Energy Conservation Standards

Rulemaking Framework Document for

Fluorescent Lamp Ballasts

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

January 14, 2008

EERE-2007-BT-STD-0016 COMMENT 01
TABLE OF CONTENTS

1 INTRODUCTION .................................................................................................................. 1

1.1 The Appliances and Commercial Equipment Standards Program.................................. 2

1.2 Overview of Definition and Sub­categories of Covered Fluorescent Lamp Ballasts..... 5

1.3 Overview of the Rulemaking Process............................................................................. 7

1.3.1 Test Procedures....................................................................................................... 7

1.3.2 Rulemaking Process and Stakeholder Participation ............................................... 9

1.4 Advance Notice of Proposed Rulemaking.................................................................... 11

1.5 Notice of Proposed Rulemaking ................................................................................... 13

1.6 Final Rule...................................................................................................................... 14

2 OVERVIEW OF ANALYSES FOR RULEMAKING......................................................... 14

3 MARKET AND TECHNOLOGY ASSESSMENT............................................................. 16

3.1 Market Assessment ....................................................................................................... 16

3.2 Product Classes............................................................................................................. 18

3.3 Technology Assessment................................................................................................ 20

4 SCREENING ANALYSIS ................................................................................................... 22

5 ENGINEERING ANALYSIS............................................................................................... 23

5.1 Engineering Analysis Overview ................................................................................... 23

5.2 Baseline Models............................................................................................................ 23

5.3 Engineering Analysis Approach ................................................................................... 24

5.4 Proprietary Designs....................................................................................................... 25

5.5 Outside Regulatory Changes Affecting the Engineering Analysis............................... 26

6 ENERGY USE AND END­USE LOAD CHARACTERIZATION .................................... 26

7 PRODUCT PRICE DETERMINATION ............................................................................. 27

8 LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSIS .......................................... 29

8.1 Energy Prices................................................................................................................ 30

8.2 Life­Cycle Cost Discount Rates.................................................................................... 31

8.3 Installation, Maintenance, and Repair Costs................................................................. 31

8.4 Fluorescent Lamp Ballast Lifetimes............................................................................. 32

9 SHIPMENTS ANALYSIS ................................................................................................... 32

9.1 Base Case Forecast ....................................................................................................... 33

9.2 Accounting Methodology ............................................................................................. 33

9.3 Standards Impacts on Ballast Shipments...................................................................... 34

10 NATIONAL IMPACT ANALYSIS..................................................................................... 34

10.1 Inputs to Forecasts ........................................................................................................ 35

10.2 Calculation of National Energy Savings....................................................................... 36

10.3 Net Present Value ......................................................................................................... 37

11 LIFE­CYCLE COST SUBGROUP ANALYSIS ................................................................. 38

12 MANUFACTURER IMPACT ANALYSIS......................................................................... 38

12.1 Sources of Information for the Manufacturer Impact Analysis.................................... 39

12.2 Industry Cash Flow Analysis........................................................................................ 40

12.3 Manufacturer Subgroup Analysis................................................................................. 40

12.4 Competitive Impacts Analysis...................................................................................... 40

12.5 Cumulative Regulatory Burden .................................................................................... 41

i

EERE-2007-BT-STD-0016 COMMENT 01
13 UTILITY IMPACT ANALYSIS.......................................................................................... 41

14 EMPLOYMENT IMPACT ANALYSIS.............................................................................. 42

15 ENVIRONMENTAL ASSESSMENT ................................................................................. 43

16 REGULATORY IMPACT ANALYSIS .............................................................................. 45

APPENDIX A – EPCA DIRECTIVES REGARDING FLUORESCENT LAMP BALLASTS . 47

APPENDIX B ­ DEFINITIONS................................................................................................... 52

APPENDIX C – TEST PROCEDURES ...................................................................................... 56

APPENDIX D – ENERGY INDEPENDENCE AND SECURITY ACT OF 2007..................... 60

APPENDIX E – LIST OF ITEMS FOR COMMENT.................................................................. 68

LIST OF TABLES

Table 1.1 Rulemaking Schedule for Fluorescent Lamp Ballast Energy Conservation Standard . 11

Table 3.1 EPCA Product Classes established by NAECA 1988 for Fluorescent Lamp Ballasts. 19

Table 3.2 EPCA Product Classes established by EPACT 2005 for Fluorescent Lamp Ballasts.. 19

Table 8.1 Inputs to the Life­Cycle Cost and Payback Period Analysis........................................ 30

Table 10.1 Inputs to the National Impact Analysis...................................................................... 36

LIST OF FIGURES

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard

Rulemaking................................................................................................................................... 15

ii

EERE-2007-BT-STD-0016 COMMENT 01
LIST OF ACRONYMS

AEO Annual Energy Outlook

ANOPR advance notice of proposed rulemaking

ANSI American National Standards Institute

BF ballast factor

BEF ballast efficacy factor

BT Building Technologies Program

CAIR Clean Air Interstate Rule

CAMR Clean Air Mercury Rule

CFR Code of Federal Regulations

CBECS Commercial Building Energy Consumption Survey

CSL candidate standard level

DOE U.S. Department of Energy

DOJ U.S. Department of Justice

EIA Energy Information Administration

EISA 2007 Energy Independence and Security Act of 2007

EPACT 1992 Energy Policy Act of 1992

EPACT 2005 Energy Policy Act of 2005

EPCA Energy Policy and Conservation Act

F Fahrenheit

FR Federal Register

F34T12 Nominally 34W T12 4­foot medium bipin lamp

F40T12 Nominally 40W T12 4­foot medium bipin lamp

F96T12 Nominally 75W T12 8­foot single pin slimline lamp

F96T12/ES Nominally 60W T12 8­foot single pin slimline lamp

F96T12HO Nominally 110W T12 8­foot recessed double contact high output lamp

F96T12HO/ES Nominally 95W T12 8­foot recessed double contact high output lamp

GRIM Government Regulatory Impact Model

Hg mercury

HVAC heating, ventilating, and air­conditioning

IESNA Illuminating Engineering Society of North America

LCC life­cycle cost

LMC Lighting Market Characterization

MECS Manufacturer Energy Consumption Survey

MIA manufacturer impact analysis

NAECA 1988 National Appliance Energy Conservation Amendments of 1988

NEMS National Energy Modeling System

NES national energy savings

NOPR notice of proposed rulemaking

NOx nitrogen oxides

NPV net present value

OMB U.S. Office of Management and Budget

PBP payback period

SO2 sulfur dioxide

TSD technical support document

iii

EERE-2007-BT-STD-0016 COMMENT 01
T5, T8, T12 tubular fluorescent lamps, diameters of 5/8, 1, or 1.5 inches, respectively

U.S.C. United States Code

W watt

iv

EERE-2007-BT-STD-0016 COMMENT 01
1

Rulemaking Framework Document for Fluorescent Lamp Ballasts

INTRODUCTION

The U.S. Department of Energy (DOE) Appliances and Commercial Equipment

Standards Program, within the Office of Energy Efficiency and Renewable Energy’s Building

Technologies Program (BT), develops and promulgates test procedures and energy conservation

standards for consumer appliances and commercial equipment. As a general matter, the process

for developing standards involves analysis, public notice, and consultation with interested

parties. Such parties, collectively referred to as “stakeholders,” include manufacturers,

consumers, energy conservation and environmental advocates, State and Federal agencies, and

any other groups or individuals with an interest in these standards and test procedures. A DOE

Report to Congress1 submitted on January 31, 2006, identifies the rulemakings DOE has

scheduled for completion by June 2011 and explains many of the techniques DOE will be

applying during the rulemaking process to meet this schedule.

The purpose of this document is to describe the procedural and analytical approaches

DOE anticipates using to evaluate energy conservation standards for fluorescent lamp ballasts

(see section 1.1 below for a discussion of the statutory authority for this rulemaking). This

document is intended to inform stakeholders of the process DOE will follow for the standards

rulemaking for these ballasts and to encourage and facilitate stakeholder input during the

rulemaking. It should be noted that this document is merely the starting point for developing

standards and is not a definitive statement with respect to any issue to be determined in the

rulemaking.

Section 1 of this report provides an overview of DOE’s rulemaking process. Sections 2

through 16 discuss analyses DOE intends to conduct to fulfill the statutory requirements and

guidance for this particular standards rulemaking. As an initial matter, it should be noted that the

category “fluorescent lamp ballasts” includes several distinct types of ballasts. DOE will

conduct separate analyses for each ballast type to determine whether amended energy

conservation standards are technologically feasible, economically justified, and would result in

significant energy savings. DOE will maintain information regarding this rulemaking on its

website at:

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

While DOE invites comment on all aspects of the material presented in this document, 

several specific issues on which DOE seeks comment are set out in comment boxes like this

one. DOE uses these comment boxes to highlight issues and ask specific questions on the

approaches DOE is proposing to follow to conduct the analyses required for the standards

rulemaking. Such requests for feedback are numbered sequentially throughout the document

and are repeated in Appendix E.

Energy Conservation Standards Activities; Submitted Pursuant to Section 141 of the Energy Policy Act of 2005

and to the Conference Report (109-275) to the FY 2006 Energy and Water Development Appropriations Act;

U.S. Department of Energy (Jan. 31, 2006). Available at: 

http://www.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.pdf.

1

1

EERE-2007-BT-STD-0016 COMMENT 01
1.1 The Appliances and Commercial Equipment Standards Program

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94­163, (42 U.S.C.

6291–6309) established an energy conservation program for major household appliances.

Additional amendments to EPCA have given DOE the authority to regulate the energy efficiency

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

of this document. Amendments to EPCA in the National Appliance Energy Conservation

Amendments of 1988 (NAECA 1988), Pub. L.100­357, established energy conservation

standards for fluorescent lamp ballasts. 2 (42 U.S.C. 6295(g)(5)) A table of the standards

promulgated by NAECA 1988 can be found in Appendix A of this document. These same

amendments also required that DOE: (1) conduct two rulemaking cycles to determine whether

these standards should be amended; and (2) for each rulemaking cycle, determine whether the

standards in effect for fluorescent lamp ballasts should be amended so that they would be

applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)­(B))

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

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

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

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

lamp ballast industry and energy­efficiency advocacy organizations. The standard levels adopted

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

fluorescent lamp ballasts. The standard level adopted was intended to eliminate certain so­called

“magnetic” ballasts which operate lamps at line frequency (60 Hertz) and are less efficient than

“electronic” ballasts, which operate lamps at high frequency.3 A table of the standards codified

by DOE can be found in Appendix A under 10 CFR 430.32(m)(3).

It was later realized that due to the structure of the language in the consensus standard

adopted by DOE in the 2000 Ballast Rule, it would still be possible for manufacturers to produce

and sell magnetic ballasts for certain types of fluorescent lamps. Aware of this problem,

Congress took action on this issue, and promulgated new energy conservation standards for

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

109­58. (EPACT section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)) On October 18, 2005,

DOE published a final rule in the Federal Register codifying those new fluorescent lamp ballast

standards into the Code of Federal Regulations (CFR) at 10 CFR 430.32(m). 70 FR 60407.

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

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

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

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

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

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

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

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

fluorescent lamp ballasts and urinals. Second, Subchapter III has “Part A­1 – Certain Industrial Equipment,” which

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

pumps, and packaged terminal air conditioners and heat pumps. 3 The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40 watt (W)

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

(F96T12).

2

EERE-2007-BT-STD-0016 COMMENT 01
These standards established minimum ballast efficacy requirements for “energy saver” versions

of full­wattage ballasts, such as the F34T12 ballast. A table of the standards promulgated by

EPACT 2005 can be found in Appendix A under 10 CFR 430.32(m)(5).

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

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

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

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

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

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

hertz. 10 CFR 430.32(m). Ballasts that are excluded from regulation include: (1) ballasts

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

with two F96T12HO lamps at ambient temperatures of ­20 degrees Fahrenheit (°F) or less and

for use in an outdoor sign or ballasts designed for use with two F96T12HO/ES lamps at ambient

temperatures of 20°F or less and for use in an outdoor sign;4 (3) ballasts with a power factor of

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

replacement ballasts as defined in paragraph (m)(4)(ii).5 10 CFR 430.32(m)(2), (m)(4), and

(m)(7).

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

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

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

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

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

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

standby mode and off mode energy consumption by March 31, 2009. (42 U.S.C.

6295(gg)(2)(B)(ii)) In addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate

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

2010. Because this energy conservation standards rulemaking for fluorescent lamp ballasts will

be completed in 2011, the requirement to incorporate standby mode energy use into the energy

conservation standards analysis is applicable.

At this time, DOE is studying the standby mode and off mode energy use provisions from

EISA 2007 that apply to fluorescent lamp ballasts that are (or could be) covered by this

rulemaking. DOE understands that standby mode and off mode energy use, as defined in EISA

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

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

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

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

temperatures of negative 20 degrees F or less. 5 The exclusion provided for replacement ballasts requires that they meet certain criteria in order to be considered a

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

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

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

430.32(m)(4)(ii)(A)) See Appendix A for the exact language of the exclusion for replacement ballasts.

3

EERE-2007-BT-STD-0016 COMMENT 01
20076

, is nonexistent for typical ballasts that operate on a switch or a motion sensor. Fluorescent

lamp ballast never meet the definition of “off mode.” When a fluorescent lamp ballast is not

providing any standby or active mode function (i.e., meeting part II of the definition of “off

mode”), the fluorescent lamp ballast must be entirely disconnected from the main power source

(i.e., not meeting part I of the definition of “off mode.”) In addition, fluorescent lamp ballasts

typically do not have a standby mode in which the ballast offers a secondary user­oriented or

protective feature while not providing its main function of driving a fluorescent lamp to emit

light. DOE understands that it may be possible for a dimming ballast to operate in a zero­lightoutput standby mode. However, dimming ballasts that dim below 50 percent of rated light

output are exempted from the standards. Finally, DOE understands that new ballasts are now

being designed with circuitry that adds new features, including intelligent operation. One

example of these new ballast designs is a DALI7

­enabled ballast. DALI­enabled ballasts may

have standby power, as they have internal circuitry that is integral to the design of the ballast that

remains on and active, even when the ballast is not driving any lamps. DOE is continuing to

study DALI­enabled ballasts, as well as other types of fluorescent lamp ballasts to evaluate the

issue of standby mode energy use. At the end of this section, DOE invites stakeholder comment

on this issue of standby mode and off mode energy use, as it relates to both the test procedure

and the energy conservation standards rulemaking for fluorescent lamp ballasts.

In section 324 of EISA 2007, “Metal Halide Lamp Fixtures,” several definitions are

provided, including “ballast” and “electronic ballast,” which although they appear in the section

pertaining to standards for Metal Halide Lamp Fixtures, are written in such a way that they also

apply to fluorescent lamp ballasts:

“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))

In addition, section 324 of EISA 2007 establishes new energy efficiency standards for ballasts

that operate in metal halide lamp fixtures. Although these new definitions and requirements do

not affect the analysis DOE intends to conduct on fluorescent lamp ballasts, DOE provides the

language from Section 324 in Appendix D of this Framework Document to facilitate stakeholder

review of the provisions pertaining to the definitions of “ballast” and “electronic ballast,” as well

6 In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii), section 310 of EISA 2007 defines “active mode,” “off

mode,” and “standby mode” as follows: “ The term ‘active mode’ means the condition in which an energy­using

product—(I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main

functions.” “The term ‘off mode’ means the condition in which an energy­using product— (I) is connected to a

main power source; and (II) is not providing any stand­by or active mode function.” “The term ‘standby mode’

means the condition in which an energy­using product­­ (I) is connected to a main power source; and (II) offers 1 or

more of the following user­oriented or protective functions: (aa) To facilitate the activation or deactivation of other

functions (including active mode) by remote switch (including remote control), internal sensor, or timer. (bb)

Continuous functions including information or status displays (including clocks) or sensor­based functions.” 7 DALI stands for the “Digital Addressable Lighting Interface,” and it represents a system that enables

communication between a central lighting controls system and the individual components, including the ballasts.

4

EERE-2007-BT-STD-0016 COMMENT 01
as the new ballast efficiency requirements for metal halide lamp fixtures. DOE is aware that

some of the same manufacturers produce both fluorescent lamp ballasts and metal halide lamp

fixture ballasts.

The above discussion summarizes the pertinent legislative and regulatory history for

fluorescent lamp ballasts, and it sets the stage for the issues raised in the balance of this

Framework Document, through which DOE is initiating its second cycle to review and to

consider amendments to the energy conservation standards in effect for fluorescent lamp ballasts

under section 325(g)(7)(B) of EPCA, reproduced below in its entirety:

(B) 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))

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

standards in effect for fluorescent lamp ballasts should be amended, which also fulfills the

corollary statutory requirement for DOE to determine whether the standards should be made

applicable to additional fluorescent lamp ballasts. This consideration regarding the application

of standards to additional fluorescent lamp ballasts is discussed in detail in the following section.

1.2 Overview of Definition and Sub­categories of Covered Fluorescent Lamp Ballasts

As stated in Section 1.1, EPCA directs DOE to determine whether current energy

conservation standards for fluorescent lamp ballasts should be made applicable to additional

fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) DOE is interpreting this directive as a

preliminary determination regarding expanded coverage to additional fluorescent lamp ballasts.

In other words, DOE will be determining whether an expansion of coverage to certain

fluorescent lamp ballasts is appropriate, and will solicit comment on that potential expansion.

This approach will provide stakeholders with several opportunities to review and comment on

DOE’s findings and analyses regarding which additional fluorescent lamp ballasts should be

evaluated as potential candidates for coverage and standards.

In the context of this rulemaking, DOE is raising the issue of the expansion of scope in

this Framework Document, to inform stakeholders of DOE’s intent to evaluate an expansion of

coverage and to request comment at this early stage in the rulemaking. In the ANOPR, DOE

will present its preliminary findings and rationale for potential expansion of coverage. In

deciding whether to establish energy conservation standards for additional ballasts, DOE will use

potential energy savings as its primary criteria. DOE will also consider technological feasibility

and economic justification as other factors in its evaluation. After identifying additional ballasts

for consideration, DOE will then conduct a preliminary assessment on whether a standard for

these ballasts would be technologically feasible and economically justified. (42 U.S.C.

6295(o)(2)(A)) Following publication of the ANOPR, stakeholders will have an opportunity to

comment on DOE’s analysis and initial position. Next, in the NOPR stage of the rulemaking,

5

EERE-2007-BT-STD-0016 COMMENT 01
DOE will present an analysis of comments on the ANOPR related to the expansion of coverage,

and then stakeholders will again have an opportunity to comment on DOE’s proposal. In the

final rule, DOE will publish its determination regarding the expansion of scope for fluorescent

lamp ballasts and, if appropriate, set standards under the authority of 42 U.S.C. 6295(g)(7)(B).

In seeking to implement the statutory directive to consider standards for additional

fluorescent lamp ballasts, DOE notes that there are currently a wide variety of fluorescent lamp

ballasts that are not covered by existing energy conservation standards. Accordingly, these

fluorescent lamp ballasts lamps are potential candidates for expanded coverage pursuant to 42

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

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 which 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. G­14:

The definition of a fluorescent lamp is “a low-pressure mercury electric-discharge lamp

in which a fluorescing coating (phosphor) transforms some of the UV energy generated

by the discharge into light.”

This IESNA definition closely matches the general description of a “fluorescent lamp” in

the introductory language of 42 U.S.C. 6291(30)(A).8 Because only lamps with these features

are commonly understood to be fluorescent lamps, DOE would only consider standards for

ballasts which operate such fluorescent lamps. Therefore, in considering whether to amend the

standards in effect for fluorescent lamp ballasts to apply to “additional” fluorescent lamp ballasts

under 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.

Like the fluorescent lamp market, the fluorescent lamp ballast market has diversified

since standards were first established for these covered products under EPCA.9 Currently, 4­foot

T8 medium bipin fluorescent lamp shipments are increasing, whereas 4­foot T12 medium bipin

fluorescent lamp shipments (F40T12 or F34T12 lamps) are decreasing, because 4­foot T12

ballasts are being replaced by 4­foot T8 ballasts. In 2004, shipments of 4­foot T8 lamps

8 The introductory language of 42 U.S.C. 6291(30)(A) is as follows: “the term ‘fluorescent lamp’ means a low

pressure mercury electric­discharge source in which a fluorescing coating transforms some of the ultraviolet energy

generated by the mercury discharge into light.” 9 Fluorescent lamp diameters are specified in the lighting industry by the letter “T,” which designates a tubular

shape, and a numerical value corresponding to a measurement in eighths of an inch. Thus, industry nomenclature

would refer to“T8” lamps as tubular fluorescent lamps having a diameter of one inch. Similarly, “T12” lamps are

fluorescent lamps with a diameter of one and a half inches.

6

EERE-2007-BT-STD-0016 COMMENT 01
exceeded those of 4­foot T12 shipments.10 The increase in 4­foot T8 lamp shipments will most

likely be compounded in 2010 when new energy conservation standards for fluorescent lamp

ballasts, including replacement F40T12 ballasts and new F34T12 ballasts, go into effect. (See 10

CFR 430.32(m)(4)(ii) and (5)­(6)) Eight­foot T8 single pin slimline lamps and 8­foot T8

recessed double contact high output lamps are also replacing their 8­foot T12 counterparts. DOE

is considering expanding its coverage to include ballasts that operate T8 lamps because of the

potential for significant energy savings. In addition, DOE may also expand its coverage to

include ballasts that operate one­ and three­lamp 4­foot T12 medium bipin lamps, one­lamp 8­

foot T12 single pin slimline lamps, one­lamp 8­foot T12 recessed double contact high output

lamps, and 2­foot U­shaped lamps. A detailed initial consideration of scope, including the

rationale for coverage for individual ballasts, will be published with DOE’s fluorescent lamp

ballast ANOPR. At this time, DOE is inviting comment on its planned expansion of scope for

fluorescent lamp ballasts.

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))

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?

1.3 Overview of the Rulemaking Process

1.3.1 Test Procedures

Under 42 U.S.C. 6293(b)(5), the statute directs DOE to establish test procedures for

fluorescent lamp ballasts that are in accord with ANSI C82.2­1984, “For Fluorescent Lamp

Ballasts­ Methods of Measurement,” or other test procedures determined appropriate by the

Secretary. The 1984 version of C82.2 internally references testing methods for magnetic ballasts

(ANSI C82.1­1977, “For Lamp Ballast­ Line Frequency Fluorescent Lamp Ballast”), but it does

not reference testing methods for electronic ballasts because the testing methods for electronic

ballasts were not yet developed in 1984. Because the market is moving towards electronic

ballasts,11 DOE believes it may be necessary to update the test procedures for fluorescent lamp

ballasts to the current industry standards, which would include electronic ballasts. At the same

time, DOE could also update its test procedure to include more recent testing methods for

magnetic ballasts. DOE may incorporate all of the following ANSI test procedures by reference

10 National Electrical Manufacturers Association. DOE Docket Number EE­2006­STD­0131, filing number 12, p.7

(Sept. 2006). 11 As described in Section 1.2, T8 lamps (mostly operated by electronic ballasts) are gaining market share, whereas

T12 lamps (mostly operated by magnetic ballasts) are losing market share.

7

EERE-2007-BT-STD-0016 COMMENT 01
in DOE’s test procedure rule for fluorescent lamp ballasts: ANSI C82.2­2002, “For Lamp

Ballasts­ Method of Measurement of Fluorescent Lamp Ballasts,” ANSI C82.1­2004, “For Lamp

Ballast­ Line Frequency Fluorescent Lamp Ballast,” and ANSI C82.11­2002, “For Lamp

Ballasts­ High Frequency Fluorescent Lamp Ballasts.” ANSI C82.2 and ANSI C82.1 are test

procedures for magnetic ballasts while ANSI C82.11 is a test procedure for electronic ballasts. If

these ANSI test procedures are updated during the course of this rulemaking, DOE will consider

updated versions in its test procedure rulemaking.

Item 3 DOE welcomes comment on the issue of updating its 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.

In its comparative review of ANSI C82.2­1984 and C82.2­2002, DOE observed a

difference in the methodology ANSI employs to determine the ballast factor (BF) for rapid­start

and instant­start ballasts. In the latter version of the ANSI standards, the method used for rapidstart ballasts involves measuring the light output of the lamp operated by the ballast, and

calculating the BF12 from these test results. This approach is consistent with DOE’s current test

procedure for fluorescent lamp ballasts.13 For instant­start ballasts however, ANSI calculates the

BF using the power delivered to the lamp, rather than the light output of test lamps connected to

the ballast. DOE is uncertain how comparable these two test methods are (i.e., whether the more

recent ANSI test procedure would alter the measure of energy efficiency (i.e., ballast efficacy

factor (BEF)) as compared to the DOE test procedure), and, therefore, is seeking comment on the

two ANSI approaches for determining ballast factor for rapid­start and instant­start ballasts. If

the methods are not comparable, DOE would be interested in understanding if there are any

conversion or adjustment factors that may be used to make the ballast factors between rapid­start

and instant­start equipment comparable.

Furthermore, DOE is interested in understanding how BF is calculated for programmedstart ballasts, as well as other types of fluorescent lamp ballasts such as modified­rapid­start

ballasts. Should any of the modifications to the test procedure cause a change in how the BEF is

calculated, those changes to the test procedure would only become effective on the date that any

amended energy conservation standards take effect.

12 The “ballast factor” (BF) of a rapid­start ballast is the ratio of the light output of a fluorescent lamp or lamps

operated on a ballast to the light output of the lamp(s) operated on a standard (reference) ballast. The light output of

a single fluorescent lamp is measured on a ballast with a BF of 1.0. The light output of a lamp can be increased or

decreased by operating a given lamp on a ballast with a higher or lower BF, respectively. 13 The measure of energy efficiency of a fluorescent lamp ballast (i.e., ballast efficacy factor (BEF)) is calculated in

DOE’s test procedure by taking the relative light output of a ballast (i.e., BF for rapid start lamps multiplied by 100)

divided by the input power of that ballast. 10 CFR Part 430, Subpart B, Appendix Q, 4.2 (b). A ballast that maintains

BF while reducing power consumption will have a higher BEF, and therefore would be considered a more energyefficient ballast. The energy conservation standards for fluorescent lamp ballasts are prescribed in terms of BEF.

8

EERE-2007-BT-STD-0016 COMMENT 01
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 BF calculation methods used for

programmed-start ballasts, modified-rapid-start ballasts, and other types of fluorescent

lamp ballasts not covered by the DOE test procedure or ANSI C82.2-2002.

1.3.2 Rulemaking Process and Stakeholder Participation

When DOE evaluates any new or amended energy conservation standard for “covered

products” under EPCA, the statute, as amended, specifies that any standard DOE prescribes for

consumer products shall be designed to “achieve the maximum improvement in energy

efficiency. . . which the Secretary [of Energy] determines is technologically feasible and

economically justified.” (42 U.S.C. 6295(o)(2)(A)) Moreover, EPCA states that the Secretary

may not establish an amended standard if such standard would not result in “significant

conservation of energy,” or “is not technologically feasible or economically justified.” (42

U.S.C. 6295(o)(3)(B)) In determining whether a standard is economically justified, DOE

considers, to the greatest extent practicable, the following seven factors:

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

products subject to such standard;

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

products in the type (or class) compared to any increase in the price, or in the initial

charges for, or maintenance expenses of the covered products which are likely to result

from the imposition of the standard;

(3) The total projected amount of energy (or as applicable, water) savings likely to result

directly from the imposition of the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result

from the imposition of the standard;

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

General, that is likely to result from the imposition of the standard;

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i))

Additional statutory requirements for prescribing new or amended standards are set forth in 42

U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)­(iii), and (3)–(5).

The process for developing efficiency standards involves analysis, public notice, and

consultation with interested parties. Such parties (collectively referred to as stakeholders)

9

EERE-2007-BT-STD-0016 COMMENT 01
generally include manufacturers, consumers, energy conservation and environmental advocates,

State and Federal agencies, and any other groups or individuals with an interest in energy

conservation standards and test procedures. DOE considers stakeholder participation to be a

very important part of the rulemaking process. Accordingly, DOE actively encourages the

participation and interaction of all stakeholders during the comment period provided at each

stage of the rulemaking. The broad array of stakeholders who routinely provide comments

promotes a balanced discussion of critical information required to conduct the standards

rulemaking, beginning with public comment on the Framework Document.

In conducting the test procedure rulemakings and the energy (and water) conservation

standards rulemakings, DOE involves stakeholders through a variety of means, including formal

public notifications (i.e., Federal Register notices) and public meetings. As discussed in further

detail below, the standards rulemaking process involves three major public notices, which are

published in the Federal Register:

• Advance notice of proposed rulemaking (ANOPR, see section 1.4). The ANOPR is

designed to publicly vet the models and tools that DOE will use in the rulemaking, and to

facilitate public participation before the proposed rule stage. Candidate standard levels,

which span the range of efficiencies from baseline products to the most efficient

technology, are the basis for demonstrating the functionality of the models and tools.

• Notice of proposed rulemaking (NOPR, see section 1.5). The NOPR presents: a

discussion of comments received in response to the ANOPR; the analysis of the impacts

of standards on consumers, manufacturers, and the nation; DOE’s weighting of the

impacts; and the proposed standard levels for public comment.

• Final rule (see section 1.6). The final rule presents a discussion of comments received in

response to the NOPR, the revised analysis of the impacts of standards, DOE’s weighting

of the impacts, and the standard levels DOE is adopting. The final rule also establishes

the effective date of the standards.

DOE’s January 31, 2006 Report to Congress presents the five­year rulemaking schedule

for the codes and standards program. Schedules for a broad set of rulemakings are laid out in the

report, including both new rulemakings from EPACT 2005 and “back­log” rulemakings from

prior EPCA amendments which DOE is in the process of addressing. The fluorescent lamp

ballast rulemaking is considered a “back­log” rulemaking. In the Report to Congress, DOE

selected certain energy conservation standards rulemakings as priority rulemakings and others as

so­called “valley­fill” rulemakings. Valley­filling is a management technique DOE is imposing

on itself to reduce the overall time necessary to complete a rulemaking. In essence, DOE assigns

two energy conservation standards rulemakings to one rulemaking team, a normal rulemaking

and a valley­fill rulemaking. In this way, when the analytical team is awaiting input on its

analysis pertaining to its current priority rule, it will re­direct its efforts to the valley­fill rule. By

having overlapping schedules for these two concurrent rulemakings, the average time necessary

to complete each of the two final rules is reduced overall, from 36 months each to 31.5 months

each.

10

EERE-2007-BT-STD-0016 COMMENT 01
Valley­fill rulemakings typically publish their ANOPR approximately two years after

publication of the Framework Document, whereas priority rulemakings typically publish the

ANOPR one and a half years after publication of the Framework Document. DOE has prepared

and intends to follow the schedule below for the fluorescent lamp ballast rulemaking.

Table 1.1 Rulemaking Schedule for Fluorescent Lamp Ballast Energy Conservation

Standard

Rulemaking Notice Publication Date

Framework Document January 2008

ANOPR November 2009

NOPR October 2010

Final Rule June 2011

The fluorescent lamp ballast energy conservation standard will be effective three years

after the final rule establishing energy conservation standards for fluorescent lamp ballasts (i.e.

in June 2014)(see 42 U.S.C. 6295(g)(7)(C)).

Concerning the fluorescent lamp ballast test procedure rulemaking, if DOE determines

that this rulemaking should be reopened and updated, the final rule for the test procedure would

be published on or before publication of the NOPR for the fluorescent lamp ballast energy

conservation standard, scheduled for October 2010 (see Table 1.1).

1.4 Advance Notice of Proposed Rulemaking

As part of its initial rulemaking activity, DOE typically conducts a screening analysis in

which product technology options are identified and subjected to a preliminary determination as

to whether DOE will retain that option for detailed analysis or to eliminate it from further

consideration. This process includes a market and technology assessment (see section 3) and a

screening analysis (see section 4). DOE applies four screening criteria in the screening analysis

to determine which technology options to eliminate from further consideration. These four

criteria are: (1) technological feasibility; (2) practicability to manufacture, install, and service;

(3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety.

Technologies that pass through the screening analysis are referred to as “design options” in the

engineering analysis.

These activities include consultations with stakeholders and independent technical

experts who can assist with identifying the key issues and design options or efficiency levels that

DOE will consider in the rulemaking. DOE intends this Framework Document, the public

meeting following its publication, and the opportunity for comment on this Framework

Document to initiate dialogue with stakeholders, and to provide an opportunity for comment and

input into the structure and analytical approach planned for this energy conservation standards

rulemaking.

11

EERE-2007-BT-STD-0016 COMMENT 01
At the start of the ANOPR analysis, DOE considers design options or efficiency levels

for each product class. DOE uses these design options or efficiency levels to collect

manufacturer cost data, historical shipment data, shipment­weighted average efficiency data, and

preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing costs,

research and development costs). During the ANOPR stage of the rulemaking, DOE also

conducts other principal analyses, including: (1) the engineering analysis (see section 5); (2) the

consumer LCC and PBP analysis (see section 8); (3) the national impact analysis, which

considers national energy savings (NES) and consumer net present value (NPV) (see section 10);

and (4) a preliminary manufacturer impact analysis (see section 12). DOE will present the

results of these analyses in the ANOPR Federal Register notice.

Discussion of various candidate standard levels (efficiency levels) in the ANOPR will

facilitate stakeholder review of the spreadsheet models that underpin the analyses. DOE will

use stakeholder comments to refine the models for the next stage of the rulemaking analyses,

where DOE will propose specific efficiency levels for adoption. Based on the results of the

ANOPR analysis, DOE selects candidate standard levels (CSLs) from the energy efficiency or

energy use levels considered in the ANOPR analysis. In addition to the efficiency corresponding

to the maximum technologically feasible (“max­tech”) design and the efficiency corresponding

to the minimum LCC point, DOE generally selects levels or design options for consideration that

span the full range of technologically­achievable efficiencies. The range of levels DOE typically

analyzes includes:

• The baseline efficiency level (i.e., the minimum level) is defined by the product with the

lowest energy efficiency level currently sold on the market for a given category. For

product categories where minimum energy efficiency standards already exist, the

baseline efficiency level is typically defined by the existing energy conservation

standard;

• The highest energy efficiency level or lowest energy consumption level that is

technologically feasible (i.e., the “max­tech” level);

• The level with the minimum life­cycle cost (LCC) or greatest LCC savings; and

• Levels that incorporate noteworthy technologies or fill in large gaps between other

efficiency levels considered.

The efficiency or energy use levels DOE analyzes serve to demonstrate the functions and

outputs of the models and tools. At the ANOPR stage, DOE uses analytical models and tools to

assess the different product classes at each efficiency or energy use level analyzed. Many of

these analytical models and tools are in the form of spreadsheets, some of which are used to

conduct the LCC and PBP analysis, as well as to determine the NES and NPV of prospective

standards. In addition, preliminary ANOPR results may facilitate discussions among interested

parties on potential joint recommendations for standard levels.

12

EERE-2007-BT-STD-0016 COMMENT 01
DOE will make the spreadsheet tools and results of the ANOPR analyses available on its

website for review and will consider comments on them after publication of the ANOPR.14

When it publishes the ANOPR, DOE will also make available a Technical Support

Document (TSD) containing the details of all the analyses performed to date. After the

publication of the ANOPR, DOE will provide a 75­day public comment period and hold one

public meeting. At this point, DOE encourages stakeholders, to the extent possible, to develop

joint recommendations for standard levels.

1.5 Notice of Proposed Rulemaking

In developing the NOPR, DOE will first review and consider all the comments it received

after the publication of the ANOPR. This process may result in revisions or refinements to the

ANOPR analyses, including the engineering and LCC analyses. DOE also will conduct

additional economic and environmental impact analyses at this stage of the rulemaking. These

analyses generally include a consumer LCC subgroup analysis (see section 11), a complete

manufacturer impact analysis (see section 12), a utility impact analysis (see section 13), an

employment impact analysis (see section 14), an environmental assessment (see section 15), and

a regulatory impact analysis (see section 16).

DOE will describe the methodology used and make the results of all the analyses

available on its website for review and comments. Based on comments by stakeholders, further

revisions to the analysis may be undertaken. This analytical process ends with the selection of

proposed standard levels (if any) that DOE will present in the NOPR. DOE selects the proposed

standard levels from the trial standard levels (TSLs) analyzed during the NOPR phase of the

rulemaking. The NOPR, published in the Federal Register, will document the evaluation and

selection of any proposed standards levels, along with a discussion of other TSLs considered but

not selected (and the reasons for not selecting them).

The selection process for proposed efficiency standards generally runs as follows. For

each product class, DOE will identify the max­tech efficiency level. If DOE proposes a level

lower than that, it will sequentially explain the reasons for eliminating higher levels, beginning

with the highest level considered. DOE will present the analytical results in the NOPR, with the

details of the analysis provided in an accompanying TSD.

DOE considers many factors in selecting proposed standards, as described above in

section 1.3.2. These factors and criteria are contained in EPCA and take into consideration the

benefits, costs, and impacts of energy conservation standards. Additionally, DOE encourages

stakeholders to develop joint recommendations for standard levels. DOE will carefully consider

such recommendations in its decision process.

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with

copies of the NOPR and TSD, in order to solicit feedback on the impact of the proposed standard

14 All materials associated with the fluorescent lamp ballast determination analyses, test procedures, and energy

conservation standards are available on DOE’s website at:

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

13

EERE-2007-BT-STD-0016 COMMENT 01
levels on competition in the ballast industry. DOJ will review these standard levels in light of

any lessening of competition that is likely to result from the imposition of standards (see 42

U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)). Publication of the NOPR will be followed by a 75­day

public comment period that includes one public meeting.

1.6 Final Rule

After the publication of the NOPR, DOE will consider public comments it receives on the

proposal (including TSLs) and accompanying analyses. On the basis of the public comments,

DOE will review the engineering and economic impact analyses and proposed standards and

consider modifications where necessary. Before the final rule is issued, DOE also will consider

DOJ comments on the NOPR relating to the impacts of the proposed standard levels on

competition, to determine whether changes to these standard levels are needed.

The standards rulemaking will conclude with the publication of the final rule. DOE will

select the final standard level based on the complete record of the standards rulemaking. The

final rule will promulgate the final standard level and the effective date and explain the basis for

their selection. The final rule will be accompanied by a final TSD.

2 OVERVIEW OF ANALYSES FOR RULEMAKING

The purpose of the analyses conducted in support of the standards rulemaking is to ensure

that DOE selects energy conservation standards that achieve the maximum improvement in

energy efficiency that is technologically feasible and economically justified, and will result in

significant energy savings. Economic justification includes the consideration of economic

impacts on domestic manufacturers and consumers, national benefits including environmental

impacts, issues of consumer utility, and impacts from any lessening of competition. DOE

expects the selection of such standards to achieve the maximum energy savings that are

economically justified without imposing excessive financial burden on any particular party.

Figure 1 summarizes the analytical components of the standards­setting process. The

“analyses” are presented in the center column. Each analysis has a set of “key inputs,” which are

data and information required for the analysis. “Approaches” are the methods that DOE will use

to obtain key inputs, which may vary depending on the information in question. For example,

some key inputs exist in public databases; DOE will collect other information from stakeholders

or experts with special knowledge, and DOE will develop yet other information independently in

support of this rulemaking. The results of each analysis are “key outputs,” which feed directly

into the rulemaking. Arrows indicate the flow of information between the various analyses.

DOE ensures a consistent approach to its analyses throughout the rulemaking by considering

each analysis as a part of the overall standards­setting framework.

14

EERE-2007-BT-STD-0016 COMMENT 01
Notice of Proposed Rulemaking (NOPR)

Final Rule

Framework Document

Advance Notice of Proposed Rulemaking (ANOPR)

Utility Impact

Analysis

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life­Cycle Cost and

Payback Period

Analyses

National Impact

Analysis

Energy Use

Revise ANOPR

Analyses

Life­Cycle Cost

Sub­Group Analysis

Manufacturer Impact

Analysis

Shipments

Analysis

Employment Impact

Analysis

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub­Group Cash­Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life­Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non­Regulatory Programs

• Efficiency­Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail

Prices

Design Energy/ Use

• Efficiency/Performance

• Commercial Products

Candidate

Standard

Levels

• Analysis of Energy Use

Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non­Regulatory

Alternatives

• NEMS­BT

• ImSET

• NEMS­BT

• Design Options

• Energy Price Forecasts

• Site­to­Source Factors

• Energy­Efficiency Levels

Direct Employment

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life­Cycle Costs

• Payback Periods

• 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

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy­Efficiency

Levels

• Department of Justice Review

Product Designs

Utility Impact

Analysis

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life­Cycle Cost and

Payback Period

Analyses

National Impact

Analysis

Energy Use

Revise ANOPR

Analyses

Life­Cycle Cost

Sub­Group Analysis

Manufacturer Impact

Analysis

Shipments

Analysis

Employment Impact

Analysis

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub­Group Cash­Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life­Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non­Regulatory Programs

Framework Document

• Efficiency­Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

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

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non­Regulatory

Alternatives

• NEMS­BT

• ImSET

• NEMS­BT

• Design Options

• Energy Price Forecasts

• Site­to­Source Factors

• Energy­Efficiency Levels

Direct Employment

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life­Cycle Costs

• Payback Periods

• 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

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy­Efficiency

Levels

• Department of Justice Review

Product Designs

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard

Rulemaking

15

EERE-2007-BT-STD-0016 COMMENT 01
3 MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the manufacturers

of fluorescent lamp ballasts and specifics about the performance attributes of these fluorescent

lamp ballasts. This assessment is particularly important at the outset of the rulemaking for

developing product classes and for identifying technology options that improve the BEF (i.e.,

efficiency) of fluorescent lamp ballasts.

3.1 Market Assessment

DOE will qualitatively and quantitatively characterize the structure of the markets for

fluorescent lamp ballasts. In the market assessment, DOE will identify and characterize the

manufacturers of this equipment, estimate market shares and trends, address regulatory and nonregulatory initiatives intended to improve the efficiency or reduce the energy consumption of

covered ballasts, and explore the potential for technological improvements in the design and

manufacturing of such equipment.

This market assessment will establish the context for this rulemaking, and it will serve as

a resource to guide the analyses that follow. For example, DOE may use historical shipments

and prices as an indicator of future shipments and prices. Similarly, DOE plans to use market

structure data for the manufacturer impact analysis, data which will be particularly useful for

assessing competitive impacts. This phase also allows DOE to start updating design options by

reviewing product literature and industry publications.

DOE recognizes that there may be limited public information on national shipments,

manufacturing costs, channels of distribution, and manufacturers’ market shares of fluorescent

lamp ballasts. This type of data is an important input for analyses that determine if energy

conservation standards are economically justified and will result in significant energy savings.

Therefore, DOE encourages stakeholders to submit data that pertains to these areas of interest

and would improve DOE’s understanding of the fluorescent lamp ballast market. These data

may be provided under a confidentiality agreement with DOE’s contractor responsible for this

part of the rulemaking analysis, namely Navigant Consulting, Inc. (NCI). In other rulemakings,

NCI works with confidential data provided by manufacturers and other organizations, in

preparing aggregated results for DOE’s analysis. These aggregated results do not divulge the

sensitive nature of the individual raw data, but enable other stakeholders to review and comment

on the aggregated dataset.

Alternatively, stakeholders may submit confidential data to DOE, indicating in writing

which data should remain confidential. In order to prevent public disclosure of the data due to

actions taken by a third party, stakeholders providing confidential information to DOE must

submit that data according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting

information that he or she believes to be confidential and exempt by law from public disclosure

should submit two copies. One copy of the document shall include all the information believed

to be confidential, and the other copy of the document shall have the information believed to be

16

EERE-2007-BT-STD-0016 COMMENT 01
confidential deleted. DOE will make its own determination about the confidential status of the

information and treat it according to its determination.15

DOE is creating a database of commonly­available products based on recent

manufacturer catalogues from fluorescent lamp ballast manufacturers, including both small and

large market participants. This database of ballasts will enable DOE to understand what is

available in the market and to better assess which ballasts should be considered in the expansion

of scope (see section 1.2). DOE will use the resulting knowledge about product availability to

evaluate how the market may respond to various standard levels (e.g., consumers substituting

fluorescent lamp ballasts that are not subject to regulation), and to gain insight on the

performance attributes of various commercially­available ballast technologies.

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.

In preparation for its review under Executive Order 12866, “Regulatory Planning and

Review,” DOE will be studying market failures or other specific problems that may warrant

agency action. DOE will assess the significance of any problem, to enable assessment of

whether a new regulation of fluorescent lamp ballasts is warranted.

DOE believes that there is a lack of consumer information and/or information processing

capability about energy efficiency opportunities in the lighting market. Fluorescent lighting

systems are composed of ballasts and lamps, and are complex systems with a multitude of

varying properties such as ballast factor, ballast efficacy factor, lamp type, wattage and so on.

These numerous variables impose high information costs which may prevent purchasers from

selecting the most cost­effective fluorescent lighting system.

DOE believes there is also a potential market failure surrounding the problem of

asymmetric information (one party to a transaction has more and better information than the

other) and/or high transactions costs (costs of gathering information and effecting exchanges of

goods and services). In the case of ballasts, in many instances the party responsible for the

ballast purchase may not be the one who pays the cost to operate it. Building owners and

developers may make purchase decisions about lighting fixtures which include ballasts and

lamps, but it may be the tenants who pay the utility bills. Although renters often have the

Factors that DOE considers when evaluating requests to treat submitted information as confidential include: (1) a

description of the items; (2) whether and why such items are customarily treated as confidential within the industry;

(3) whether the information is generally known by, or available from other public sources; (4) whether the

information has previously been made available to others without obligation concerning its confidentiality; (5) an

explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date

after which such information might lose its confidential character; and (7) why disclosure of the information would

be contrary to the public interest.

17

15

EERE-2007-BT-STD-0016 COMMENT 01
opportunity to purchase the replacement lamps, from a practical perspective, they may be

constrained in their choices by prior fixture and ballast selections. If there were no transactions

costs, it would be in the building developers’ and owners’ interests to install lighting fixtures

selected by the tenants. For example, a tenant who knowingly faces higher utility bills from lowefficiency lighting might expect to pay a lower rent, forcing the building owner to indirectly bear

the higher utility cost. However, information about lighting­related utility bills is not costless,

and it may not be in the interest of the renter to take the time to develop it, or, in the case of the

building owner who installs the lamp system, to convey that information to the renter.

To the extent that asymmetric information and/or high transactions costs are problems,

one would expect to find certain outcomes with respect to commercial and industrial lighting

energy efficiency. For example, other things equal, one would not expect to see higher rents for

office space with high­efficiency lighting systems. Conversely, if there were symmetric

information, one would expect higher energy efficiency lighting in commercial space where the

rent includes utilities, as compared to those where the tenant pays the utility bills separately.

DOE also believes that there may be certain “external” benefits resulting from the

improved efficiency of units that are not captured by the users of such equipment. These include

both environmental and energy security­related 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 weight that should be given to these

factors in DOE’s determination of the maximum efficiency level at which the total benefits are

likely to exceed the total costs resulting from a DOE standard.

DOE is seeking data that would enable it to conduct tests of market failure for products

under consideration for standard­setting. For example, given adequate data, there are ways to

test for the extent of market failure for commercial ballasts. One would expect the owners of

fluorescent lamp ballasts who also pay for their electricity consumption to purchase ballasts that

exhibit higher energy efficiency compared to lamps whose owners do not pay for the electricity

usage, all else being equal. To test for this form of market failure, DOE needs data on energy

efficiency of such units and whether the owner of the equipment is also the one who pays the

operating costs. DOE is also interested in other potential tests of market failure and data that

would enable such tests.

Item 7 DOE is seeking stakeholder comment and data on potential market failures

that could apply to fluorescent lamp ballasts.

3.2 Product Classes

When necessary, DOE divides covered product into classes by: (a) the type of energy

used; (b) the capacity of the product; or (c) any other performance­related feature that justifies

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE

then conducts its analysis and considers establishing or amending standards so as to provide

separate standard levels for each product class.

18

EERE-2007-BT-STD-0016 COMMENT 01
In amending EPCA, NAECA 1988 established eight product classes for fluorescent lamp

ballasts, as shown in Table 3.1.

Table 3.1 EPCA Product Classes established by NAECA 1988 for Fluorescent Lamp

Ballasts

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F40T12 lamp 120 40

277 40

Two F40T12 lamps 120 80

277 80

Two F96T12 lamps 120 150

277 150

Two F96T12HO lamps 120 220

277 220

In further amendments to EPCA, EPACT 2005 established an additional eight product

classes for fluorescent lamp ballasts, as shown in Table 3.2.

Table 3.2 EPCA Product Classes established by EPACT 2005 for Fluorescent Lamp

Ballasts

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F34T12 lamp 120 34

277 34

Two F34T12 lamps 120 68

277 68

Two F96T12/ES lamps 120 120

277 120

Two F96T12HO/ES lamps 120 190

277 190

As described above in section 1.2, DOE understands that in addition to the lamps and

lamp ballasts identified in Table 3.1 and Table 3.2, the fluorescent lamp ballast market today

includes ballasts that operate smaller diameter lamps such as T8 and T5 lamps. These

fluorescent lamp and ballast systems are gaining in market share, whereas T12 systems are

becoming less popular and consequently, losing market share. This market shift is expected to

accelerate in 2010, when the exclusion from the standard levels established by the 2000 Ballast

Rule and EPACT 2005 for replacement ballasts will expire. The standard levels (i.e., the BEF)

established by the 2000 Ballast Rule and EPACT 2005 for fluorescent lamp ballasts will

essentially eliminate magnetic ballasts from the marketplace by requiring a BEF that is not

attainable with magnetic ballast technology. Because magnetic ballasts comprise the large

majority of T12 ballast sales, DOE believes that when the standards prevent the sales of

magnetic T12 ballasts, there will be a further increase in the shipments of high­frequency ballasts

that operate T8 and T5 lamps.

19

EERE-2007-BT-STD-0016 COMMENT 01
Because of these market changes and because DOE is anticipating expanding its scope of

covered product for fluorescent lamp ballasts, DOE is considering amending the product classes

for fluorescent lamp ballasts. DOE may establish separate product classes for ballasts that

operate specific lamp lengths and lamp base types, as well as the number of lamps that the ballast

operates. For example, DOE is considering establishing one product class for all ballasts that

operate two 4­foot medium bipin lamps, irrespective of lamp diameter. To account for the

variance in BEF by lamp wattage in a product class like this, DOE could develop an equation

from which manufacturers could calculate the minimum BEF energy conservation standard

based on the fluorescent lamps’ wattage.

If appropriate, DOE could further divide product classes by the diameter of the lamp

operated by the ballast, the starting method of the ballast (e.g., rapid­start, instant­start,

programmed­start), and/or the total harmonic distortion of the ballast. If DOE chooses not to

establish an equation for the minimum BEF standard that takes into account fluorescent lamp

wattage, DOE may choose to subdivide product classes by the wattage of the lamp operated by

the ballast. Product classes may also be established for ballasts which have the ability to operate

multiple input voltages (i.e., universal or non­universal voltage systems) or the ability of a ballast

to operate multiple numbers of lamps (i.e., a 2­lamp ballast that can also operate three lamps

versus a 2­lamp ballast that can operate only two lamps). DOE seeks comment on all of the

possible approaches described above for product classes, as well as any other methods for

establishing product classes corresponding to the requirements of 42 U.S.C. 6295(q), discussed

above.

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).

3.3 Technology Assessment

The technology assessment centers on understanding how energy is used by the product,

and efficiency measures that would work to reduce energy consumption by the fluorescent

ballast. These measures that improve the energy efficiency of the product are called “technology

options,” and they are based on existing technologies, as well as prototype designs and concepts.

In consultation with stakeholders, DOE will develop a list of technology options for

consideration in this rulemaking. Following research into this list of technology options, DOE

will then consider each of them against four screening criteria: (1) technological feasibility; (2)

practicability to manufacture, install, and service; (3) adverse impacts on product utility or

availability; and (4) adverse impacts on health or safety (see section 4 for discussion on the four

screening criteria). Those technology options that pass the four screening criteria are called

“design options” and will be considered as appropriate ways of improving the efficiency of the

product in the engineering analysis and will assist DOE in determining the “max­tech” design.

DOE is studying technology options that could be employed to improve the BEF of the

fluorescent lamp ballasts covered in this rulemaking. Accordingly, DOE is reviewing

manufacturer catalogues, recent trade publications, technical journals and patent filings. To

20

EERE-2007-BT-STD-0016 COMMENT 01
gather more information, DOE also intends to consult with technical experts who have worked

on fluorescent lamp ballast designs and to conduct manufacturer interviews about these

technology options.

Presently, DOE is aware of a limited set of technology options that could improve the

efficiency of these ballasts. However, due to provisions in prior DOE standards, certain

technology options may only be applied to certain product classes. For example, existing

standards do not allow for the sale of magnetic ballasts that operate one F40T12 lamp. 65 FR

56740. Therefore, the cathode cutout technology option, which can only be used for magnetic

ballasts, cannot be incorporated into this product class. However, existing standards for ballasts

that operate two F96T12HO lamps allow for magnetic ballast operation, and, therefore, the

cathode cutout ballast is a technology option for this product class. 65 FR 56740.

A list of preliminary technology options that DOE intends to study for the ANOPR

includes the following:

• Cathode Cutout or Hybrid Ballast. The cathode cutout or hybrid ballast is a magnetic

ballast that uses an electronic circuit to remove electrode power after the discharge

has been initiated for rapid­start lamps. Cathode cutout ballasts start lamps in the

same way that magnetic rapid­start ballasts do. Operating lamps without electrode

power maintains the light output while reducing power by about two watts per lamp.

• The Electronic Ballast. For equivalent light output, electronic ballasts generally

consume less energy than magnetic ballasts. The electronic ballast converts the 60

hertz alternating current input power into a high­frequency voltage (20 kilohertz or

higher) to operate the lamp. At high frequency, the losses near the lamp electrode are

decreased. In addition, high­frequency operation utilizes smaller components,

thereby reducing ballast losses and making the ballast more efficient.

• Integrated Circuits. By substituting integrated circuits for discrete components,

electronic ballasts can save additional energy through a reduction in conductive

energy losses.

• Higher­Grade Components. Higher­grade components can further reduce energy

losses in ballasts. For example, using higher­grade magnetic materials in both highfrequency transformers and inductors can increase the efficiency of electronic

ballasts. Improved semiconductor materials used in integrated circuits can also

improve the efficiency of a fluorescent lamp ballast.

• Improved Circuit Design. Better circuit design may also improve the efficiency of an

electronic ballast. For instance, through better circuit design, a ballast’s power factor

can be increased. The higher a ballast’s power factor, the lower the current per watt

required to operate the ballast. These decreased currents reduce additional losses in

the power distribution system because of lower conductive losses (also called I2R

losses).

21

EERE-2007-BT-STD-0016 COMMENT 01
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 consider. In commenting on design options, please discuss their impacts

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

4 SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will

not consider in the rulemaking for fluorescent lamp ballasts. DOE will follow the process set

forth below to screen out technology design options.

As an initial matter, DOE will develop a list of technology options (developed through its

own research and in consultation with interested parties) for consideration in the engineering

analysis (see section 5). The identified candidate technology options or best available

technologies will encompass all those technologies that may be technologically feasible.

Thereafter, DOE will review each such technology option or best available technology in light of

the following four criteria, as provided in sections 4(a)(4) and 5(b) of the Process Rule16 and

tailored to the current rulemaking:

1. Technological feasibility. DOE will not further consider technologies that are not

incorporated in commercially­available products or in working prototypes.

2. Practicability to manufacture, install, and service. If DOE determines that mass

production of a technology in commercial products and reliable installation and servicing

of the technology could not be achieved on the scale necessary to serve the relevant

market by the time of the effective date of the standard, then it will not consider that

technology further.

3. Adverse impacts on product or equipment utility or availability. If DOE determines a

technology to have significant adverse impact on the utility of the product to significant

subgroups of consumers, or result in the unavailability of any covered product type with

performance characteristics (including reliability), features, size, capacities, and volumes

that are substantially the same as products generally available in the United States at the

time, it will not consider that technology further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have

significant adverse impacts on health or safety, it will not consider that technology

further.

DOE will fully document its reasons for eliminating any technology options during the

screening analysis, and will publish this documentation for stakeholder review and comment as

part of the ANOPR. Those technology options which are not screened out by the above four

16 10 CFR Part 430, Subpart C, Appendix A.

22

EERE-2007-BT-STD-0016 COMMENT 01
criteria are called “design options” and are considered in the development of cost­efficiency

curves in the engineering analysis.

Item 10 DOE welcomes comment on how the above four screening criteria might

apply to any additional technology design option(s) that a stakeholder recommends to

DOE.

5 ENGINEERING ANALYSIS

After conducting the screening analysis described above, DOE will perform an

engineering analysis based on the remaining design options that improve product efficiency. The

engineering analysis consists of estimating the energy consumption and cost of products at

various levels of increased efficiency. In this chapter, section 5.1 provides an overview of the

engineering analysis; section 5.2 discusses baseline models; section 5.3 describes DOE’s

proposed approach; section 5.4 addresses proprietary designs; and section 5.5 discusses

cumulative regulatory burdens that might affect the engineering analysis.

5.1 Engineering Analysis Overview

The purpose of the engineering analysis (discussed in this chapter) and the product price

determination (discussed in chapter 7) is to determine the relationship between fluorescent lamp

ballast efficiency and end­user price. This combination of the relationship between price and

efficiency serves as the basis for cost/benefit calculations to individual consumers in the LCC

analysis and to the nation in the NIA.

The engineering analysis will focus on selecting commercially­available ballasts that

exhibit design options that improve the BEF. The engineering analysis will also identify the

highest efficiency that is technologically feasible within each product class (i.e., the “max­tech”

model).

5.2 Baseline Models

Once DOE establishes product classes for fluorescent lamp ballasts, it will need to

identify baseline models which will serve as reference points against which it can measure

changes resulting from potential energy conservation standards. DOE will develop a separate

engineering analysis for each of the baseline models selected.

In order to manage the analytical burden and maintain the schedule for this rulemaking,

DOE may need to limit the number of product classes selected for analysis. The selected product

classes (called “representative product classes”) would be chosen to encompass those ballasts

which have the highest volume of market share or some other unique performance characteristic

that deserves special consideration. Once it has identified the representative product classes,

DOE would select baseline models from those representative product classes, which would be

23

EERE-2007-BT-STD-0016 COMMENT 01
analyzed in the rulemaking. The results of DOE’s analysis would then be scaled from the

representative product classes to the other product classes that were not analyzed.

Selection of the baseline model is a critical aspect of DOE’s analytical approach. The

baseline model should represent the characteristics of common or typical product sold in a given

product class. Typically, the baseline model would be a model that just meets current energy

conservation standard. If there are not standards that apply to a product, as is the case with the

additional fluorescent lamp ballasts that DOE intends to consider in this rulemaking, DOE will

select baseline models typical of the least­efficient ballast offered for sale in the market. This

baseline model will encompass ballast features and performance characteristics such as power

factor, total harmonic distortion, and ballast factor. DOE will not define all the detailed

characteristics of the potential baseline models until it receives comments from stakeholders and

can conduct further analysis.

In section 3.2, DOE discusses factors that may be used to establish product class

divisions for fluorescent lamp ballasts. DOE believes that it may be possible to extrapolate

analyses conducted on one product class to another (e.g., extrapolate minimum BEF from

ballasts that operate one lamp type to ballasts that operate a different lamp type). DOE is

inviting comment on the identification and selection of representative product classes and on a

representative ballast or ballasts that may serve as baseline models for those product classes.

The representative ballasts selected will be evaluated in both the engineering analysis and LCC

analysis (see section 8).

As stated above, once the representative analysis on the baseline models is complete,

DOE will then scale those findings to the other product classes which were not analyzed. For

this reason, the importance of carefully selecting representative product classes is critical, in

order to ensure that DOE is extending its findings to product classes appropriately. DOE is

inviting comment on fluorescent lamp ballast scaling relationships between ballast product

classes.

Item 11 DOE welcomes comment on representative product classes and selection of

baseline models from those representative product classes.

Item 12 DOE welcomes comment on the scaling of findings from representative

product classes to other product classes that DOE may not analyze.

5.3 Engineering Analysis Approach

In the engineering analysis, DOE will select a series of more­efficient ballasts (i.e.,

commercially­available ballasts) for each of the baseline models considered within each

representative product class. As stated above, these ballasts will be paired with prices

(developed in the product price determination) to develop the relationship between efficiency

and price. The relationship between price and efficiency serves as the basis for cost/benefit

calculations for individual consumers and the nation.

24

EERE-2007-BT-STD-0016 COMMENT 01
Selections of these ballasts will be made such that potential substitutions maintain light

output within 10 percent from the baseline system’s light output, and that the substitute lamp and

ballast system have performance characteristics similar to those of the baseline system. In

identifying more­efficient substitutes, DOE will utilize a database of commercially­available

ballasts. If ballasts that operate T8 and T12 lamps are in the same product class, DOE may

consider commercially­available ballasts under two different substitution scenarios: (1) higherefficiency ballasts which operate the same diameter lamp; and (2) higher­efficiency ballasts

which operate a smaller diameter lamp.

Having identified the more­efficacious substitutes for each of the baseline lamp­andballast systems, DOE will develop CSLs. CSLs are a set of efficiency levels considered in the

ANOPR that spans the range of BEFs from baseline products to the maximum technologically

feasible. Each CSL is analyzed in the LCC and NIA analysis. At the NOPR stage of the

rulemaking process, DOE will propose an energy conservation standard for public comment.

CSLs for fluorescent lamp ballasts are generally based on the consideration of several

factors, including: (1) design options associated with the specific ballasts being studied; (2) the

ability of ballasts that operate a given diameter lamp across multiple wattages to comply with the

standard level of a given product class;17 and (3) the maximum technologically­feasible level.

DOE welcomes comment from stakeholders on the selection of higher­efficiency ballasts.

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.

Item 14 DOE welcomes comment on how BEF varies with lamp wattage.

5.4 Proprietary Designs

DOE will consider in its engineering and economic analyses all design options that are

commercially available or present in a working prototype, including proprietary designs, that

meet the screening criteria discussed in section 4. However, DOE will consider a proprietary

design in the subsequent analyses only if it does not represent a unique path to a given efficiency

level. If the proprietary design is the only approach available to achieve a given efficiency level,

then DOE will reject the efficiency level (that can only be achieved by a proprietary design) from

further analysis, because the analytical results would appear to favor one manufacturer over

others. However, if a given energy efficiency level can be achieved by a number of design

approaches, including with a proprietary design, DOE may examine the given efficiency level

based on that design. Furthermore, DOE is sensitive to manufacturer concerns regarding

proprietary designs and will take appropriate steps to maintain the confidentiality of any

proprietary data provided by manufacturers. This information will provide input to the

competitive impacts assessment and other economic analyses.

17 The BEF of a given ballast will vary depending on the wattage of the lamp it is operating. In selecting CSLs,

DOE will consider whether ballasts that operate lamps at multiple wattages will meet a given CSL.

25

EERE-2007-BT-STD-0016 COMMENT 01
6

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?

5.5 Outside Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, DOE takes into consideration the effects of

regulatory burdens outside DOE’s statutory energy conservation standards rulemaking process

that can impact the manufacturers of the covered equipment. Some regulatory requirements can

also affect the energy efficiency or energy consumption of the fluorescent lamp ballasts covered

under this rulemaking. DOE will attempt to identify all such outside regulatory requirements

that could impact the engineering analysis. The consideration of these requirements is closely

related to the cumulative regulatory burden assessment that DOE will carry out as part of the

manufacturer impact analysis. Based on consideration of the comments received on the

engineering analysis documented in the ANOPR, DOE will make the necessary changes to its

analysis. It will reflect those changes in the documentation of the NOPR.

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 other engineering issues that could impact the

engineering analysis.

ENERGY USE AND END­USE LOAD CHARACTERIZATION

The purpose of the energy­use and end­use load characterization is to identify how

products and equipment are used by consumers, and thereby determine the energy savings

potential of energy efficiency improvements. For fluorescent lamp ballasts, DOE’s analysis will

focus on how end users install and operate these ballasts.

The energy­use and end­use load characterization, which is an input to the LCC and

national impact analyses, will capture and represent the typical energy consumption in the field.

This usage profile will enable DOE to conduct a calculation to determine the LCC and the

payback period (PBP) of more efficient ballast technologies relative to the baseline ballast.

For fluorescent lamp ballasts, energy consumption is derived by multiplying the system

power rating by the number of operating hours in a given year. The system power rating will be

developed in the engineering analysis, as it is a necessary parameter in determining the BEF.

DOE is considering using data from the U.S. Lighting Market Characterization: Volume I

26

EERE-2007-BT-STD-0016 COMMENT 01
(LMC),18 the Energy Information Administration’s (EIA) 2003 Commercial Building Energy

Consumption Survey (CBECS),19 and the 2002 Manufacturer Energy Consumption Survey

(MECS)20 to develop a distribution of operating hours for fluorescent lamps by sector and

Census Division. The EIA studies provide information on the distribution of buildings within

the U.S., by building type and census division. The LMC, which is based on thousands of

building audits and surveys, provides national­level data on annual operating hours by building

type and lamp type for all sectors. These operating hours are broken down by application for the

commercial and industrial sectors. DOE associates the LMC’s operating hours data by building

type with the EIA’s data by building type and Census Division to derive annual operating hours

by Census Division and large States. This allows DOE to correlate the electricity price

distribution, and sales tax distribution with the operating hours distribution by Census Division

and large States in the LCC spreadsheet.

Using this methodology will allow DOE to conduct a sensitivity analysis to determine

how high and low estimates of energy use might impact the economic feasibility of any amended

energy conservation standards. DOE will also be able to correlate regional electricity prices and

sales tax data to develop a more accurate distribution of the variability in consumer impacts in

the LCC analysis.

Item 18 DOE welcomes comment on use of the planned operating hours profile for

fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment on

whether the end-use operating profiles are different for the various types of fluorescent

lamp ballasts covered under this rulemaking, and if so, how.

7 PRODUCT PRICE DETERMINATION

As stated in section 5, the purpose of the engineering analysis and product price

determination together is to provide an analysis of the relationship between the end­user price

and efficiency for fluorescent lamp ballasts. Because DOE needs retail (consumer) prices for the

baseline efficiency levels under consideration for use in the LCC and PBP analysis and the

national impact analysis, DOE will base the product price determination for ballasts on markeddown manufacturer product price schedule lists, developing high­range, medium­range, and low18 U.S. Department of EnergyCOffice of Energy Efficiency and Renewable Energy, Final Report: U.S. Lighting

Market Characterization, Volume I: National Lighting Inventory and Energy Consumption Estimate (2002).

Available at: www.eere.energy.gov/buildings/info/documents/pdfs/lmc_vol1_final.pdf.

19 U.S. Department of EnergyCEnergy Information Agency, Commercial Building Energy Consumption Survey:

Micro­level data, file 2 Building Activities, Special Measures of Size, and Multi­building Facilities (2003).

Available at: http://www.eia.doe.gov/emeu/cbecs/public_use.html.

20 U.S. Department of EnergyCEnergy Information Agency, Manufacturing Energy Consumption Survey, Table 1.4:

Number of Establishments by First Use of Energy for All Purposes (Fuel and Nonfuel) (2002). Available at:

http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html.

27

EERE-2007-BT-STD-0016 COMMENT 01
range end­user retail prices. DOE develops these three different retail price scenarios to account

for the pricing variability encountered by consumers. For example, a consumer that is

purchasing large quantities of ballasts, such as a State or large corporation, will experience on

average lower prices than a consumer who is purchasing similar ballasts in smaller quantities.

Using three price points allows DOE to account for the economic impacts on a wide variety of

consumers. Once the end­user retail price set is prepared, DOE will compare those prices with

publicly­available prices in State procurement contracts, at large electrical supply distributors,

and other sources of publicly available end­user prices (e.g., Internet retailers).

To develop low­range prices for ballasts, DOE will calculate a discount off the list price

in the manufacturer product price schedule consistent with prices found in State procurement

contracts and other sources. DOE believes that using this discount schedule is appropriate for

the rulemaking analyses, as it reflects currently­available pricing and because it takes into

account commoditization of standards­compliant ballasts.

For medium­range prices, DOE will take a discount off the manufacturer product price

schedule list that is consistent with the distributor pricing it receives and that represents a typical

discount for commercial institutions on high­volume ballasts. In addition, DOE will add a

contractor mark­up so that the resulting price will encompass both a contractor and distributor

mark­up.

For the high­range prices, DOE will deduce discounts on commodity ballasts from the

manufacturer product price schedule list for small quantity purchasers by observing Internet

pricing and obtaining distributor quotes. These prices will also encompass both a contractor and

a distributor mark­up.

After determining the high­range, medium­range, and low­range prices, DOE will

develop an estimate of the sales tax to apply to the end­user product price. The sales tax

represents State and local sales taxes, and is a multiplicative factor that increases the end­user

product price. DOE will obtain information on State and local sales tax from the Sales Tax

Clearinghouse.21 This data will be compiled to calculate a national, population­weighted average

sales tax as well as a population­weighted average tax for each Census division.

Item 19 DOE welcomes comment on final end-user prices for high-range, mediumrange, 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.

The Sales Tax Clearinghouse, Inc. was established in August 1999 to facilitate the calculation of sales and use

taxes administered by the Nation's 7,000 taxing authorities at the State, county, and city levels. Information on the

Sales Tax Clearinghouse can be found at http://www.thestc.com/.

28

21

EERE-2007-BT-STD-0016 COMMENT 01
8 LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSIS

The effects of increased energy conservation standards on consumers include a change in

operating expense (usually decreased) and a change in purchase price (usually increased). The

LCC of a product is the cost a product incurs over its lifetime, taking into account both purchase

price and operating expenses. The PBP represents the time it takes to recover the additional

installed cost of the more­efficient device through annual operating cost savings. DOE analyzes

the net effect on consumers by calculating the LCC and PBP using the engineering performance

data (section 5), the energy­use and end­use load characterization data (section 6), and the

product price determination (section 7). Inputs to the LCC calculation include the installed cost

to the consumer (purchase price plus installation cost), operating expenses (energy expenses,

and, if applicable, repair costs and maintenance costs), the lifetime of the equipment or other

defined period of analysis, and a discount rate. Inputs to the payback period calculation include

the installed cost to the consumer and annual operating costs.

In addition to the LCC and PBP calculations, for certain products, DOE also conducts a

rebuttable presumption analysis. Under 42 U.S.C. 6295(o)(2)(B)(iii), the statute establishes a

rebuttable presumption that a standard is economically justified “[i]f the Secretary finds that the

additional cost to the consumer of purchasing a product complying with an energy conservation

standard level will be less than three times the value of the energy ... savings during the first

year that the consumer will receive as a result of the standard, as calculated under the applicable

test procedure....” For fluorescent lamp ballasts, because the DOE test procedure does not

include an input for operating hours, DOE plans to use the average annual operating hours of the

most common end­use application. While the rebuttable presumption calculation is helpful in

understanding that certain standard levels have short payback periods, often DOE has found that

some efficiency levels higher that the rebuttable presumption level are cost­justified. Therefore,

DOE does not make a determination of economic justification based on this calculation.

Economic justification is based on a weighing of the seven EPCA factors described in section

1.3.2 of this Framework Document. The LCC and PBP analysis described in the following

section reflects field conditions and is, therefore, a more accurate depiction of consumer impacts.

For the ANOPR, DOE will conduct the LCC and PBP analysis using typical values to

reflect conditions in the field for equipment retail price and life, energy costs, energy usage, and

discount rates. If DOE determines that there is significant variability in any of the above inputs,

it will conduct sensitivity analyses to determine how the LCC and PBP are impacted by high and

low estimates for each of the inputs. For any sensitivity analyses that it conducts, DOE will

account for correlations that may exist between inputs (e.g., energy usage may be correlated to

energy prices). The detailed impact calculation, which DOE will conduct after the ANOPR, may

include an assessment of impacts on subgroups of consumers, as described in section 11.

For the NOPR, DOE will carefully review all of the comments it receives on the ANOPR

LCC analysis, make any necessary revisions to the analysis, and evaluate additional parameters

not included in the ANOPR analysis, if necessary.

For fluorescent lamp ballasts, DOE will need to determine input values for several

variables. The following sections discuss the methodologies DOE plans to use to develop energy

prices, discount rates, maintenance/repair/installation costs, and ballast lifetimes. Some of the

29

EERE-2007-BT-STD-0016 COMMENT 01
major inputs DOE is anticipating it will develop for the fluorescent lamp ballast life­cycle cost

and PBP analysis are listed in the table below.

Table 8.1 Inputs to the Life­Cycle Cost and Payback Period Analysis

Input Description

Product Price The price of certain fluorescent lamp ballasts established in section 7, Product Price

Determination.

Sales tax Sales tax is applied to convert the product price to a final consumer price including sales

tax. Sales tax mark­ups will be developed in section 7, Product Price Determination.

Maintenance, repair, and

installation cost

This input represents the cost to customers of installing the ballast as well as the cost of

maintaining that ballast.

Annual operating hours The annual operating hours are the estimated hours that a fluorescent lamp ballast is in

use during the time span of one year. Operating hours are developed in section 6,

Energy-use and End-use Load Characterization.

Product energy

consumption rate

The product energy consumption is the site­energy usage rate associated with operating

the lamp system developed in section 6, Energy-use and End-use Load Characterization

Electricity prices Electricity prices used in the analysis are the average price per kilowatt­hour (i.e.,

$/kWh) paid by customers.

Electricity price trends Electricity price trends estimate the future cost of electricity.

Lifetime The total hours in operation after which the consumer retires the ballast or components

of a ballast system from service.

Discount rate The discount rate is the rate at which DOE discounts future expenditures to establish

their present value.

Analysis Period Analysis period is the time span over which DOE calculates the LCC.

8.1 Energy Prices

For consumers of fluorescent lamp ballasts, DOE will survey residential, commercial,

and industrial energy tariffs22 as a means for establishing marginal electricity prices. DOE will

also use data from CBECS23 conducted by EIA to estimate building energy use characteristics

that impact electricity prices. If the tariff survey and EIA data demonstrate a large variability in

electricity prices, DOE will conduct a sensitivity analysis to determine how high and low

electricity price estimates might impact the economic feasibility of any amended energy

conservation standards. DOE will use projections of national average energy prices for

residential, commercial, and industrial consumers—principally from EIA’s Annual Energy

Outlook (AEO) from the most recent year available—as input for future energy prices in its LCC

analysis.

Item 21 DOE welcomes input on the electricity prices used in this analysis.

22 “Energy tariffs” are the rules for calculating energy bills. DOE contractors maintain a database of hundreds of

tariffs that can be used to calculate incremental energy bill impacts from energy savings. See: http://tariffs.lbl.gov/ 23 See: http://www.eia.doe.gov/emeu/cbecs/.

30

EERE-2007-BT-STD-0016 COMMENT 01
8.2 Life­Cycle Cost Discount Rates

The calculation of consumer LCC requires the use of an appropriate discount rate. DOE

uses the discount rate to determine the present value of lifetime operating expenses. For

consumers of fluorescent lamp ballasts, DOE will derive the discount rates for commercial and

industrial consumers by estimating the cost of capital of companies that purchase commercial

equipment. The cost of capital is commonly used 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 weighted­average cost of equity

and debt financing. This corporate finance approach is referred to as the “weighted­average cost

of capital.” However, because the set of commercial or industrial companies purchasing

fluorescent lamp ballasts may differ from those who purchase another product such as

distribution transformers, each rulemaking requires development of its own targeted discount

rates.

DOE will publish the discount rates and associated documentation on the derivation of

these discount rates in the ANOPR. It will invite stakeholders to comment specifically on the

issue of consumer discount rates during the ANOPR comment period. Based upon consideration

of the comments received on the LCC and PBP analysis documented for the ANOPR, DOE will

make the necessary changes to the analysis and will reflect those changes in the documentation

of the NOPR.

Item 22 DOE welcomes input on the planned approaches for estimating discount rates

for consumers of fluorescent lamp ballasts covered under this rulemaking.

8.3 Installation, Maintenance, and Repair Costs

Typically, DOE takes into consideration any expected changes to installation,

maintenance, and repair costs for covered equipment in a rulemaking. Often, small incremental

changes in equipment efficiency would incur little or no change in installation, maintenance, and

repair costs over baseline equipment. For equipment with significant energy­efficiency

improvements over the baseline, there may be increased installation, maintenance, and repair

costs, because such equipment is more likely to incorporate technologies that are not widely

available or utilized.

For fluorescent lamp ballasts, DOE intends to handle each of these costs in its LCC

analysis as follows:

• Installation costs ­­ DOE does not expect that installation costs for fluorescent

lamp ballasts will change with more energy­efficient ballast designs, as new

regulations are not expected to change either the ballast lifetime or the labor costs

for installing a standards­compliant ballast.

• Maintenance costs – DOE expects that maintenance costs for fluorescent lamp

ballasts could change with more energy­efficient ballast designs. Due to the fact

31

EERE-2007-BT-STD-0016 COMMENT 01
that maintenance costs include both the installation labor and equipment cost of

replacement lamps that operate on any given ballast, it is possible that

maintenance costs may change. For example, if a certain standard level included

a shift in ballast technology from T12 to T8 ballasts, the equipment cost of the

replacement T8 lamps may be different from the T12 lamps. That said, DOE does

not believe that the labor costs of installing a fluorescent lamp will change with

more efficient ballasts. Furthermore, DOE understands that more energy­efficient

ballasts would not significantly impact the useful lifetime (i.e., shorter or longer)

of the lamps operated by those ballasts.

• Repair costs ­­ DOE does not believe that fluorescent lamp ballasts are subject to

being “repaired,” as ballasts are generally simply replaced at the end of their

useful life. For this reason, repair costs will not be part of the LCC analysis.

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.

8.4 Fluorescent Lamp Ballast Lifetimes

DOE will use information from manufacturer product catalogues, various literature

sources such as technical reports and conference proceedings, and the 2000 Ballast Rule, as well

as input from manufacturers and other stakeholders, to establish fluorescent lamp ballast

lifetimes for use in the LCC and subsequent analyses.

Based on consideration of the comments received for the ANOPR, DOE will make

necessary changes to the analysis. These changes will be reflected in the documentation of the

NOPR.

Item 24 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for

the ballasts covered in this rulemaking.

9 SHIPMENTS ANALYSIS

DOE develops shipment forecasts of products in order to calculate the national impacts of

standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to

develop shipments forecasts based on an analysis of key market drivers for the fluorescent lamp

ballasts.

32

EERE-2007-BT-STD-0016 COMMENT 01
9.1 Base Case Forecast

To evaluate the various impacts of standards, DOE develops a base case shipments

forecast against which to compare standards­case shipments forecasts at higher efficiency levels

(based on the CSLs). DOE will design the base case forecast to depict what would be anticipated

to happen to energy consumption and energy costs over time if energy conservation standards for

the ballasts covered under this rulemaking are not adopted. In determining the base case

forecast, DOE will consider historical shipments, the mix of ballast efficiencies currently sold in

the absence of regulation, and how that mix might change over time. For these purposes, DOE

needs data on historical equipment shipments and the market shares of the different efficiency

levels offered in each product class.

DOE seeks data on historical shipments of fluorescent lamp ballasts, possibly from

manufacturers or industry associations. Alternatively, DOE could base its shipments analysis on

an extrapolation the shipments analysis from the 2000 Ballast Rulemaking, selected national

market reports, and/or the extrapolation of historical sales data from the U.S. Census Bureau.

The Census Bureau publishes limited information on the quantity and dollar­value of fluorescent

lamp ballast shipments; however, those shipments are not broken down by ballast type or

product class. DOE is also interested in stakeholder comment on efficiency trends in the base

case (i.e., the trends of consumers purchasing ballasts that use less energy).that would enable

DOE to represent these market trends in its analysis.

DOE hopes to develop shipment data within each fluorescent lamp ballast product class,

as well as to understand the breakdown of efficiency levels within each product class (i.e., data

on the distribution of equipment shipments by BEF). However, DOE recognizes that this

information may be difficult to collect, so DOE may ultimately need to consider other

approaches, such as interviewing experts who work in the fluorescent lamp ballast market.

Item 25 DOE welcomes recommendations on 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.

9.2 Accounting Methodology

DOE plans to determine annual shipments in the base case by accounting for new ballast

installation, ballast replacements due to failure, and ballast retrofits. Each of these three impacts

on the accounting methodology is discussed below:

• New Construction means the new ballasts that are installed each year due to

equipment growth in a particular sector. DOE plans to determine a value for this

input by using the National Energy Modeling System (NEMS) growth projections for

the commercial and industrial equipment sectors.

• Replacements refers to the new ballasts that are installed each year to replace ballasts

33

EERE-2007-BT-STD-0016 COMMENT 01
that have failed. DOE plans to base this calculation on equipment sales and

retirement rates.

• Retrofits means the ballasts replacing existing ballasts during renovation and/or repair

of equipment. This retrofit replacement may occur before the original ballast has

failed.

DOE intends to use an accounting model method to prepare shipment scenarios for the

base case and the standards level cases. The model will keep track of the aging and

replacement of fluorescent lamp ballasts given a projection of future ballast sales growth.

Item 26 DOE welcomes comment on the accounting methodology described above for

each of the fluorescent lamp ballasts covered in this rulemaking.

9.3 Standards Impacts on Ballast Shipments

For each ballast type, DOE will develop a set of shipment forecasts for the covered

ballasts for each set of efficiency standards analyzed. It will use these standards­case forecasts to

evaluate the impacts of standards on ballast shipments. DOE derives standards­case forecasts

using the same data sets as it used for the base­case forecasts. However, because the standardscase forecasts take into account the increase in purchase price and the decrease in operating costs

caused by standards, forecasted shipments typically deviate from the base case. The magnitude

of the difference between the standards­case and base­case shipment forecasts depends on the

estimated purchase­price increase, as well as the operating­cost savings from the standard.

Because the purchase price tends to have a larger impact than operating cost on equipment

purchase decisions, standards­case forecasts typically do show an elasticity of demand,

manifested as a drop in shipments relative to the base case.

Market­pull programs, such as consumer rebate programs that encourage the purchase of

more efficacious fluorescent lamp ballasts and manufacturer tax credits that encourage the

production of more efficacious fluorescent lamp ballasts, also affect standards­case shipment

forecasts. To the extent that such programs exist, DOE will consider their impact on the forecast

of both standards­case and base­case shipments.

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 currently exist to promote the adoption of

more-efficacious ballasts.

10 NATIONAL IMPACT ANALYSIS

The national impact analysis discusses DOE’s assessment of the aggregate impacts of

potential efficiency standards at the national level. Measures of impact that DOE will report

include future NES from CSLs (i.e., the cumulative incremental energy savings from a new or

increased energy conservation standard relative to a base case of no change in the energy

34

EERE-2007-BT-STD-0016 COMMENT 01
conservation national standard over a specified forecast period) and the NPV from CSLs (i.e., the

cumulative incremental LCC from a new or increased energy conservation state relative to the

base case over a specified forecast period).

10.1 Inputs to Forecasts

Analyzing impacts of Federal energy conservation standards for fluorescent lamp ballasts

requires a comparison of projected energy consumption in the United States with, and without,

new energy conservation standards. The forecasts contain projections of unit energy

consumption of new ballasts, annual equipment shipments, the price of purchased equipment,

and base­case and standards­case efficiencies. The derivations of the base­case shipments

forecasts are discussed in section 9. Approaches to determine retail prices for equipment are

described in section 7, while approaches to determine unit energy consumption are described in

section 6.

The rebound effect, another input to the NIA, is discussed in this section. Often,

consumers that encounter lower operating costs associated with a more­energy­efficient product

will use that product more often than a less­efficient product. The rebound effect analysis

accounts for this increase in consumer use. Some of the major inputs DOE is anticipating it will

develop for the national impact analysis are described in the table below.

35

EERE-2007-BT-STD-0016 COMMENT 01
Table 10.1 Inputs to the National Impact Analysis

Input Data Description of Data Sources

Shipments Annual shipments developed in section 9.

Stock of Fluorescent Lamp Ballasts This stock is calculated from the service life of ballasts developed in

section 8 and annual shipments from ballasts developed in section 9.

Effective Date of Standard 2014

Analysis Period 2014 to 2043 (30 years)

Base­Case Forecasted Efficiency Distribution of base­case shipments by efficiency level over time

developed in section 9.

Standards­Case Forecasted Efficiency Distribution of shipments by efficiency level for each standards case

over time.

Unit Energy Consumption (kWh/yr) This is the average energy consumption of a fluorescent lamp ballast

established in the energy­use and end­use load characterization, section

6

Total Installed Cost Established in the Product Price Determination, section 7 and the LCC

analysis, section 8.

Electricity Price Forecast Established in the Life Cycle Cost Analysis, section 8.

Electricity Site­to­Source Conversion Conversion varies yearly and is generated by EIA Annual Energy

Outlook forecasts of electricity generation and electricity related losses.

Heating, Ventilating, and Air­ Accounts for the additional energy saved through HVAC interactions.

Conditioning (HVAC) Interaction The methodology will be similar to that used in the 2000 Ballast Rule.

Savings

Discount Rate The discount rate is the rate at which DOE discounts future expenditures

to establish their present value. 3 and 7 percent discount rates will be

used.

Present Year Future costs and savings will be discounted to the year 2009.

Rebound Effect The difference between the projected and actual savings due to

increased efficiency.

Item 28 DOE welcomes comment on the data sources it anticipates using to develop

inputs for the national impact analysis.

10.2 Calculation of National Energy Savings

DOE intends to calculate national energy consumption for each year beginning with the

expected effective date of the standards. It will calculate national electricity consumption for the

base case and each standard level analyzed. DOE plans to perform this calculation through the

use of a spreadsheet model that effectively multiplies annual shipment forecasts by unit energy

savings, thereby accounting for the stock of equipment affected by standards.

In response to comments by stakeholders who asked for a simple, transparent model,

DOE developed NES spreadsheet models for its standards rulemakings starting in 1996, to

project energy savings and to demonstrate how the growth in efficiency can be accounted for

36

EERE-2007-BT-STD-0016 COMMENT 01
over time.24 Although these models are specific to each product, their general framework is

applicable to the entire fluorescent lamp ballast market. It is DOE’s expectation that the NES

spreadsheet model will provide a stand­alone forecast of national energy savings and NPV for

fluorescent lamp ballasts. Based on consideration of comments DOE may receive on the

ANOPR, DOE will make any necessary changes to the analysis. It will reflect those changes in

the documentation for the NOPR.

Item 29 DOE welcomes comment on the NES spreadsheet models it plans to use for

estimating national impacts of energy conservation standards for fluorescent lamp

ballasts.

10.3 Net Present Value

DOE calculates the national NPV of energy conservation standards in conjunction with

the NES. It calculates annual energy expenditures from annual energy consumption by

incorporating forecasted energy prices, using the shipment and average energy efficiency

forecasts described in section 9. DOE calculates annual equipment expenditures by multiplying

the price per unit times the forecasted shipments. The difference between a base­case and a

standards­case scenario gives the national energy bill savings and increased equipment

expenditure in dollars, and for the fluorescent lamp ballasts rulemaking, this differential will

likely result in an NES offset against increased expenditures on ballasts. The difference each

year between energy bill savings and increased equipment expenditures is the net savings (if

positive) or net costs (if negative). DOE will discount these annual values to the present time

and sum them to provide a net present value. Since the national cost of capital may differ from

the consumer cost of capital, the discount rate used in the NIA can be different from that used in

the LCC. According to U.S. Office of Management and Budget (OMB) guidance, DOE will

conduct two NPV calculations, one using a real discount rate of three percent and another using a

real discount rate of seven percent (OMB, Circular A­4: Regulatory Analysis, September 17,

2003). The seven­percent and three­percent real discount rates are considered to be

representative of the present value of costs and benefits associated with projects in the

marketplace facing an average degree of risk. Specifically, the seven­percent real value is an

estimate of the average before­tax rate of return to private capital in the U.S. economy. The

three­percent real value represents the “societal rate of time preference,” which is the rate at

which society discounts future consumption flows to their present value. Based on consideration

of the comments received on the ANOPR, DOE will make any necessary changes to the analysis

and the CSLs.

Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at

www.eere.energy.gov/buildings/appliance_standards/.

37

24

EERE-2007-BT-STD-0016 COMMENT 01
11 LIFE­CYCLE COST SUBGROUP ANALYSIS

At the NOPR stage of this rulemaking, DOE will conduct a life­cycle cost subgroup

analysis. In this analysis, DOE analyzes consumer impacts by dividing consumers into

subgroups and accounting for variations in key inputs to the LCC analysis. A consumer

subgroup comprises a subset of the population that is likely, for one reason or another, to be

affected disproportionately by new or revised energy conservation standards (e.g., small

businesses, ethnic minorities, low income or senior consumers). The purpose of a subgroup

analysis is to determine the extent of any such disproportional impact. DOE will work with

stakeholders early in the rulemaking process to identify any subgroups for this consideration.

However, as noted above, DOE will not analyze the consumer subgroups until the NOPR stage

of the analysis.

In comparing potential impacts on the different consumer subgroups, DOE will evaluate

variations in regional electricity prices, variations in usage profiles, and variations in installation

costs that might affect the NPV of an energy conservation standard to certain consumer

subgroups. To the extent possible, DOE may obtain estimates of the variability in each input

factor and consider this variability in its calculation of consumer impacts. It will discuss with

stakeholders the variability in each input factor and likely sources of information.

Item 30 DOE welcomes comment on what, if any, consumer subgroups are

appropriate in considering standards for fluorescent lamp ballasts.

12 MANUFACTURER IMPACT ANALYSIS

DOE announced changes to the manufacturer impact analysis (MIA) approach in a report

issued to Congress on January 31, 2006 (as required by section 141 of EPACT 2005). This

report, titled “Energy Conservation Standards Activities” (Standards Activities), is available on

the DOE website at:

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

Previously, DOE did not report any MIA results during the ANOPR phase; however,

under this new approach, DOE will collect, evaluate, and report preliminary information and data

on manufacturer impacts in the ANOPR. (See Standards Activities, page 48.) Such preliminary

information includes the anticipated conversion capital expenditures by efficiency level and the

corresponding, anticipated impacts on employment. DOE will invite further input on these

issues during its ANOPR manufacturer interviews.

DOE intends the MIA to provide an assessment of the potential impacts of energy

conservation standards on manufacturers of fluorescent lamp ballasts. DOE intends to conduct a

separate manufacturer impact analysis for each of the ballast types covered under this

rulemaking. In addition to financial impacts, a wide range of quantitative and qualitative effects

38

EERE-2007-BT-STD-0016 COMMENT 01
may occur following adoption of a standard that may require changes to the manufacturing

practices for these ballasts. DOE will identify these effects through interviews with

manufacturers and other experts.

For the NOPR, DOE will supplement the results of the preliminary MIA conducted as

part of the ANOPR with more detailed analyses, described in sections 12.1 through 12.5.

Specifically, DOE will carry out an industry­wide cash flow analysis using the Government

Regulatory Impact Model (GRIM), identify and analyze subgroups of manufacturers whose

business varies significantly from the industry as a whole, perform a competitive impacts

assessment, and review the cumulative regulatory burden for the industry.

12.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described earlier provide important information that DOE will use

as inputs for the manufacturer impact analysis. Such information includes financial parameters

developed in the market assessment (section 3.1), retail price forecasts (section 7), and shipments

forecasts (section 9). DOE will supplement this information with information gathered during

manufacturer interviews.

DOE will conduct detailed interviews with manufacturers to gain insight into the range of

potential impacts from standards. The interview process plays a key role in the manufacturer

impact analysis, because it provides an opportunity for directly­affected parties to express their

views on important issues. During the interviews, DOE will solicit information on the possible

impacts on manufacturing costs, equipment prices, sales, direct employment, capital assets, and

industry competitiveness. Both qualitative and quantitative information are valuable in terms of

this analysis. DOE will schedule interviews well in advance to provide every opportunity for

key individuals to be available to participate. In addition, DOE will provide manufacturers with

the questionnaires before the interviews in order to facilitate the gathering of the appropriate

information. Although a written response to the questionnaire is acceptable, DOE prefers an

interactive interview process, because it helps to clarify responses and provides the opportunity

to identify additional issues.

DOE will ask interview participants to identify all confidential information provided in

writing or orally, and DOE will determine whether the information submitted is entitled to

confidential treatment. It will consider the information gathered, as appropriate, in the energy

conservation standard decision­making process. DOE will also ask participants to identify any

information that they wish to have included in the public record, but that they do not want to

have associated with their interview (thereby identifying that particular manufacturer); DOE will

incorporate this information into the public record, but will report it without attribution.

DOE will collate the interview results and prepare a summary of the major issues and

outcomes. This summary will become part of the technical support document for this

rulemaking.

39

EERE-2007-BT-STD-0016 COMMENT 01
12.2 Industry Cash Flow Analysis

The industry cash flow analysis will rely primarily on the GRIM. DOE uses the GRIM to

analyze the financial impacts of new or more stringent energy conservation standards on the

industry that produces the equipment covered by the standard.

The GRIM analysis uses a number of factors—annual expected revenues; manufacturer

costs such as costs of goods sold; selling, general, and administrative costs; taxes; and capital

expenditures (both ordinary capital expenditures and those related to standards)—to determine

annual cash flows associated with a new standard, beginning from the announcement of the

standard and continuing for several years after its implementation. DOE compares the results

against base­case projections that involve no new standards. The financial impact of new

standards is the difference between the two sets of discounted annual cash flows. Other

performance metrics, such as return on invested capital, are also available from the GRIM.

DOE will gather the inputs needed for the GRIM from two primary sources: (1) the

analyses conducted to this point; and (2) interviews with manufacturers and other stakeholders.

Information gathered from previous analyses will include financial parameters, manufacturing

costs, price forecasts, and shipments forecasts. Interviews with manufacturers and other

stakeholders will be essential in supplementing this information.

12.3 Manufacturer Subgroup Analysis

It is possible that the use of average industry cost values may not adequately assess

differential impacts among subgroups of ballast manufacturers. DOE recognizes that smaller

manufacturers, niche players, and manufacturers exhibiting a cost structure that differs

significantly from the industry average may be impacted differently by the imposition of

standards. Ideally, DOE would consider the impact on every firm individually. In highly

concentrated industries, this may be possible. In industries having numerous participants,

however, DOE uses the results of the market and technology assessment to group manufacturers

into subgroups, as appropriate. For ballasts, DOE does not intend to assess the impacts on every

manufacturer individually, and, therefore, is interested in stakeholder feedback about potential

subgroups.

The detailed manufacturer subgroup impact analysis will entail calculating cash flows

separately for each defined class of manufacturer.

Item 31 If appropriate, what are potential subgroups of fluorescent lamp ballast

manufacturers that DOE should consider in a manufacturer subgroup analysis?

12.4 Competitive Impacts Analysis

EPCA directs DOE to consider any lessening of competition that is likely to result from

an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney

40

EERE-2007-BT-STD-0016 COMMENT 01
General to determine in writing the impacts, if any, of any lessening of competition. (42 U.S.C.

6295(o)(2)(B)(ii))

DOE will make a determined effort to gather firm­specific financial information and

impacts, and it will then report the aggregated impact of the standard on manufacturers. The

competitive impacts analysis will focus on assessing the impacts to smaller, yet significant,

manufacturers. DOE will base the assessment on manufacturing cost data and on information

collected from interviews with manufacturers. The manufacturer interviews will focus on

gathering information that would help in assessing asymmetrical cost increases to some

manufacturers, increased proportion of fixed costs potentially increasing business risks, and

potential barriers to market entry (e.g., proprietary technologies). DOE will provide the Attorney

General with a copy of the NOPR for consideration in his evaluation of the impact of standards

on the lessening of competition.

12.5 Cumulative Regulatory Burden

DOE is aware that other regulations may apply to equipment covered under this

rulemaking, as well as to other equipment produced by the same manufacturers of equipment

covered under this rulemaking. Multiple regulations may result in a significant, cumulative

regulatory burden on these manufacturers. DOE will analyze and consider the impact on ballast

manufacturers of multiple, equipment­specific regulatory actions.

Regulations that could affect the industry impacted by this rulemaking include:

• Energy conservation standards for fluorescent lamp ballasts established by DOE on

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

• New EPCA standards, prescribed in EPACT 2005, for medium­base compact

fluorescent lamps and mercury vapor lamp ballasts;

• New EPCA standards for incandescent lamps and metal halide lamp fixtures

prescribed in EISA 2007 (see Appendix D);

• Existing and/or proposed State standards for high intensity discharge ballasts, and/or

under­cabinet luminaires;

• State building energy codes lighting requirements (e.g., American Society of Heating,

Refrigerating, and Air­Conditioning Engineers Standard 90.1); and

• International standards, including Canada’s regulation of fluorescent lamp ballasts.

Item 32 DOE welcomes comment on what other regulations or pending regulations it

should consider in its examination of cumulative regulatory burden.

13 UTILITY IMPACT ANALYSIS

Like the life­cycle cost subgroup analysis, the utility impact analysis is completed during

the NOPR stage of this rulemaking. In the utility impact analysis, DOE estimates the effects of

energy conservation standards for fluorescent lamp ballasts on electricity sales for the electric

utility industry. In order to quantify this impact, DOE plans to use a variant of EIA’s NEMS,

41

EERE-2007-BT-STD-0016 COMMENT 01
called NEMS­BT (BT refers to DOE’s Office of Building Technologies Program).25 NEMS is a

large, multi­sectoral partial­equilibrium model of the U.S. energy sector, used primarily for the

purpose of preparing the AEO. NEMS­BT is a customized version of NEMS which incorporates

revisions to the NEMS model that are appropriate for the rulemaking analyses conducted by

DOE’s Office of Building Technologies. NEMS­BT provides the reference case forecast for the

United States through 2030 and is available in the public domain.

The utility impact analysis is a comparison between the NEMS­BT model results for the

base case and standards cases. Outputs of the utility impact analysis usually parallel results that

appear in the latest AEO, with some additions. Typical outputs include forecasts of electricity

generation, sales, price, and avoided capacity. DOE plans to conduct the utility impact analysis

as a scenario departing from the latest AEO reference case. In other words, DOE will model the

energy savings impacts from energy conservation standards for fluorescent lamp ballasts using

NEMS­BT to generate forecasts that deviate from the AEO reference case.26

Item 33 DOE welcomes input from stakeholders on its plans to use NEMS-BT to

conduct the utility impact analysis.

14 EMPLOYMENT IMPACT ANALYSIS

DOE includes employment impacts among the factors considered in selecting a proposed

efficiency standard, and it also considers the impact of CSLs on both direct and indirect

employment. There is a general presumption against any CSL that would directly cause plant

closures or significant loss of domestic employment, unless specifically identified expected

benefits of the standard would outweigh such adverse effects. (See the Process Rule, 10 CFR

Part 430, Subpart C, Appendix A, sections 4(d)(7)(ii) and (vi), and 5(e)(3)(i)(B).)

During the NOPR stage of the fluorescent lamp ballast rulemaking, DOE will estimate

the impacts of standards on employment for equipment manufacturers, relevant service

industries, energy suppliers, and the economy in general. Its analysis covers both direct and

indirect employment impacts. Direct employment impacts would result if standards led to a

change in the number of employees at manufacturing plants and related supply and service firms.

Direct impact estimates are covered in the manufacturer impact analysis.

25 For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000,

DOE/EIA­0581(March 2000). EIA approves use of the name NEMS to describe only an official version of the

model without any modification to code or data. Because this analysis entails some minor code modifications and

the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model by

the name NEMS­BT (“BT” refers to DOE’s Building Technologies Program, under whose aegis this work has been

performed).

26 Several NEMS­BT models from previous rulemakings can be found on the DOE’s website at

www.eere.energy.gov/buildings/appliance_standards/.

42

EERE-2007-BT-STD-0016 COMMENT 01
Indirect employment impacts are impacts on the national economy other than in the

manufacturing sector being regulated. Indirect impacts may result both from expenditures

shifting among goods (the substitution effect) and changes in income that lead to a change in

overall expenditure levels (the income effect). DOE defines indirect employment impacts from

standards as net jobs eliminated or created in the general economy as a result of increased

spending driven by the increased equipment prices and reduced spending on energy.

DOE will investigate the combined direct and indirect employment impacts in the

employment impact analysis using the Pacific Northwest National Laboratory (PNNL)’s “Impact

of Sector Energy Technologies” (ImSET) model. PNNL developed ImSET for DOE’s Office of

Planning, Budget, and Analysis. The model estimates the employment and income effects of

energy­saving technologies in buildings, industry, and transportation. In comparison with simple

economic multiplier approaches, ImSET allows for more complete and automated analysis of the

economic impacts of energy efficiency investments. Although DOE intends to use ImSET for its

analysis of employment impacts, it welcomes input on other tools and factors it might consider.

Item 34 DOE welcomes feedback on its planned approach for assessing national

employment impacts, both direct and indirect.

15 ENVIRONMENTAL ASSESSMENT

During the NOPR stage of this rulemaking, DOE will conduct an environmental

assessment. The intent of the environmental assessment is to provide emissions results estimates,

and to fulfill requirements to properly quantify and consider the environmental effects of all new

Federal rules. In this rulemaking, the environmental assessment will consider potential

environmental impacts from three pollutants (sulfur dioxide (SO2), nitrous oxide (NOX), and

mercury (Hg)), and from carbon dioxide (CO2) emissions.

The primary environmental effects of energy conservation standards for fluorescent lamp

ballasts are likely to be reduced emissions resulting from reduced electricity consumption. At

the NOPR rulemaking stage, for each of the trial standard levels, DOE will calculate total

undiscounted and discounted power plant emissions using NEMS­BT, and will use other

methods to calculate site emissions. The environmental assessment performed in this

rulemaking will be conducted as an incremental policy impact (i.e., a standard for the product

under evaluation) of the most current AEO forecast, applying the same basic set of assumptions

used in AEO. Also, forecasts conducted with NEMS­BT consider the supply­side and demandside effects on the electric utility industry. Thus, DOE’s analysis will account for any factors

affecting the type of electricity generation and, in turn, the type and amount of airborne

emissions generated by the utility industry.

The NEMS­BT model tracks CO2 emissions with a specialized carbon emissions

estimation subroutine, producing reasonably accurate results due to the broad coverage of all

43

EERE-2007-BT-STD-0016 COMMENT 01
sectors and inclusion of interactive effects. Past experience with carbon results from NEMS

suggests that emissions estimates are somewhat lower than emissions based on simple average

factors. One of the reasons for this divergence is that NEMS tends to predict that conservation

displaces new generating capacity in future years, and new generating capacity is expected to be

more efficient than most existing capacity. On the whole, NEMS­BT provides carbon emissions

results of reasonable accuracy, at a level consistent with other Federal published results. In

addition to providing estimates of the quantitative impacts of ballast efficiency standards on

carbon emissions, DOE may consider the use of monetary values to represent the potential value

of such emission reductions. DOE invites comments on how to estimate such monetary values

or on any widely accepted values that might be used in DOE’s analysis.

NEMS­BT also reports SO2, NOX, and Hg, which DOE has reported in past analyses.

The Clean Air Act Amendments of 1990 set an SO2 emissions cap on all power generation. The

attainment of this target, however, is flexible among generators through the use of emissions

allowances and tradable permits. Although NEMS includes a module for SO2 allowance trading

and delivers a forecast of SO2 allowance prices, accurate simulation of SO2 trading implies that

the effect of efficiency standards on physical emissions will be zero because emissions will

always be at or near the ceiling. However, there is an SO2 benefit from energy conservation, in

the form of a lower SO2 allowance price. But since the impact of any one standard on the

allowance price is likely small and highly uncertain, DOE does not plan to monetize the SO2

benefit.

NEMS­BT also has an algorithm for estimating NOx emissions from power generation.

The impact of these emissions, however, will be affected by the Clean Air Interstate Rule

(CAIR), which the Environmental Protection Agency (EPA) issued on March 10, 2005. CAIR

will permanently cap emissions of NOx in 28 eastern states and the District of Columbia. 70 FR

25162 (May 12, 2005). As with SO2 emissions, a cap on NOx emissions means that equipment

efficiency standards may have little or no physical effect on these emissions. When NOx

emissions are subject to emissions caps, DOE’s emissions reduction estimate corresponds to

incremental changes in the prices of emissions allowances in cap­and­trade emissions markets

rather than physical emissions reductions. Therefore, while the emissions cap may mean that

physical emissions reductions will not result from standards, standards could produce an

environmental­related economic benefit in the form of lower prices for emissions allowance

credits. However, as with SO2 allowance prices, DOE does not plan to monetize this benefit

because the impact on the NOx allowance price from any single energy conservation standard is

likely small and highly uncertain.

With regard to mercury emissions, NEMS­BT has an algorithm for estimating these

emissions from power generation. However, the impact on mercury emissions will be affected

by the Clean Air Mercury Rule (CAMR), which the EPA published on May 18, 2005. 70 FR

28606. As of 2010, CAMR will permanently cap emissions of mercury for new and existing

coal­fired plants in all States. As with SO2 and NOx emissions, a cap on mercury emissions

means that appliance efficiency standards may have no physical effect on these emissions.

When mercury emissions are subject to emissions caps, DOE’s emissions reduction estimate

corresponds to incremental changes in the prices of emissions allowances in cap­and­trade

emissions markets rather than physical emissions reductions. Therefore, while the emissions cap

44

EERE-2007-BT-STD-0016 COMMENT 01
may mean that physical emissions reductions will not result from standards, standards could

produce an economic benefit in the form of lower prices for emissions allowance credits.

However, as with SO2 and NOx allowance prices, DOE does not plan to monetize this benefit

because the impact on the mercury allowance price from any single energy conservation standard

is likely small and highly uncertain.

Item 35 DOE welcomes feedback on its planned approach to assessing national

environmental impacts, including other factors or approaches that should be

considered.

16 REGULATORY IMPACT ANALYSIS

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis.

The regulatory impact analysis will address the potential for non­regulatory approaches to

supplant or augment energy conservation standards to improve the efficiency of fluorescent lamp

ballasts in the market.

The regulatory impact analysis will consider the likely effects of non­regulatory

initiatives on ballast energy use, consumer utility, and life­cycle costs. DOE will take into

account the actual impacts of any existing initiatives to date, but also will consider historical

information presented that may reasonably estimate the impacts that any such initiative might

have in the future. DOE will use the NES spreadsheet model (as discussed in section 10.2,

“Calculation of National Energy Savings”) to calculate the NES and NPV for the alternatives to

the potential conservation standards under consideration.

If DOE proposes energy conservation standards for fluorescent lamp ballasts, and if the

proposed rule constitutes a significant regulatory action, DOE would prepare and submit to OMB

for review the assessment of costs and benefits required under section 6(a)(3) of Executive Order

12866, “Regulatory Planning and Review,” 58 FR 51735 (October 4, 1993). The Executive

Order requires agencies to identify the specific market failure or other specific problem that it

intends to address that warrant new agency action, as well as assess the significance of that

problem, to enable assessment of whether any new regulation is warranted. (Executive Order

12866, section 1(b)(1)). Without a market failure, a regulation cannot result in net benefits.

DOE discusses potential market failures in Section 3.1 of this Framework Document, and invites

stakeholders to comment on them.

Of course, there are likely to be certain “external” benefits resulting from the improved

efficacy of ballasts that are not captured by the users of such equipment. These include both

environmental and energy security­related 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 weight that should be given to these factors

45

EERE-2007-BT-STD-0016 COMMENT 01
in DOE’s determination of the maximum efficiency level at which the total benefits are likely to

exceed the total burdens resulting from a DOE standard.

46

EERE-2007-BT-STD-0016 COMMENT 01
APPENDIX A – EPCA DIRECTIVES REGARDING FLUORESCENT LAMP

BALLASTS

This appendix lists the relevant statutory requirements under 42 U.S.C. 6295(g) (i.e.,

section 325(g) of EPCA, as amended by the Energy Policy Act of 2005) that apply to fluorescent

lamp ballasts, as well as standards established by DOE in the 2000 Ballast Rule.

42 U.S.C. 6295(g). Standards for dishwashers; clothes washers; clothes dryers; fluorescent

lamp ballasts

(5) Except as provided in paragraph (6), each fluorescent lamp ballast--

(A) (i) manufactured on or after January 1, 1990;

(ii) sold by the manufacturer on or after April 1, 1990; or

(iii) incorporated into a luminaire by a luminaire manufacturer on or after

April 1, 1991; and

(B) designed--

(i) to operate at nominal input voltages of 120 or 277 volts;

(ii) to operate with an input current frequency of 60 Hertz; and

(iii) for use in connection with an F40T12, F96T12, or F96T12HO lamps;

(C) shall have a power factor of 0.90 or greater and shall have a ballast efficacy factor

not less than the following:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

(6) The standards described in paragraph (5) do not apply to

(A) a ballast which is designed for dimming or for use in ambient temperatures of 0° F or

less, or

(B) a ballast which has a power factor of less than 0.90 and is designed and labeled for

use only in residential building applications.

(7) (A) The Secretary shall publish a final rule no later than January 1, 1992, to determine if the

standards established under paragraph (5) should be amended, including whether such

standards should be amended so that they would be applicable to ballasts described in

paragraph (6) and other fluorescent lamp ballasts. Such rule shall contain such

47

EERE-2007-BT-STD-0016 COMMENT 01
amendment, if any, and provide that the amendment shall apply to products

manufactured on or after January 1, 1995.

(B) 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.

(C) Any amendment prescribed under subparagraph (B) shall apply to products

manufactured after a date which is five years after--

(i) the effective date of the previous amendment; or

(ii) if the previous final rule did not amend the standards, the earliest date by which a

previous amendment could have been effective;

except that in no case may any amended standard apply to products manufactured within

three years after publication of the final rule establishing such amended standard.

(8)(A) Each fluorescent lamp ballast (other than replacement ballasts or ballasts described in

subparagraph (C))—

(i) (I) manufactured on or after July 1, 2009;

(II) sold by the manufacturer on or after October 1, 2009; or

(III) incorporated into a luminaire by a luminaire manufacturer on or after July

1, 2010; and

(ii) designed—

(I) to operate at nominal input voltages of 120 or 277 volts;

(II) to operate with an input current frequency of 60 Hertz; and

(III) for use in connection with F34T12 lamps, F96T12/ES lamps, or

F96T12HO/ES lamps; shall have a power factor of 0.90 or greater and shall have

a ballast efficacy factor of not less than the following:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast Efficacy

Factor

120 34 2.61

One F34T12 lamp 277 34 2.61

Two F34T12 lamps 120 68 1.35

277 68 1.35

Two F96T12/ES lamps 120 120 0.77

277 120 0.77

Two F96T12HO/ES 120 190 0.42

277 190 0.42

(B) The standards described in subparagraph (A) shall apply to all ballasts covered by

subparagraph (A)(ii) that are manufactured on or after July 1, 2010, or sold by the

manufacturer on or after October 1, 2010.

(C) The standards described in subparagraph (A) do not apply to—

(i) a ballast that is designed for dimming to 50 percent or less of the maximum output

of the ballast;

48

EERE-2007-BT-STD-0016 COMMENT 01
(ii) a ballast that is designed for use with 2 F96T12HO lamps at ambient

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

(iii) a ballast that has a power factor of less than 0.90 and is designed and labeled for

use only in residential applications.;

10 CFR 430.32(m) Energy Conservation Standards

(m)(1) Fluorescent lamp ballasts. Except as provided in paragraphs (m)(2), (m)(3), (m)(4), 

(m)(5), (m)(6) and (m)(7) of this section, each fluorescent lamp ballast—

(i) (A) Manufactured on or after January 1, 1990;

(B) Sold by the manufacturer on or after April 1, 1990; or

(C) Incorporated into a luminaire by a luminaire manufacturer on or after April 1, 1991;

and

(ii) Designed—

(A) To operate at nominal input voltages of 120 or 277 volts;

(B) To operate with an input current frequency of 60 Hertz; and

(C) For use in connection with an F40T12, F96T12, or F96T12HO lamps shall have a

power factor of 0.90 or greater and shall have a ballast efficacy factor not less than

the following:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

(2) The standards described in paragraph (m)(1) of this section do not apply to—

(i) A ballast that is designed for dimming or for use in ambient temperatures of 0 °F or

less, or

(ii) A ballast that has a power factor of less than 0.90 and is designed for use only in

residential building applications.

(3) Except as provided in paragraph (m)(4) of this section, each fluorescent lamp ballast—

(i) (A) Manufactured on or after April 1, 2005;

(B) Sold by the manufacturer on or after July 1, 2005; or

(C) Incorporated into a luminaire by a luminaire manufacturer on or after April 1, 

2006; and

(ii) Designed—

(A) To operate at nominal input voltages of 120 or 277 volts;

49

EERE-2007-BT-STD-0016 COMMENT 01
(B) To operate with an input current frequency of 60 Hertz; and

(C) For use in connection with an F40T12, F96T12, or F96T12HO lamps; shall have

a power factor of 0.90 or greater and shall have a ballast efficacy factor not less

than the following:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast

Efficacy Factor

One F40 T12 lamp 120 40 2.29

277 40 2.29

Two F40 T12 lamps 120 80 1.17

277 80 1.17

Two F96T12 lamps 120 150 0.63

277 150 0.63

Two F96T12HO lamps 120 220 0.39

277 220 0.39

(4) (i) The standards described in paragraph (m)(3) do not apply to:

(A) A ballast that is designed for dimming to 50 percent or less of its maximum output;

(B) A ballast that is designed for use with two F96T12HO lamps at ambient temperatures

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

(C) A ballast that has a power factor of less than 0.90 and is designed and labeled for use

only in residential building applications; or

(D) A replacement ballast as defined in paragraph (m)(4)(ii) of this section.

(ii) For purposes of this paragraph (m), a replacement ballast is defined as a ballast that:

(A) Is manufactured on or before June 30, 2010;

(B) Is designed for use to replace an existing ballast in a previously installed luminaire;

(C) Is marked “FOR REPLACEMENT USE ONLY”;

(D) Is shipped by the manufacturer in packages containing not more than 10 ballasts;

(E) Has output leads that when fully extended are a total length that is less than the

length of the lamp with which it is intended to be operated; and

(F) Meets or exceeds the ballast efficacy factor in the following table:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

(5) Except as provided in paragraph (m)(7) of this section, each fluorescent lamp ballast (other

than replacement ballasts defined in §430.2)—

(i) (A) Manufactured on or after July 1, 2009;

50

EERE-2007-BT-STD-0016 COMMENT 01
(B) Sold by the manufacturer on or after October 1, 2009; or

(C) Incorporated into a luminaire by a luminaire manufacturer on or after July 1, 

2010; and

(ii) Designed—

(A) To operate at nominal input voltages of 120 or 277 volts;

(B) To operate with an input current frequency of 60 Hertz; and

(C) For use in connection with F34T12 lamps, F96T12/ES lamps, or F96T12HO/ES

lamps; shall have a power factor of 0.90 or greater and shall have a ballast

efficacy factor of not less than the following:

Application for

Operation of

Ballast Input

Voltage

Total Nominal

Lamp Watts

Ballast Efficacy

Factor

One F34 T12 lamp 120 34 2.61

277 34 2.61

Two F34 T12 lamps 120 68 1.35

277 68 1.35

Two F96T12/ES lamps 120 120 0.77

277 120 0.77

Two F96T12HO/ES 120 190 0.42

lamps 277 190 0.42

(6) The standards in paragraph (m)(5) shall apply to all ballasts covered by paragraph

(m)(5)(ii), including replacement ballasts and ballasts described in paragraph (m)(7) of this

section, that are manufactured on or after July 1, 2010, or sold by the manufacturer on or

after October 1, 2010.

(7) The standards in paragraph (m)(5) do not apply to—

(i) A ballast that is designed for dimming to 50 percent or less of the maximum output of

the ballast;

(ii) A ballast that is designed for use with 2 F96T12HO lamps at ambient temperatures of

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

(iii) A ballast that has a power factor of less than 0.90 and is designed and labeled for

use only in residential applications.

51

EERE-2007-BT-STD-0016 COMMENT 01
APPENDIX B ­ DEFINITIONS

This appendix provides relevant definitions under the statute (42 U.S.C. 6291) and DOE

regulations (10 CFR 430.2) that are applicable to the lighting products covered under this

rulemaking. DOE takes the definitions from the statute and codifies them into the CFR;

therefore, some terms in this appendix may be listed twice. Please note that due to the recent

enactment of EISA 2007 (Pub. L. 110­140; December 19, 2007), some terms may only be

defined in the statute at the time this Framework Document is published, as they have not yet be

codified into the CFR.

STATUTORY DEFINITIONS

“Fluorescent Lamp Ballast”

42 U.S.C. 6291(29)

(A) The 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.

(B) The term “ANSI standard” means a standard developed by a committee accredited

by the American National Standards Institute.

(C) The term “ballast efficacy factor” means the relative light output divided by the

power input of a fluorescent lamp ballast, as measured under test conditions

specified in ANSI standard C82.2-1984, or as may be prescribed by the Secretary.

(D)(i) The term “F40T12 lamp” means a nominal 40 watt tubular fluorescent lamp

which is 48 inches in length and one-and-a-half inches in diameter, and conforms

to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-1010-1).

(ii) The term “F96T12 lamp” means a nominal 75 watt tubular fluorescent lamp

which is 96 inches in length and one-and-a-half inches in diameter, and conforms

to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-3007-1).

(iii) The term “F96T12HO lamp” means a nominal 110 watt tubular fluorescent lamp

which is 96 inches in length and one-and-a-half inches in diameter, and conforms

to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-1019-1).

(E) The term “input current” means the root-mean-square (RMS) current in amperes

delivered to a fluorescent lamp ballast.

(F) The term “luminaire” means a complete lighting unit consisting of a fluorescent lamp

or lamps, together with parts designed to distribute the light, to position and protect

such lamps, and to connect such lamps to the power supply through the ballast.

(G) The term “ballast input voltage” means the rated input voltage of a fluorescent lamp

ballast.

(H) The term “nominal lamp watts” means the wattage at which a fluorescent lamp is

designed to operate.

(I) The term “power factor” means the power input divided by the product of ballast

input voltage and input current of a fluorescent lamp ballast, as measured under

52

EERE-2007-BT-STD-0016 COMMENT 01
test conditions specified in ANSI standard C82.2-1984, or as may be prescribed by

the Secretary.

(J) The term “power input” means the power consumption in watts of a ballast and

fluorescent lamp or lamps, as determined in accordance with the test procedures

specified in ANSI standard C82.2-1984, or as may be prescribed by the Secretary.

(K) The term “relative light output” means the light output delivered through the use of a

ballast divided by the light output delivered through the use of a reference ballast, 

expressed as a percent, as determined in accordance with the test procedures

specified in ANSI standard C82.2-1984, or as may be prescribed by the Secretary.

(L) The term “residential building” means a structure or portion of a structure which

provides facilities or shelter for human residency, except that such term does not

include any multifamily residential structure of more than three stories above

grade.

(M) The term ``lamp efficacy'' means the lumen output of a lamp divided by its wattage, 

expressed in lumens per watt (LPW).

(N) The term ``lamp type'' means all lamps designated as having the same electrical and

lighting characteristics and made by one manufacturer.

(O) The term ``lamp wattage'' means the total electrical power consumed by a lamp in

watts, after the initial seasoning period referenced in the appropriate IES standard

test procedure and including, for fluorescent, arc watts plus cathode watts.

(P) The terms ``life'' and ``lifetime'' mean length of operating time of a statistically large

group of lamps between first use and failure of 50 percent of the group in

accordance with test procedures described in the IES Lighting HandbookReference Volume.

“Fluorescent Lamps”

42 U.S.C. 6291(30)(A)

(A) Except as provided in subparagraph (E), 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, including

only the following:

(i) Any straight-shaped lamp (commonly referred to as 4-foot medium bi-pin lamps)

with medium bi-pin bases of nominal overall length of 48 inches and rated

wattage of 28 or more.

(ii) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with

medium bi-pin bases of nominal overall length between 22 and 25 inches and

rated wattage of 28 or more.

(iii)Any rapid start lamp (commonly referred to as 8-foot high output lamps) with

recessed double contact bases of nominal overall length of 96 inches and 0.800

nominal amperes, as defined in ANSI C78.1-1978 and related supplements.

(iv)Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single

pin bases of nominal overall length of 96 inches and rated wattage of 52 or more, 

53

EERE-2007-BT-STD-0016 COMMENT 01
as defined in ANSI C78.3-1978 (R1984) and related supplement ANSI C78.3a1985.

42 U.S.C. 6291(30)(E)

(E) The terms “fluorescent lamp” and “incandescent lamp” do not include any lamp

excluded by the Secretary, by rule, as a result of a determination that standards for

such lamp would not result in significant energy savings because such lamp is

designed for special applications or has special characteristics not available in

reasonably substitutable lamp types.

“Ballast”

42 U.S.C. 6291(58)

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.

“Electronic Ballast”

42 U.S.C. 6291(60)

The term `electronic ballast' means a device that uses semiconductors as the primary

means to control lamp starting and operation.

DEFINITIONS IN DOE REGULATIONS

10 CFR 430.2 – Definitions

Ballast efficacy factor means the relative light output divided by the power input of a fluorescent

lamp ballast, as measured under test conditions specified in ANSI Standard C82.2–1984.

Fluorescent lamp means a low pressure mercury electric­discharge source in which a fluorescing

coating transforms some of the ultraviolet energy generated by the mercury discharge into light,

including only the following:

(1) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin lamps) with

medium bi­pin bases of nominal overall length of 48 inches and rated wattage of 28 or

more.

54

EERE-2007-BT-STD-0016 COMMENT 01
(2) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps) with medium bipin bases of nominal overall length between 22 and 25 inches and rated wattage of 28 or

more.

(3) Any rapid start lamp (commonly referred to as 8­foot high output lamps) with recessed

double contact bases of nominal overall length of 96 inches and 0.800 nominal amperes,

as defined in ANSI C78.1–1991.

(4) Any instant start lamp (commonly referred to as 8­foot slimline lamps) with single pin

bases of nominal overall length of 96 inches and rated wattage of 52 or more, as defined

in ANSI C78.3–1991.

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.

Replacement ballast means a ballast that—

(1) Is designed for use to replace an existing fluorescent lamp ballast in a previously installed

luminaire;

(2) Is marked “FOR REPLACEMENT USE ONLY”;

(3) Is shipped by the manufacturer in packages containing not more than 10 fluorescent lamp

ballasts; and

(4) Has output leads that when fully extended are a total length that is less than the length of

the lamp with which the ballast is intended to be operated.

55

EERE-2007-BT-STD-0016 COMMENT 01
APPENDIX C – TEST PROCEDURES

This appendix provides the DOE test procedures for measuring the energy consumption

of fluorescent lamp ballasts, as contained in 10 CFR 430, Subpart B, Appendix Q.

Appendix Q to Subpart B of Part 430—Uniform Test Method for Measuring the Energy

Consumption of Fluorescent Lamp Ballasts

1. Definitions

1.1 ANSI Standard means a standard developed by a committee accredited by the American

National Standards Institute.

1.2 Ballast input voltage means the rated input voltage of a fluorescent lamp ballast.

1.3 F4OT12 lamp means a nominal 40 watt tubular fluorescent lamp which is 48 inches in

length and one and a half inches in diameter, and conforms to ANSI standard C78.81–2003

(Data Sheet 7881–ANSI–1010–1).

1.4 F96T12 lamp means a nominal 75 watt tubular fluorescent lamp which is 96 inches in length

and one and one­half inches in diameter, and conforms to ANSI Standard C78.81–2003 (Data

Sheet 7881–ANSI–3007–1).

1.5 F96T12HO lamp means a nominal 110 watt tubular fluorescent lamp that is 96 inches in

length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81–2003 (Data Sheet

7881–ANSI–1019–1).

1.6 F34T12 lamp (also known as a “F40T12/ES lamp”) means a nominal 34 watt tubular

fluorescent lamp that is 48 inches in length and 1 1/2 inches in diameter, and conforms to ANSI

standard C78.81–2003 (Data Sheet 7881–ANSI–1006–1).

1.7 F96T12/ES lamp means a nominal 60 watt tubular fluorescent lamp that is 96 inches in

length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81–2003 (Data Sheet

7881–ANSI–3006–1).

1.8 F96T12HO/ES lamp means a nominal 95 watt tubular fluorescent lamp that is 96 inches in

length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81–2003 (Data Sheet

7881–ANSI–1017–1).

1.9 Input current means the root­mean­square (RMS) current in amperes delivered to a

fluorescent lamp ballast.

1.10 Luminaire means a complete lighting unit consisting of a fluorescent lamp or lamps,

together with parts designed to distribute the light, to position and protect such lamps, and to

connect such lamps to the power supply through the ballast.

56

EERE-2007-BT-STD-0016 COMMENT 01
1.11 Nominal lamp watts means the wattage at which a fluorescent lamp is designed to operate.

1.12 Power factor means the power input divided by the product of ballast input voltage and

input current of a fluorescent lamp ballast, as measured under test conditions specified in ANSI

Standard C82.2–1984.

1.13 Power input means the power consumption in watts of a ballast and fluorescent lamp or

lamps, as determined in accordance with the test procedures specified in ANSI Standard C82.2–

1984.

1.14 Relative light output means the light output delivered through the use of a ballast divided

by the light output delivered through the use of a reference ballast, expressed as a percent, as

determined in accordance with the test procedures specified in ANSI Standard C82.2–1984.

1.15 Residential building means a structure or portion of a structure which provides facilities or

shelter for human residency, except that such term does not include any multifamily residential

structure of more than three stores above grade.

1.16 ANSI Standard C82.2–1984 means the test standard published by the American National

Standard Institute (ANSI), titled “American National Standard for Fluorescent Lamp Ballasts—

Method of Measurement, 1984”, and designated as ANSI C82.2–1984.

2. Test conditions. The test conditions for testing fluorescent lamp ballasts shall be done in

accordance with the American National Standard Institute (ANIS) Standard C82.2–1984,

“American National Standard for Fluorescent Lamp Ballasts—Methods of Measurement,”

approved October 21, 1983. This incorporation by reference was approved by the Director of the

Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. Copies may be obtained

from ANSI Publication Sales, 1430 Broadway, New York, NY 10068. Copies may be inspected

at the Department of Energy, Freedom of Information Reading Room, Room 1E–190,

Fluorescent Lamp Ballasts, Docket No. CE–RM–89–102, 1000 Independence Avenue, SW,

Washington DC 20585, or at the National Archives and Records Administration (NARA). For

information on the availability of this material at NARA, call 202–741–6030, or go to:

http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. Any

subsequent amendment to this standard by the standard­setting organization will not affect the

DOE test procedures unless and until amended by DOE. The test conditions are described in

sections 4, 5, 6, 7, and 21 of ANSI Standard C82.2–1984.

3. Test Method and Measurements.

3.1. The test method for testing fluorescent lamp ballasts shall be done in accordance with ANSI

Standard C82.2–1984.

3.2 Instrumentation. The instrumentation shall be as specified by sections 8, 9, 10, 11, 12, 19.1,

and 23.2 of ANSI Standard C82.2–1984.

3.3 Electric Supply.

57

EERE-2007-BT-STD-0016 COMMENT 01
3.3.1. Input Power. Measure the input power (watts) to the ballast in accordance with ANSI

Standard C82.2–1984, section 3.2.1(3) and section 4.

3.3.2 Input Voltage. Measure the input voltage (volts) (RMS) to the ballast in accordance with

ANSI Standard C82.2–1984, section 3.2.1(1) and section 4.

3.3.3 Input Current. Measure the input current (amps) (RMS) to the ballast in accordance with

ANSI Standard C82.2–1984, section 3.2.1(2) and section 4.

3.4 Light Output.

3.4.1 Measure the light output of the reference lamp with the reference ballast in accordance

with ANSI Standard C82.2–1984, section 16.

3.4.2 Measure the light output of the reference lamp with the test ballast in accordance with

ANSI Standard C82.2–1984, section 16.

4. Calculations.

4.1 Calculate relative light output:

Where:

photocell output of lamp on test ballast is determined in accordance with section 3.4.2, expressed

in watts, and photocell output of lamp on ref. ballast is determined in accordance with section

3.4.1, expressed in watts.

4.2. Determine the Ballast Efficacy Factor (BEF) using the following equations:

(a) Single lamp ballast

(b) Multiple lamp ballast

58

EERE-2007-BT-STD-0016 COMMENT 01
Where:

input power is determined in accordance with section 3.3.1,

relative light output as defined in section 4.1, and

average relative light output is the relative light output, as defined in section 4.1, for all lamps,

divided by the total number of lamps.

4.3 Determine Ballast Power Factor (PF):

Where:

Input power is as defined in section 3.3.1,

Input voltage is determined in accordance with section 3.3.2, expressed in volts, and

Input current is determined in accordance with section 3.3.3, expressed in amps.

[54 FR 6076, Feb. 7, 1989, as amended at 56 FR 18682, April 24, 1991; 69 FR 18803, Apr. 9,

2004; 70 FR 60412, Oct. 18, 2005]

59

EERE-2007-BT-STD-0016 COMMENT 01
APPENDIX D – ENERGY INDEPENDENCE AND SECURITY ACT OF 2007

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

of 2007 (EISA 2007) (P.L. 110­140). This legislation amended certain aspects of EPCA,

including, in particular, the potential amendment of existing testing requirements for fluorescent

lamp ballasts (see section 310 of EISA 2007) and addition of mandatory efficiency standards for

metal halide lamp fixtures (see section 324 of EISA 2007). Among other things, the new

standard for metal halide lamp fixtures establishes requirements for the efficiency of the ballasts

installed in metal halide lamp fixtures. DOE is aware that some companies that produce

fluorescent lamp ballasts may also manufacture metal halide lamp ballasts and fixtures;

therefore, the entirety of EISA 2007 section 324 is included here for reference.

SEC. 310. STANDBY MODE.

Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) is amended—

(1) in subsection (u)—

(A) by striking paragraphs (2), (3), and (4); and

(B) by redesignating paragraphs (5) and (6) as paragraphs (2) and (3), 

respectively;

(2) by redesignating subsection (gg) as subsection (hh);

(3) by inserting after subsection (ff) the following:

`(gg) Standby Mode Energy Use-

`(1) DEFINITIONS-

`(A) IN GENERAL- Unless the Secretary determines otherwise pursuant to

subparagraph (B), in this subsection:

`(i) ACTIVE MODE- The term `active mode' means the condition in which

an energy-using product—

`(I) is connected to a main power source;

`(II) has been activated; and

`(III) provides 1 or more main functions.

60

EERE-2007-BT-STD-0016 COMMENT 01
`(ii) OFF MODE- The term `off mode' means the condition in which an

energy-using product—

`(I) is connected to a main power source; and

`(II) is not providing any standby or active mode function.

`(iii) STANDBY MODE- The term `standby mode' means the condition in

which an energy-using product—

`(I) is connected to a main power source; and

`(II) offers 1 or more of the following user-oriented or protective

functions:

`(aa) To facilitate the activation or deactivation of other

functions (including active mode) by remote switch

(including remote control), internal sensor, or timer.

`(bb) Continuous functions, including information or status

displays (including clocks) or sensor-based functions.

`(B) AMENDED DEFINITIONS- The Secretary may, by rule, amend the

definitions under subparagraph (A), taking into consideration the most current

versions of Standards 62301 and 62087 of the International Electrotechnical

Commission.

`(2) TEST PROCEDURES-

`(A) IN GENERAL- Test procedures for all covered products shall be amended

pursuant to section 323 to include standby mode and off mode energy

consumption, taking into consideration the most current versions of Standards

62301 and 62087 of the International Electrotechnical Commission, with such

energy consumption integrated into the overall energy efficiency, energy

consumption, or other energy descriptor for each covered product, unless the

Secretary determines that—

`(i) the current test procedures for a covered product already fully

account for and incorporate the standby mode and off mode energy

consumption of the covered product; or

`(ii) such an integrated test procedure is technically infeasible for a

particular covered product, in which case the Secretary shall prescribe a

separate standby mode and off mode energy use test procedure for the

covered product, if technically feasible

.

61

EERE-2007-BT-STD-0016 COMMENT 01
`(B) DEADLINES- The test procedure amendments required by subparagraph (A)

shall be prescribed in a final rule no later than the following dates:

`(i) December 31, 2008, for battery chargers and external power supplies.

`(ii) March 31, 2009, for clothes dryers, room air conditioners, and

fluorescent lamp ballasts.

`(iii) June 30, 2009, for residential clothes washers.

`(iv) September 30, 2009, for residential furnaces and boilers.

`(v) March 31, 2010, for residential water heaters, direct heating

equipment, and pool heaters.

`(vi) March 31, 2011, for residential dishwashers, ranges and ovens, 

microwave ovens, and dehumidifiers.

`(C) PRIOR PRODUCT STANDARDS- The test procedure amendments adopted

pursuant to subparagraph (B) shall not be used to determine compliance with

product standards established prior to the adoption of the amended test

procedures.

`(3) INCORPORATION INTO STANDARD-

`(A) IN GENERAL- Subject to subparagraph (B), based on the test procedures

required under paragraph (2), any final rule establishing or revising a standard

for a covered product, adopted after July 1, 2010, shall incorporate standby mode

and off mode energy use into a single amended or new standard, pursuant to

subsection (o), if feasible.

`(B) SEPARATE STANDARDS- If not feasible, the Secretary shall prescribe

within the final rule a separate standard for standby mode and off mode energy

consumption, if justified under subsection (o).'; and

(4) in paragraph (2) of subsection (hh) (as redesignated by paragraph (2)), by

striking `(ff)' each place it appears and inserting `(gg)'.

SEC. 324. METAL HALIDE LAMP FIXTURES.

(a) DEFINITIONS.-- Section 321 of the Energy Policy and Conservation Act (42 U.S.C. 6291)

(as amended by section 322(a)(2)) is amended by adding at the end the following:

62

EERE-2007-BT-STD-0016 COMMENT 01
`(58) 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.

`(59) BALLAST EFFICIENCY.--

`(A) IN GENERAL.-- The term `ballast efficiency' means, in the case of a high

intensity discharge fixture, the efficiency of a lamp and ballast combination, 

expressed as a percentage, and calculated in accordance with the following formula:

Efficiency = Pout/Pin.

`(B) EFFICIENCY FORMULA.-- For the purpose of subparagraph (A)--

`(i) Pout shall equal the measured operating lamp wattage;

`(ii) Pin shall equal the measured operating input wattage;

`(iii) the lamp, and the capacitor when the capacitor is provided, shall constitute

a nominal system in accordance with the ANSI Standard C78.43-2004;

`(iv) for ballasts with a frequency of 60 Hz, Pin and Pout shall be measured after

lamps have been stabilized according to section 4.4 of ANSI Standard C82.6-2005

using a wattmeter with accuracy specified in section 4.5 of ANSI Standard C82.6-

2005; and

`(v) for ballasts with a frequency greater than 60 Hz, Pin and Pout shall have a

basic accuracy of ±0.5 percent at the higher of--

`(I) 3 times the output operating frequency of the ballast; or

`(II) 2 kHz for ballast with a frequency greater than 60 Hz.

`(C) MODIFICATION.-- The Secretary may, by rule, modify the definition of `ballast

efficiency' if the Secretary determines that the modification is necessary or

appropriate to carry out the purposes of this Act.

`(60) ELECTRONIC BALLAST.-- The term `electronic ballast' means a device that uses

semiconductors as the primary means to control lamp starting and operation.

`(61) GENERAL LIGHTING APPLICATION.-- The term `general lighting application'

means lighting that provides an interior or exterior area with overall illumination.

`(62) METAL HALIDE BALLAST.-- The term `metal halide ballast' means a ballast used

to start and operate metal halide lamps.

`(63) METAL HALIDE LAMP.-- The term `metal halide lamp' means a high intensity

discharge lamp in which the major portion of the light is produced by radiation of metal

halides and their products of dissociation, possibly in combination with metallic vapors.

63

EERE-2007-BT-STD-0016 COMMENT 01
`(64) METAL HALIDE LAMP FIXTURE.-- The term `metal halide lamp fixture' means a

light fixture for general lighting application designed to be operated with a metal halide

lamp and a ballast for a metal halide lamp.

`(65) PROBE-START METAL HALIDE BALLAST.-- The term `probe-start metal halide

ballast' means a ballast that--

`(A) starts a probe-start metal halide lamp that contains a third starting electrode

(probe) in the arc tube; and

`(B) does not generally contain an igniter but instead starts lamps with high ballast

open circuit voltage.

`(66) PULSE-START METAL HALIDE BALLAST.--

`(A) IN GENERAL.-- The term `pulse-start metal halide ballast' means an electronic

or electromagnetic ballast that starts a pulse-start metal halide lamp with high

voltage pulses.

`(B) STARTING PROCESS.-- For the purpose of subparagraph (A)--

`(i) lamps shall be started by first providing a high voltage pulse for ionization of

the gas to produce a glow discharge; and

`(ii) to complete the starting process, power shall be provided by the ballast to

sustain the discharge through the glow-to-arc transition.'.

(b) COVERAGE.-- Section 322(a) of the Energy Policy and Conservation Act (42 U.S.C.

6292(a)) is amended--

(1) by redesignating paragraph (19) as paragraph (20); and

(2) by inserting after paragraph (18) the following:

`(19) Metal halide lamp fixtures.'.

(c) TEST PROCEDURES.-- Section 323(b) of the Energy Policy and Conservation Act (42

U.S.C. 6293(b)) (as amended by section 301(b)) is amended by adding at the end the following:

`(18) METAL HALIDE LAMP BALLASTS.-- Test procedures for metal halide lamp

ballasts shall be based on ANSI Standard C82.6-2005, entitled `Ballasts for High

Intensity Discharge Lamps--Method of Measurement'.'.

(d) LABELING.-- Section 324(a)(2) of the Energy Policy and Conservation Act (42 U.S.C.

6294(a)(2)) is amended--

(1) by redesignating subparagraphs (C) through (G) as subparagraphs (D) through (H), 

respectively; and

64

EERE-2007-BT-STD-0016 COMMENT 01
(2) by inserting after subparagraph (B) the following:

`(C) METAL HALIDE LAMP FIXTURES.--

`(i) IN GENERAL.-- The Commission shall issue labeling rules under this section

applicable to the covered product specified in section 322(a)(19) and to which

standards are applicable under section 325.

`(ii) LABELING.-- The rules shall provide that the labeling of any metal halide

lamp fixture manufactured on or after the later of January 1, 2009, or the date

that is 270 days after the date of enactment of this subparagraph, shall indicate

conspicuously, in a manner prescribed by the Commission under subsection (b)

by July 1, 2008, a capital letter `E' printed within a circle on the packaging of the

fixture, and on the ballast contained in the fixture.'.

(e) STANDARDS.-- Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) (as

amended by section 310) is amended--

(1) by redesignating subsection (hh) as subsection (ii);

(2) by inserting after subsection (gg) the following:

`(hh) METAL HALIDE LAMP FIXTURES.--

`(1) STANDARDS.--

`(A) IN GENERAL.-- Subject to subparagraphs (B) and (C), metal halide

lamp fixtures designed to be operated with lamps rated greater than or

equal to 150 watts but less than or equal to 500 watts shall contain--

`(i) a pulse-start metal halide ballast with a minimum ballast

efficiency of 88 percent;

`(ii) a magnetic probe-start ballast with a minimum ballast

efficiency of 94 percent; or

`(iii) a nonpulse-start electronic ballast with--

`(I) a minimum ballast efficiency of 92 percent for wattages

greater than 250 watts; and

`(II) a minimum ballast efficiency of 90 percent for

wattages less than or equal to 250 watts.

`(B) EXCLUSIONS.-- The standards established under subparagraph (A)

shall not apply to--

`(i) fixtures with regulated lag ballasts;

65

EERE-2007-BT-STD-0016 COMMENT 01
`(ii) fixtures that use electronic ballasts that operate at 480 volts;

or

`(iii) fixtures that--

`(I) are rated only for 150 watt lamps;

`(II) are rated for use in wet locations, as specified by the

National Electrical Code 2002, section 410.4(A); and

`(III) contain a ballast that is rated to operate at ambient

air temperatures above 50°C, as specified by UL 1029-

2001.

`(C) APPLICATION.-- The standards established under subparagraph (A)

shall apply to metal halide lamp fixtures manufactured on or after the

later of--

`(i) January 1, 2009; or

`(ii) the date that is 270 days after the date of enactment of this

subsection.

`(2) FINAL RULE BY JANUARY 1, 2012.--

`(A) IN GENERAL.-- Not later than January 1, 2012, the Secretary shall

publish a final rule to determine whether the standards established under

paragraph (1) should be amended.

`(B) ADMINISTRATION.-- The final rule shall--

`(i) contain any amended standard; and

`(ii) apply to products manufactured on or after January 1, 2015.

`(3) FINAL RULE BY JANUARY 1, 2019.--

`(A) IN GENERAL.-- Not later than January 1, 2019, the Secretary shall

publish a final rule to determine whether the standards then in effect

should be amended.

`(B) ADMINISTRATION.-- The final rule shall--

`(i) contain any amended standards; and

`(ii) apply to products manufactured after January 1, 2022.

66

EERE-2007-BT-STD-0016 COMMENT 01
`(4) DESIGN AND PERFORMANCE REQUIREMENTS.-- Notwithstanding any

other provision of law, any standard established pursuant to this subsection may

contain both design and performance requirements.'; and

(3) in paragraph (2) of subsection (ii) (as redesignated by paragraph (2)), by striking

`(gg)' each place it appears and inserting `(hh)'.

(f) EFFECT ON OTHER LAW.-- Section 327(c) of the Energy Policy and Conservation Act (42

U.S.C. 6297(c)) is amended--

(1) in paragraph (8)(B), by striking the period at the end and inserting `; and'; and

(2) by adding at the end the following:

`(9) is a regulation concerning metal halide lamp fixtures adopted by the California

Energy Commission on or before January 1, 2011, except that--

`(A) if the Secretary fails to issue a final rule within 180 days after the deadlines

for rulemakings in section 325(hh), notwithstanding any other provision of this

section, preemption shall not apply to a regulation concerning metal halide lamp

fixtures adopted by the California Energy Commission--

`(i) on or before July 1, 2015, if the Secretary fails to meet the deadline

specified in section 325(hh)(2); or

`(ii) on or before July 1, 2022, if the Secretary fails to meet the deadline

specified in section 325(hh)(3).'.

67

EERE-2007-BT-STD-0016 COMMENT 01
APPENDIX E – LIST OF ITEMS FOR COMMENT

This appendix lists all the items for comment contained in this Fluorescent Lamp Ballast

Framework Document, and the page numbers on which those items for comment can be found.

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)).................................................................................................................. 7

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?........................................................................................................................... 7

Item 3 DOE welcomes comment on the issue of updating its fluorescent lamp ballast test

procedure. DOE also invites comment on whether it should update the test procedure to

include the industry standards ANSI C82.2­2002, C82.1­2004, C82.11­2002 or any

additional procedures that should be considered in its test procedure rulemaking for

fluorescent lamp ballasts. ................................................................................................. 8

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

factor for rapid­start and instant­start 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

instant­start ballasts in their literature using the ANSI or DOE test procedure. .............. 9

Item 5 DOE also welcomes comment on BF calculation methods used for programmed­start

ballasts, modified­rapid­start ballasts, and other types of fluorescent lamp ballasts not

covered by the DOE test procedure or ANSI C82.2­2002. .............................................. 9

Item 6 DOE welcomes input on shipments, manufacturing costs, product­feature 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.......................................................................................................................... 17

Item 7 DOE is seeking stakeholder comment and data on potential market failures that could

apply to fluorescent lamp ballasts. ................................................................................. 18

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). .......................................................................................................................... 20

68

EERE-2007-BT-STD-0016 COMMENT 01
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 consider. In commenting on design options, please discuss their impacts on

safety, performance, and consumer utility (if any)......................................................... 22

Item 10 DOE welcomes comment on how the above four screening criteria might apply to any

additional technology design option(s) that a stakeholder recommends to DOE. ......... 23

Item 11 DOE welcomes comment on representative product classes and selection of baseline

models from those representative product classes.......................................................... 24

Item 12 DOE welcomes comment on the scaling of findings from representative product classes

to other product classes that DOE may not analyze. ...................................................... 24

Item 13 DOE welcomes comment on commercially­available fluorescent lamp ballasts for each

of the baseline models with incrementally increasing BEF, all the way to the max­tech

ballast.............................................................................................................................. 25

Item 14 DOE welcomes comment on how BEF varies with lamp wattage................................. 25

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? .................................................... 26

Item 16 DOE welcomes comment on regulatory burdens or changes that should be considered in

the engineering analysis of fluorescent lamp ballasts. ................................................... 26

Item 17 DOE welcomes comment on other engineering issues that could impact the engineering

analysis. .......................................................................................................................... 26

Item 18 DOE welcomes comment on use of the planned operating hours 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............................................................... 27

Item 19 DOE welcomes comment on final end­user prices for high­range, medium­range, and

low­range fluorescent ballasts. ....................................................................................... 28

Item 20 DOE welcomes comment on typical contractor and distributor markups associated with

the purchase and installation of fluorescent lamp ballasts. ............................................ 28

Item 21 DOE welcomes input on the electricity prices used in this analysis. ............................. 30

Item 22 DOE welcomes input on the planned approaches for estimating discount rates for

consumers of fluorescent lamp ballasts covered under this rulemaking. ....................... 31

Item 23 DOE welcomes comment on how to develop installation, maintenance, and (if

applicable) repair costs for fluorescent lamp ballasts. In particular, will fluorescent

69

EERE-2007-BT-STD-0016 COMMENT 01
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 re­lamping practices (i.e., group re­lamping and spot re­lamping) would change

as a result of the standard. .............................................................................................. 32

Item 24 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for the

ballasts covered in this rulemaking. ............................................................................... 32

Item 25 DOE welcomes recommendations on 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 long­term trends in efficiency of fluorescent lamp ballasts for

the base­case shipments forecast. ................................................................................... 33

Item 26 DOE welcomes comment on the accounting methodology described above for each of

the fluorescent lamp ballasts covered in this rulemaking............................................... 34

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 market­pull programs that currently exist to promote the adoption of moreefficacious ballasts.......................................................................................................... 34

Item 28 DOE welcomes comment on the data sources it anticipates using to develop inputs for

the national impact analysis............................................................................................ 36

Item 29 DOE welcomes comment on the NES spreadsheet models it plans to use for estimating

national impacts of energy conservation standards for fluorescent lamp ballasts.......... 37

Item 30 DOE welcomes comment on what, if any, consumer subgroups are appropriate in

considering standards for fluorescent lamp ballasts....................................................... 38

Item 31 If appropriate, what are potential subgroups of fluorescent lamp ballast manufacturers

that DOE should consider in a manufacturer subgroup analysis?.................................. 40

Item 32 DOE welcomes comment on what other regulations or pending regulations it should

consider in its examination of cumulative regulatory burden. ....................................... 41

Item 33 DOE welcomes input from stakeholders on its plans to use NEMS­BT to conduct the

utility impact analysis..................................................................................................... 42

Item 34 DOE welcomes feedback on its planned approach for assessing national employment

impacts, both direct and indirect. ................................................................................... 43

Item 35 DOE welcomes feedback on its planned approach to assessing national environmental

impacts, including other factors or approaches that should be considered. ................... 45

70

EERE-2007-BT-STD-0016 COMMENT 01