 U.S. Lighting Market Characterization: Volume I report

– EIA’s 2003 Commercial Building Energy Survey

– EIA’s 2002 Manufacturer Energy Consumption Survey

• Correlate electricity price distribution and sales tax distribution with the 

operating hour distribution by census division.

• Multiply system power by the number of operating hours per year.

• Conduct sensitivity analysis for estimates of high and low operating 

hours.

Energy Use and End-Use Load Characterization

76

Inputs to Energy Use Calculation

• System Input Power: Manufacturer information verified by catalogs.

• Operating Hours: Example of commercial sector distribution for 

fluorescent lamp ballasts is given below.

Fluorescent Lamp Ballast Annual Operating Hours

Probability

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

20%

1,7052,5702,6433,3313,3943,4603,5453,5703,6383,6813,6863,7803,8194,3854,5984,9735,2245,751

Energy Use and End-Use Load Characterization

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39

77

Item 18 DOE welcomes comment on the use of the planned 

operating hour profile for fluorescent lamp ballasts in this rule. 

Furthermore, DOE welcomes comment on whether the enduse operating profiles are different for the various types of 

fluorescent lamp ballasts covered under this rulemaking, and if 

so, how. 

Request for Comment

Energy Use and End-Use Load Characterization

78

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

EERE-2007-BT-STD-0016 COMMENT 07
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40

79

Purpose

• Assess the payback period (PBP) and the net life-cycle cost (LCC) 

impacts on the consumer of fluorescent lamp ballast efficiency 

standards.

Method

• LCC equals consumer price plus the sum of annual operating costs 

discounted to a particular base year

• Economic evaluation from the consumer perspective

• Analysis implemented in an Excel® spreadsheet

• Results expressed as LCC difference (baseline minus standard level)

• Simple Payback (years) is also calculated and reported

Consumer Life 

Cycle Cost

(Baseline and Standard)

LCC impacts

(difference between

Operating Cost baseline and standard)

(Sum & discount to 

present value)

First Cost

(Consumer Price & 

Installation)

Life-Cycle Cost and Payback Period Analysis

80

Approach

Life-Cycle Cost and Payback Period Analysis

• Monte Carlo simulation analysis to be used.

– Characterize the variability and uncertainty associated with the

inputs using probability distributions.

– Probability distributions will be used to characterize the uncertainty 

in operating cost inputs (e.g., discount rates, operating hours).

– Correlate inputs where necessary (e.g., electricity price, sector).

EERE-2007-BT-STD-0016 COMMENT 07
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81

Sales Tax Total Installed

Cost

End-User

Direct Price

System 

Power

Operating

Hours Electricity 

Price 2014

Annual Electricity

Cost

Annual Energy

Consumption

Operating

Cost

Lifetime 

Operating Cost

Payback

Period

Life-Cycle

Cost

Discount Rate

Electricity 

Price Trend

Input Value Output

Lamp Price

Lamp Lifetime

Maintenance and 

Analysis Repair Costs

Period Ballast Lifetime

Lamp Installation

Costs

Ballast Installation

Costs

Life-Cycle Cost and Payback Period Analysis

82

Annual Energy Costs

• DOE will develop electricity prices from DOE-Energy Information 

Administration (EIA) Form 861 data. 

• DOE will use projections of national average energy prices for 

residential, commercial, and industrial consumers from EIA’s Annual 

Energy Outlook (AEO) as input for future energy prices.

• DOE may conduct a sensitivity analysis using high and low electricity 

prices to determine the impact on economic feasibility.

Item 21 DOE welcomes input on the electricity prices used in 

this analysis.

Life-Cycle Cost and Payback Period Analysis

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83

Installation, Maintenance and Repair Costs

• Installation costs: May not change with more energy-efficient fluorescent 

lamp ballast designs as new regulations may not change either the ballast 

lifetime or the labor costs for installing a standards-compliant ballast.

• Maintenance costs: Could change with more energy-efficient ballast 

designs:

– If a standard level results in a shift from T12 to T8 ballasts, the equipment cost 

of the replacement T12 and T8 lamp may be different. 

– Labor costs of installing a fluorescent lamp will not change with more efficient 

ballasts as more energy-efficient ballasts would not significantly impact the 

useful lifetime (i.e., shorter or longer) of the lamps operated by those ballasts.

• Repair costs: May not be a part of the LCC analysis because fluorescent 

lamp ballasts are not “repaired” as ballasts are generally replaced at the 

end of their useful life. 

Life-Cycle Cost and Payback Period Analysis

84

Request for Comment

Item 23 DOE welcomes comment on how to develop 

installation, maintenance, and (if applicable) repair costs for 

fluorescent lamp ballasts. In particular, will fluorescent lamp

ballast energy conservation standards affect the useful lifetime

of the ballasts and/or the fluorescent lamps operated by those 

ballasts? If the lamps operated by the more efficient ballasts 

would be impacted, then DOE invites stakeholder comment on 

whether re-lamping practices (i.e., group re-lamping and spot 

re-lamping) would change as a result of the standard.

Item 24 DOE welcomes comment on appropriate fluorescent 

lamp ballast lifetimes for the ballasts covered in this 

rulemaking.

Life-Cycle Cost and Payback Period Analysis

EERE-2007-BT-STD-0016 COMMENT 07
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85

Discount Rate

• Discount rates are used to convert streams of annual operating 

expenses to present value in the LCC analysis.

• DOE will derive a distribution of discount rates for the 

commercial and industrial sectors.

– These distributions will be developed by estimating the weighted 

average cost of capital (or WACC) for commercial and industrial 

consumers of ballasts.

– WACC includes:

• Financial cost of any debt incurred to purchase products. 

• Opportunity cost of any equity to purchase products.

Item 22 DOE welcomes input on the planned approaches for 

estimating discount rates for consumers of fluorescent lamp ballasts 

covered under this rulemaking.

Life-Cycle Cost and Payback Period Analysis

86

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

EERE-2007-BT-STD-0016 COMMENT 07
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87

Purpose

• Quantify changes in product shipments due to potential new or 

amended energy efficiency standards.

Method

• The shipments model will rely on a range of data sources.

• The model will only consider shipments of covered products.

• Two Possible Approaches:

– Shipment projections based on historical data.

– Shipment projections based on modeling the installed base of 

fluorescent lamp ballasts nationally.

Shipments Analysis

DOE welcomes input on these two approaches or others for 

estimating fluorescent lamp ballasts shipments.

88

Shipments Analysis

Base-Case Shipments Forecast Approach

• Depicts the situation where new or amended standards are not 

adopted.

• Depicts the current mix of ballast efficiencies sold in the absence of 

new regulation.

• Shipments forecast by market segment: (1) new construction sales; 

(2) replacements for failed units; and (3) retrofits.

• Data requirements:

– Historical shipments

– Breakdown of shipments by market segment (e.g., new construction, 

replacements, and retrofits), end-use sector, and product class

EERE-2007-BT-STD-0016 COMMENT 07
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45

89

Request for Comment

Item 25 DOE welcomes recommendations on the sources of data that 

would provide information on shipments of fluorescent lamp ballasts by 

product class and BEF distributions within those product classes. In 

addition, DOE welcomes comment or recommendations on how it 

might characterize long-term trends in efficiency of fluorescent lamp 

ballasts for the base-case shipments forecast.

Item 26 DOE welcomes comment on the accounting methodology for 

each of the fluorescent lamp ballasts covered in this rulemaking.

Shipments Analysis

DOE welcomes comment on the breakdown of fluorescent lamp ballast 

shipments by market segment and sector.

90

Shipments Analysis

Standards Impacts on Ballast Shipments

• DOE develops Standards-Case Forecasts from the same data it 

will use to develop the Base-Case Forecast.

• Standards-Case Forecasts may also use purchase price increases 

and operating cost savings to estimate shipments impacts.

• DOE will also consider impacts from market-pull programs.

• Impacts on the total amount of light produced by these ballasts in 

the commercial and industrial sector may also be considered.

Item 27 DOE welcomes comment on how any new energy 

conservation standard for fluorescent lamp ballasts might impact

shipments of these ballasts. DOE also invites information about

market-pull programs that promote the adoption of more-efficacious 

ballasts.

EERE-2007-BT-STD-0016 COMMENT 07
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46

91

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Shipments

Analysis

National

Impact

Analysis

Product Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Steps in the Standards Rulemaking: ANOPR

Preliminary 

Manufacturer 

Impact 

Analysis

Energy Conservation Standards

Energy Use and 

End-Use Load 

Characterization

92

Purpose

• Determine the projected national energy savings and consumer 

national net present value.

Method

• Utilize the shipments model to estimate the total stock of fluorescent 

lamp ballasts in service each year.

• Estimate cost and energy use per unit from LCC.

• Aggregate the costs and energy use over the analysis period.

• Report national energy savings (NES) in Quads of primary energy 

consumption.

• Energy savings will take into account HVAC interactions and the 

rebound effect.

• Report estimates for economic impact as change in consumer 

National Net Present Value (NPV) (in constant year dollars).

• Account for the time-value of money though defined discount rates.

National Impact Analysis

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93

Base Case

Annual Energy

Consumption

2043

Base Case

Annual Energy

Consumption

2016

Base Case

Annual Energy

Consumption

2015

Base Case

Annual Energy

Consumption

2014

National Energy Savings Flow Diagram

National Impact Analysis

Shipments

Analysis

StandardsCase Projection

Base-Case 

Projection

Base Case

Annual Energy

Consumption

2043

Base Case

Annual Energy

Consumption

2016

Base Case

Annual Energy

Consumption

2015

Standards Case

Annual Energy

Consumption

2014

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site to Source

Energy

Conversion

National Energy

Savings

94

National Consumer Net Present Value Flow Diagram

National Impact Analysis

Shipments

Analysis

StandardsCase Projection

Energy

Cost

(2014 –

2043)

Base-Case 

Projection

Cumulative

Operating Cost 

Savings

Cumulative

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Maint &

Install Cost

(2014 –

2043)

Product 

Cost

(2014 –

2043)

Energy

Cost

(2014 –

2043)

Maint &

Install Cost

(2014 –

2043)

Product

Cost

(2014 –

2043)

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95

Item 28 DOE welcomes comment on the data sources it 

anticipates using to develop inputs for the national impact 

analysis.

Item 29 DOE welcomes comment on the NES spreadsheet 

models it proposes to use for estimating national impacts of 

energy conservation standards for fluorescent lamp ballasts.

National Impact Analysis

Request for Comment

96

2

3

NOPR Analyses

1

ANOPR Analyses

4

Rulemaking Overview

Introduction

2

Energy Conservation Standards

Test Procedure

3

Introduction

5 NOPR Analyses

4 ANOPR Analyses

6 Closing Remarks

Public Meeting Agenda

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97

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

98

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

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99

Purpose

• Analyze the economic impacts of standards on consumers, 

including subgroups who may be disproportionately impacted 

compared with the general user population.

Method

• Extend the LCC analysis to examine the impacts for defined 

subgroups.

Life-Cycle Cost Subgroup Analysis

Item 30 The Department welcomes comment on what, if 

any, consumer subgroups are appropriate in considering 

standards for fluorescent lamps ballasts. 

100

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

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101

Manufacturer Impact Analysis

Legislative Requirements

• The Manufacturer Impact Analysis (MIA) fulfills a legislative 

requirement to determine if a proposed standard is economically 

justified.

– EPCA provides 7 factors to evaluate in determining whether an 

efficiency standard is justified. Two factors are addressed in the MIA:

• Economic impact of standards on manufacturers

• Impacts of any lessening of competition in the industry

– MIA format changes described in the 2006 report to Congress, at:

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html

• DOE will collect, evaluate, and report preliminary MIA data in the 

ANOPR

• Preliminary data includes: anticipated conversion capital 

expenditures by efficiency level and anticipated direct employment 

impacts

102

Manufacturer Impact Analysis

Purpose

• Assess the impacts of standards on manufacturers. 

• Identify and estimate impacts on manufacturer subgroups that 

may be more severely impacted than the industry as a whole.

• Examine the impact of cumulative regulatory burden on the 

industry.

Method

• Analyze industry cash flow and net present value through use of 

the Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop 

subgroup analyses, and address qualitative issues.

Output

• Industry Net Present Value impacts

• Subgroup Net Present Value impacts

• Other impacts

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103

Manufacturer Impact Analysis

Methodology

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

Industry 

profile

Develop 

straw-man 

GRIM*

Develop 

interview 

guide

Interviews

& industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 3

Preliminary 

MIA 

Interviews

Phase 1

ANOPR NOPR

104

Manufacturer Impact Analysis

Methodology: Phase 2

• Consists of the strawman GRIM and interview guide preparation

Strawman GRIM

» Starting point for discussion of 

impacts

» Inputs include:

» Manufacturer prices

» Shipment forecasts

» Manufacturing cost estimates

» Financial information

» Starting point for discussion of 

impacts

» Inputs include:

» Manufacturer prices

» Shipment forecasts

» Manufacturing cost estimates

» Financial information

Interview Guide Preparation

» Interview topics include:

» Engineering analysis

» Shipments model

» Cost structure and financial 

parameters

» Conversion costs

» Cumulative burden

» Direct employment impacts

» Import / Export issues

» Consolidation / competitive impacts

» Replacement parts or refurbishments

» Impact of the standard’s effective date

» Interview topics include:

» Engineering analysis

» Shipments model

» Cost structure and financial 

parameters

» Conversion costs

» Cumulative burden

» Direct employment impacts

» Import / Export issues

» Consolidation / competitive impacts

» Replacement parts or refurbishments

» Impact of the standard’s effective date

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105

Manufacturer Impact Analysis

Methodology: Phase 3

• Consists of the manufacturer interviews, subgroup analyses, and 

assessment of industry impacts

Manufacturer Interviews

» Confidential discussion of potential 

impacts resulting from standards, 

including:

» Obsolescence of existing 

manufacturing assets

» Tooling

» Investment

» Confidential discussion of potential 

impacts resulting from standards, 

including:

» Obsolescence of existing 

manufacturing assets

» Tooling

» Investment

Assessment of Impacts

» Assess competitive impacts on 

smaller, significant manufacturers

» Assess cumulative regulatory 

burden on manufacturers from 

amended DOE standards and other 

regulatory actions

» Assess impacts on industry 

employment levels

» Assess impacts on manufacturer 

subgroups

» Assess competitive impacts on 

smaller, significant manufacturers

» Assess cumulative regulatory 

burden on manufacturers from 

amended DOE standards and other 

regulatory actions

» Assess impacts on industry 

employment levels

» Assess impacts on manufacturer 

subgroups

106

Manufacturer Impact Analysis

Cumulative Regulatory Burden

• Regulations that could affect the industries impacted by this 

rulemaking include:

– DOE energy conservation standards for fluorescent lamp ballasts 

enacted on September 19, 2000 (65 FR 56740) and by EPACT 2005;

– New EPCA standards, prescribed in EPACT 2005, for medium-base 

compact fluorescent lamps, and mercury vapor lamp ballasts;

– New EPCA standards for incandescent lamps and metal halide lamp 

fixtures prescribed in EISA 2007;

– Existing and/or proposed State standards for high intensity discharge 

ballasts, and/or under-cabinet luminaires;

– State building energy codes lighting requirements (e.g. American

Society of Heating, Refrigerating, and Air-Conditioning Engineers 

Standard 90.1); and

– International standards, including Canada’s regulation on fluorescent 

lamp ballasts.

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107

Manufacturer Impact Analysis

Item 31 If appropriate, what are potential subgroups of 

fluorescent lamp ballast manufacturers that DOE should 

consider in a manufacturer subgroup analysis?

Item 32 DOE welcomes comment on what other regulations 

or pending regulations it should consider in its examination of 

cumulative regulatory burden.

Request for Comment

108

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

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109

Purpose

• Assess the overall impacts on domestic energy supplies that 

would result from the imposition of standards. 

Utility Impact Analysis

• The Department proposes to use NEMS-BT, a variant of the 

NEMS (National Energy Modeling System) developed and used 

by DOE/EIA for their Annual Energy Outlook report, as the basis 

of the Utility Impact Analysis.

• Outputs of the utility impact analysis include forecasts of 

electricity generation, sales, price, and avoided capacity resulting 

from a comparison of base and standards cases.

• DOE will model the energy savings impacts from amended 

energy conservation standards using NEMS-BT to generate 

forecasts that deviate from the AEO reference case.

Method

110

Request for Comment

Item 33 The Department welcomes input from stakeholders 

on its plans to use NEMS-BT to conduct the utility impact 

analysis.

Utility Impact Analysis

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111

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

112

Purpose

• Assess the overall impact on national employment from the imposition of 

efficiency standards at differing levels.

• Include both direct and indirect employment impacts.

– Direct employment impacts are estimated in the manufacturer impact 

analysis.

– Indirect employment impacts result from shifting consumer expenditures 

among goods and services ( “substitution effect”) and changing equipment 

and energy costs (“income effect”).

Method

• DOE intends to use the ImSET (Impact of Sector Energy Technologies) 

model for the evaluation of indirect employment impacts. (Note: ImSET 

is an update of IMBUILD.)

Employment Impact Analyses

Item 34 The Department welcomes feedback on its planned approach 

to assessing national employment impacts, both direct and indirect.

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113

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

114

Purpose

• Estimate national environmental impacts from new energy efficiency 

standards for fluorescent lamp ballasts.

Method

• DOE intends to use the environmental impacts predicted from the 

NEMS-BT modeling analysis used for the Utility Impacts Analysis. 

– Carbon dioxide (CO2) will be the primary emissions reported.

– Existing legislation caps SO2, NOx, and mercury emissons, so physical 

emission reductions will be zero or nearly zero from any single energy 

conservation standard. 

Environmental Assessment

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115

Item 35 DOE welcomes feedback on its planned approach to 

assessing national environmental impacts, including other 

factors or approaches that should be considered.

Request for Comment

Environmental Assessment

116

Framework

Document ANOPR NOPR Final

Rule

Effective

Date

Steps in the Standards Rulemaking: NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise 

ANOPR 

Analyses

Environmental 

Assessment

Regulatory

Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Energy Conservation Standards

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117

Purpose

• Explore the potential for non-regulatory alternatives to new 

manufacturing efficiency standards.

Regulatory Impact Analysis

Method

• Base the assessment on the actual impacts of any such initiatives 

to date, but will consider information presented regarding the 

impacts that any existing initiative might have in the future.

118

2

3

NOPR Analyses

1

ANOPR Analyses

4

Rulemaking Overview

Introduction

2

Energy Conservation Standards

Test Procedure

3

Introduction

5 Final Rule

4 ANOPR Analyses

6 Closing Remarks

5 NOPR Analyses

Public Meeting Agenda

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119

Closing Remarks

How to Submit Written Comments

In all correspondence, please refer to the Fluorescent Lamp Ballast 

rulemaking by:

– Fluorescent Lamp Ballast Rulemaking,

– Docket Number EERE–2007–BT–STD–0016, and

– Regulatory Identification Number (RIN) 1904-AB50

Email: Ballasts.Rulemaking@ee.doe.gov

Comment period closes: March 7, 2008

Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 6th Floor

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586 2945

Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Postal: Courier:

EERE-2007-BT-STD-0016 COMMENT 07