[6450-01-P] 

DEPARTMENT OF ENERGY 

Office of Energy Efficiency and Renewable Energy 

10 CFR Part 430 

[Docket No. EERE-2009-BT-TP-0016] 

RIN: 1904-AB99 

Energy Conservation Program: Test Procedures for Fluorescent Lamp Ballasts 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking and public meeting.

SUMMARY: The U.S. Department of Energy (DOE) proposes major revisions to its test

procedures for fluorescent lamp ballasts established under the Energy Policy and Conservation

Act. The proposed test method would eliminate the use of photometric measurements in favor of

purely electrical measurements with the goal of reducing measurement variation. DOE proposes

a set of transfer functions to convert the measured ballast electrical efficiency to a ballast

efficacy factor value. These revisions, however, do not concern the measurement of energy

consumption of ballasts in the standby and off modes, which DOE addressed in another

rulemaking. DOE also announces a public meeting to receive comment on the issues presented in

this notice.

DATES: DOE will hold a public meeting on Monday, April 26, 2010, beginning at 9:00 a.m. in

Washington, DC. The agenda for the public meeting will first cover this test procedure

rulemaking for fluorescent lamp ballasts, and then the concurrent energy conservation standards

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rulemaking (see proposal in today's Federal Register) for the same products. Any person
 

requesting to speak at the public meeting should submit such a request, along with an electronic

copy of the statement to be given at the public meeting, before 4:00 p.m., Monday, April 12, 

2010.

DOE will accept comments, data, and information regarding this notice of proposed

rulemaking (NOPR) before or after the public meeting, but no later than [INSERT DATE 75 

DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]. See section

V, "Public Participation," of this NOPR for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, Forrestal

Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585-0121. To

attend the public meeting, please notify Ms. Brenda Edwards at (202) 586-2945. Please note that

foreign nationals participating in the public meeting are subject to advance security screening

procedures. If a foreign national wishes to participate in the workshop, please inform DOE of

this fact as soon as possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that the

necessary procedures can be completed.

Any comments submitted must identify the Fluorescent Lamp Ballast Active Mode Test

Procedures NOPR, and provide the docket number EERE-2009-BT-TP-0016 and/or Regulation

Identifier Number (RIN) 1904-AB99. Comments may be submitted using any of the following

methods:

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Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for
 

submitting comments.

E-mail: FLB-2009-TP-0016@ee.doe.gov. Include the docket number EERE-2009-BTTP-0016 and/or RIN 1904-AB99 in the subject line of the message.

Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 20585-0121.

Please submit one signed paper original.

Hand DeliverY/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building

Technologies Program, 6th Floor, 950 L'Enfant Plaza, SW., Washington, DC, 20024. Telephone:

(202) 586-2945. Please submit one signed paper original.

For detailed instructions on submitting comments and additional information on the

rulemaking process, see section V, "Public Participation," of this document.

Docket: For access to the docket to read background documents or comments received, 

visit the U.S. Department of Energy, 6th Floor, 950 L'Enfant Plaza, SW., Washington, DC, 

20024, (202) 586-2945, between 9:00 a.m. and 4:00 p.m., Monday through Friday, except

Federal holidays. Please call Ms. Brenda Edwards at (202) 586-2945 for additional information

regarding visiting the Resource Room.

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FOR FURTHER INFORMATION CONTACT: Ms. Linda Graves, U.S. Department
 

of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, 

EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-

1851. E-mail: Linda.Graves@ee.doe.gov. In the Office of General Counsel, contact Ms. Betsy

Kohl, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence

Avenue, SW., Washington, DC 20585. Telephone: (202) 586-7796. E-mail:

Betsy.Kohl@hq.doe.gov.

For additional information on how to submit or review public comments and on how to

participate in the public meeting, contact Ms. Brenda Edwards, U.S. Department of Energy, 

Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J,

1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. Email: Brenda.Edwards@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents 

I. Authority and Background

II. Summary of the Proposal

III. Discussion

A. Scope of Applicability

1. Ballasts Covered

2. Effective Date

B. Existing Test Procedure

C. Drawbacks of Existing BEF Test Procedure

D. Efficiency Metric for Fluorescent Lamp Ballasts

E. Test Procedure Improvement Options

1. Resistor-Based Ballast Efficiency Correlated to Ballast Efficacy Factor

2. Lamp-Based Ballast Efficiency Correlated to Ballast Efficacy Factor

3. Improvements to Existing Test Procedure

4. Relative System Efficacy

F. Proposed Test Procedure

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1. Test Conditions

2. Test Setup

3. Test Method

4. Calculations

5. Transfer Equations - General Method

6. Transfer Equations - Testing, Analysis, and Results

7. Resistor Value Determination

8. Non-Operational Ballasts When Connected to a Resistor

9. Existing Test Procedure Update

10. References to ANSI C82.2-2002

G. Burden to Conduct the Proposed Test Procedure

H. Impact on Measured Energy Efficiency

I. Certification and Enforcement

IV. Procedural Issues and Regulatory Review

A. Executive Order 12866

B. National Environmental Policy Act

C. Regulatory Flexibility Act

D. Paperwork Reduction Act

E. Unfunded Mandates Reform Act of 1995

F. Treasury and General Government Appropriations Act, 1999

G. Executive Order 13132

H. Executive Order 12988

I. Treasury and General Government Appropriations Act, 2001

J. Executive Order 13211

K. Executive Order 12630

L. Section 32 of the Federal Energy Administration Act of 1974

V. Public Participation

A. Attendance at Public Meeting

B. Procedure for Submitting Requests to Speak

C. Conduct of Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

1. All Aspects of the Existing Test Procedure for Active Mode Energy Consumption

2. Appropriate Usage of ANSI Standards

3. Method of Measurement for Dimming Ballasts

4. Resistor-based Ballast Efficiency Test Method

5. Alternative Approaches to Amending the Test Procedure

6. Ballasts that do not Operate Resistors

7. Ballast Factor Variation Due to Variations in Measured Lamp Power

8. Ballast Factor Binning

9. Transfer Equations

10. Scaling Transfer Equations

11. Burden on Manufacturers and Testing Facilities

VI. Approval of the Office of the Secretary

I. Authority and Background

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Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA or the

Act) sets forth a variety of provisions designed to improve energy efficiency. Part A of Title III

(42 U.S.C. 6291-6309) establishes the "Energy Conservation Program for Consumer Products

Other Than Automobiles," which covers consumer products and certain commercial products (all

of which are referred to below as "covered products"), including fluorescent lamp ballasts

(ballasts). (42 U.S.C. 6291(1)(2) and 6292(a)(13))

Under the Act, the overall program consists essentially of the following parts: testing, 

labeling, and Federal energy conservation standards. The testing requirements consist of test

procedures, prescribed under EPCA, that manufacturers of covered products must use as the

basis for certifying to the DOE that their products comply with energy conservation standards

adopted under EPCA and for representations as to the efficiency of their products. Also, these

test procedures must be used whenever testing is required in an enforcement action to determine

whether covered products comply with EPCA standards.

Section 323 of EPCA (42 U.S.C. 6293) sets forth generally applicable criteria and

procedures for DOE's adoption and amendment of test procedures. It states, for example, that

"[a]ny test procedures prescribed or amended under this section shall be reasonably designed to

produce test results which measure energy efficiency, energy use, . . . or estimated annual

operating cost of a covered product during a representative average use cycle or period of use, as

determined by the Secretary [of Energy], and shall not be unduly burdensome to conduct." (42

U.S.C. 6293(b)(3)) In addition, if DOE determines that a test procedure amendment is warranted, 

it must publish proposed test procedures and offer the public an opportunity to present oral and

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written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any rulemaking to amend a test
 

procedure, DOE must determine "to what extent, if any, the proposed test procedure would alter

the measured energy efficiency . . . of any covered product as determined under the existing test

procedure." (42 U.S.C. 6293(e)(1)) If DOE determines that the amended test procedure would

alter the measured efficiency of a covered product, DOE must amend the applicable energy

conservation standard accordingly. (42 U.S.C. 6293(e)(2))

As to fluorescent lamp ballasts specifically, DOE must "prescribe test procedures that are

in accord with ANSI1 standard C82.2-19842 or other test procedures determined appropriate by

the Secretary." (42 U.S.C. 6293(b)(5)) DOE's existing test procedures for ballasts, adopted

pursuant to these and the above-described provisions, appear at 10 CFR Part 430, Subpart B, 

Appendix Q.

This test procedure rulemaking will fulfill the periodic review requirement prescribed by

the Energy Independence and Security Act of 2007. "At least once every 7 years, the Secretary

shall review test procedures for all covered products and-amend test procedures with respect to

any covered product . or publish notice in the Federal Register of any determination not to

amend a test procedure." (42 U.S.C. 6293(b)(1)(A) DOE invites comment on all aspects of the

existing test procedures for fluorescent lamp ballasts for active mode energy consumption that

appear at Title 10 of the CFR Part 430, Subpart B, Appendix Q ("Uniform Test Method for

Measuring the Energy Consumption of Fluorescent Lamp Ballasts").

1 American National Standards Institute
 2

 "American National Standards for Fluorescent Lamp Ballasts - Methods of Measurement." Approved October 21,
 

1983.
 

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In a separate rulemaking proceeding, DOE is considering amending energy conservation
 

standards for fluorescent lamp ballasts (docket number EERE-2007-BT-STD- 0016; hereinafter

referred to as the fluorescent lamp ballast standards rulemaking''). DOE initiated that

rulemaking by publishing a Federal Register (FR) notice announcing a public meeting and

availability of the framework document ( Energy Efficiency Program for Consumer Products:

Public Meeting and Availability of the Framework Document for Fluorescent Lamp Ballasts,'') 

on January 22, 2008. 73 FR 3653. DOE has completed the preliminary analyses for the energy

conservation standard rulemaking and published in today's Federal Register a notice announcing

a public meeting and availability of the preliminary technical support document.

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

framework document for the fluorescent lamp ballast energy conservation standards rulemaking

(hereinafter referred to as the "2008 public meeting"). At that meeting, attendees also discussed

potential revisions to the test procedure for active mode energy consumption. All comments on

the fluorescent lamp ballast standards rulemaking regarding the measurement of active mode

energy consumption are discussed in section III of this proposed rulemaking.

DOE has also completed a standby mode and off mode test procedure. The Energy

Independence and Security Act of 2007 (Pub. L. 110-140) amended EPCA to require that, for

each covered product for which DOE's current test procedures do not fully account for standby

mode and off mode energy consumption, DOE amend the test procedures to include standby

mode and off mode energy consumption into the overall energy efficiency, energy consumption, 

or other energy descriptor for that product. If an integrated test procedure is technically

infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure, 

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if technically feasible. (EPCA section 325(gg)(2)(A); 42 U.S.C. 6295(gg)(2)(A)) DOE
 

published a final rule addressing standby mode and off mode energy consumption for fluorescent

lamp ballasts in the Federal Register on October 22, 2009. 74 FR 54445.

II. Summary of the Proposal 

In this notice of proposed rulemaking (NOPR), DOE proposes to modify the current test

procedures for fluorescent lamp ballasts to revise the scope of applicability of this test procedure

for consistency with the ongoing fluorescent lamp ballast standards rulemaking, improve

measurement variability, and update the referenced standards. DOE also proposes provisions for

manufacturers to submit compliance statements and certification reports for fluorescent lamp

ballasts. The following paragraphs summarize these proposed changes.

In the preliminary technical support document for the fluorescent lamp ballast standards

rulemaking, DOE makes a preliminary determination of the scope of coverage. Today's

proposed test procedure includes specific procedures for ballasts identified in the preliminary

determination of scope. If the scope of coverage changes in the fluorescent lamp ballast

standards rulemaking, DOE will add or remove provisions from the test procedure so that it is

consistent with the final scope of coverage of standards. The preliminary determination of scope

includes ballasts that operate multiple numbers of lamps (one through six), all values of ballast

factor, and many different lamp classes including 4-foot medium bipin T8 and T12 lamps, 4-foot

T5 miniature bipin lamps, 8-foot single pin slimline T8 and T12 lamps, and 8-foot recessed

double contact high output T8 and T12 lamps. See section III.A.1 for further detail.

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In addition to matching the scope of coverage for the active mode test procedure to the
 

scope of coverage being considered in the fluorescent lamp ballast standards rulemaking, the

proposed amendments seek to reduce the measurement variation inherent in the existing test

procedure. The existing test procedure exhibits variation in measurements of a similar magnitude

to the spread in efficiency within many fluorescent lamp ballast product classes analyzed in the

preliminary determination. The test measurement variation can be attributed to reference lamp

variation, lamp operation conditions, and ballast wiring. DOE believes a test procedure with 

reduced variation will allow for more precise standard setting and certification, compliance, and

enforcement testing.

DOE's proposed test method greatly reduces the impact of reference lamps on

measurement variation. The method calculates a ballast input power and output power using only

electrical measurements and resistors that simulate the load placed on a ballast by a fluorescent

lamp at a given operating condition. Because a resistor can be manufactured with much smaller

performance tolerances than a fluorescent lamp, the resistor introduces much less variation to the

operating characteristics of the ballast. This revised test method delivers increased precision, 

thereby allowing for greater resolution. The procedure proposed in this rulemaking measures

ballast input power and ballast output power and then calculates ballast electrical efficiency

(output power divided by input power). The ballast electrical efficiency is then converted to

ballast efficacy factor (BEF) using a transfer equation to maintain the reported metric for energy

efficiency as BEF for consistency with use of BEF in 42 USC 6295(g)(5) and (g)(8). DOE

developed the transfer equation by measuring several ballasts within a product class for ballast

efficiency (BE) using the proposed BE test procedure and for BEF using the existing test

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procedure, and then calculating a line of best fit for the combined data. This proposed method is

hereafter referred to as the resistor-based ballast efficiency test procedure.

Prior to selecting the proposed test method, DOE also considered three other methods as

potential improvements in the revised test procedure: (1) the lamp-based ballast efficiency

(correlated to BEF) method, (2) the existing BEF method with revisions to reduce variation; and

(3) the relative system efficacy (RSE) method. DOE's initial assessment of the lamp-based

ballast efficiency method, which uses a lamp as a load, rather than a resistor, indicated that, 

similar to the resistor-based ballast efficiency method, there could be significant improvements

by eliminating light output-based measurements. However, adopting that method would result in

a test procedure that was still susceptible to lamp-to-lamp variability. DOE explored the existing

light-output-based test procedure and found improvements could be made without making

fundamental changes. DOE believes that tightening tolerances on certain specifications and

clarifying loosely-defined directions can reduce measurement variation relative to the existing

test procedure for fluorescent ballasts, but to a lesser extent than the proposed resistor-based BE

test procedure. DOE found the RSE method to exhibit larger variation than the proposed resistorbased BE test procedure because it uses the same measurement techniques as the existing test

procedure.

In any rulemaking to amend a test procedure, DOE must determine "to what extent, if

any, the proposed test procedure would alter the measured energy efficiency . . . of any covered

product as determined under the existing test procedure." (42 U.S.C. 6293(e)(1)) If DOE

determines that the amended test procedure would alter the measured efficiency of a covered

product, DOE must amend the applicable energy conservation standard accordingly. (42 U.S.C.

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6293(e)(2)) The proposed test procedure would change the measured energy efficiency of some
 

products relative to the existing test procedure. To ensure that the standards developed in the

ongoing fluorescent lamp ballast standards rulemaking account for any changes to the test

procedure, DOE is developing the standards based on the measured energy efficiency generated

by the active mode test procedure proposed in this rulemaking. As a result, DOE proposes an

effective date for this revised test procedure, to be published as Appendix Q1 of 10 CFR part 430

Subpart B, concurrent with the compliance date of the fluorescent lamp ballast standards

rulemaking (approximately June 30, 2014). DOE plans to publish the final rule establishing the

procedures in Appendix Q1 in the same rule document as the final rule establishing any amended

standards.

DOE notes that ballasts that operate one or two 40 or 34 watt (W) 4-foot T12 medium

bipin lamps (F40T12 and F34T12), two 75 W or 60 W 8-foot T12 single pin slimline lamps

(F96T12 and F96T12/ES); and two 110 W and 95 W 8-foot T12 recessed double contact high 

output lamps (F96T12HO and F96T12HO/ES) are covered by existing energy conservation

standards. 10 CFR 430.32(m). Until the proposed effective date of the test procedure to be

published at Appendix Q1, these ballasts should continue to be tested using the existing test

procedure to determine compliance with existing standards. DOE proposes in this NOPR to

make minor updates to the existing test procedure, published at Appendix Q to Subpart B of part

430. DOE would update the reference to ANSI C82.2-1984 in the existing test procedure

(appendix Q) to ANSI C82.2-2002. Because DOE does not believe the updated standard will

impose increased testing burden or alter the measured BEF of fluorescent lamp ballasts, DOE

proposes that the amendments to Appendix Q be effective 30 days after publication of this test

procedure final rule. DOE notes that because use of the test method in Appendix Q1 is not

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appropriate for those ballasts that cannot operate a resistor load bank, manufacturers would
 

continue to test those ballasts using the test method set forth in Appendix Q. In addition, the test

procedures for any ballasts that operate in standby mode are also located in Appendix Q.

DOE also proposes amending the language in 10 CFR 430.62 to require fluorescent lamp

ballast manufacturers to submit compliance statements and certification reports. This provision

would also be effective 30 days after publication of this test procedure final rule. Ballast

manufacturers would begin to submit these documents to certify compliance with existing

fluorescent lamp ballast energy conservation standards using the test procedures at Appendix Q

one year following publication of this final rule. Ballast manufacturers would certify compliance

with any amended standards using the test procedures at Appendix Q1 beginning one year

following the compliance date of the amended standards.

III. Discussion

A. Scope of Applicability

1. Ballasts Covered

Today's proposed test procedure is applicable to the fluorescent lamp ballasts covered in

the preliminary determination of scope outlined in the preliminary technical support document

for the fluorescent lamp ballast standards rulemaking. The preliminary determination of scope is

as follows:

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

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

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nominal overall length of 48 inches, a rated wattage

3 of 25 watts (W) or more, and

an input voltage at or between 120 volts (V) and 277 V; 

(2) Ballasts that operate one, two, three, four, five, or six U-shaped lamps (commonly

referred to as 2-foot U-shaped lamps) with medium bipin bases, a nominal overall

length between 22 and 25 inches, a rated wattage of 25 W or more, and an input

voltage at or between 120 V and 277 V;

(3) Ballasts that operate one or two rapid-start lamps (commonly referred to as 8-foot

high output lamps) with recessed double contact bases, a nominal overall length 

of 96 inches and an input voltage at or between 120 V and 277 V;

(4) Ballasts that operate one or two instant-start lamps (commonly referred to as 8-

foot slimline lamps) with single pin bases, a nominal overall length of 96 inches, a

rated wattage of 52 W or more, and an input voltage at or between 120 V and 277

V; 

(5) Ballasts that operate one or two straight-shaped lamps (commonly referred to as

4-foot miniature bipin standard output lamps) with miniature bipin bases, a

nominal length between 45 and 48 inches, a rated wattage of 26 W or more, and

an input voltage at or between 120 V and 277 V;

(6) Ballasts that operate one, two, three, or four straight-shaped lamps (commonly

referred to as 4-foot miniature bipin high output lamps) with miniature bipin

bases, a nominal length between 45 and 48 inches, a rated wattage of 49 W or

more, and an input voltage at or between 120 V and 277 V; 

(7) Ballasts that operate one, two, three, or four straight-shaped lamps (commonly

referred to as 4-foot medium bipin lamps) with medium bipin bases, a nominal

overall length of 48 inches, a rated wattage of 25 W or more, an input voltage at

or between 120 V and 277 V, a power factor of less than 0.90, and designed and

labeled for use in residential applications; and

(8) Ballasts that operate one, two, three, four, five, or six rapid-start lamps

(commonly referred to as 8-foot high output lamps) with recessed double contact

bases, a nominal overall length of 96 inches, an input voltage at or between 120 V 

and 277 V, and that operate at ambient temperatures of 20 degrees Fahrenheit (OF) 

or less and are used in outdoor signs.

3 The July 14, 2009 final rule establishing amended energy conservation standard for general service fluorescent

lamps and incandescent reflector lamps (74 FR 34080) adopted a new definition for "rated wattage" that can be

found in 10 CFR 430.2. Please see

http://www1.eere.energy.gov/buildings/appliance standards/residential/incandescent lamps.html for further

information.

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For the proposed test procedure in this rulemaking, DOE would establish particular test
 

setups and calculations depending on the product class. When evaluating and establishing energy

conservation standards, DOE divides covered products into product classes by the type of energy

used, capacity, or other performance-related features that affect efficiency, considering factors

such as the utility of the product to users. (See 42 U.S.C. 6295(q)) The fluorescent lamp ballast

standards rulemaking delineates product classes based on the maximum number of lamps

operated by a ballast, ballast factor, starting method, lumen package,

4 lamp base, market sector, 

and lamp length. Ballasts contained in the same product class are subject to the same energy

conservation standards.

At the 2008 Framework public meeting for the fluorescent lamp ballast standards

rulemaking, the Appliance Standards Awareness Project (ASAP) asked DOE to elaborate on

how the schedules for the fluorescent lamp ballast energy conservation standard and active mode

test procedure rulemakings interact. (ASAP5

, Public Meeting Transcript, No. 9 at p. 29) Because

the fluorescent lamp ballast standards rulemaking is in the preliminary analysis phase of the

rulemaking process, the proposed scope of coverage is still in draft form. To ensure consistency

in the scope of coverage, DOE plans to publish the final rule for this test procedure rulemaking

concurrently with the ballasts standards rulemaking final rule (scheduled for June 30, 2011).

Concurrent publication affords DOE the opportunity to synchronize its test procedure with the

4 Lumen package refers to the quantity of light generated by a lamp and ballast system. For example, 8-foot RDC

high output HO lamps and 4-foot miniature bipin (MiniBP) HO lamps tend to operate at higher currents than 8-foot

single pin (SP) slimline lamps and 4-foot MiniBP standard output (SO) lamps, respectively. This difference in

operating design increases the quantity of light per unit of lamp length. 5 A notation in the form ASAP, Public Meeting Transcript, No. 9 at p. 29'' identifies a statement made in a public

meeting that DOE has received and has included in the docket of this rulemaking. This particular notation refers to a

comment: (1) submitted during the public meeting on February 6, 2008; (2) in document number 9 in the docket of

this rulemaking; and (3) appearing on page 29 of the transcript.

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final scope of coverage for the fluorescent lamp ballast standards rulemaking. If a ballast type

6 is

removed from the scope of coverage, DOE will eliminate the pertinent test procedures from the

active mode test procedure in the final rule. Conversely, in the event additional ballasts are

added to the scope of coverage, DOE will develop test procedures for these ballasts and update

the active mode test procedure in a subsequent rulemaking. For example, in the preliminary

analyses of the fluorescent lamp ballast standards rulemaking, DOE's preliminary scope of

coverage that does not include ballasts capable of dimming. As DOE invites comment on this in

the fluorescent lamp ballast standards rulemaking, if DOE's final scope of coverage includes

dimming ballasts, DOE will need finalize test procedures for these ballasts. DOE also invites

comment in this test procedure rulemaking on suggested methods of measuring the efficiency of

dimming-capable ballasts.

2. Effective Date

Because some of the test procedure amendments proposed for Appendix Q1 will change

measured efficiency and therefore affect compliance with existing standards, DOE proposes an

effective date of the revised test procedure in Appendix Q1 to Subpart B concurrent with the

compliance date of the energy conservation standards prescribed by the fluorescent lamp ballast

standards rulemaking. DOE also plans to publish the final rule establishing the procedures in

Appendix Q1 in the same rule document as the final rule establishing any amended standards. In

the fluorescent lamp ballast standards rulemaking, DOE is developing standards that correspond

with the active mode test procedure proposed in this rulemaking. The proposed active mode test

procedure would be used to test ballast efficiency on or after the compliance date of the

6 Ballast type refers to a grouping of ballasts that use the same starting method, and operate lamps of the same

diameter, lumen package, base type, and length. For example, instant-start ballasts that operate 4-foot medium bipin

T8 lamps.

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fluorescent lamp ballast standards rulemaking (approximately June 2014). Until this compliance
 

date, fluorescent lamp ballasts would continue to be tested using the existing test procedure in

Appendix Q to determine compliance with existing standards. Because the modifications to

Appendix Q (an update to referenced industry standards) do not affect the measured efficiency, 

DOE proposes that they be effective 30 days after publication of this test procedure final rule.

DOE notes that because use of the test method in Appendix Q1 is not appropriate for those

ballasts that cannot operate a resistor load bank, manufacturers would continue to test those

ballasts using the test method set forth in Appendix Q. In addition, the test procedures for any

ballasts that operate in standby mode are also located in Appendix Q.

Certification and compliance procedures for fluorescent lamp ballasts are also proposed

in this rulemaking. Because these provisions also do not affect measured efficiency, DOE

proposes that they be effective 30 days after publication of this test procedure final rule.

Accordingly, manufacturers of fluorescent lamp ballasts would be required to submit compliance

statements and certification reports to certify compliance with existing standards, using the test

procedures at Appendix Q, one year following publication of the test procedure final rule.

Ballast manufacturers would certify compliance with any amended standards using the test

procedures at Appendix Q1 beginning one year following the compliance date of the amended

standards.

B. Existing Test Procedure

The existing ballast test procedure (in Appendix Q to Subpart B of 10 CFR part 430) used

to determine the energy efficiency of a fluorescent lamp ballast is based on light output

measurements and ballast input power. The metric used is called ballast efficacy factor (BEF).

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BEF is 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. 42 U.S.C. 6291(29)(C) 

The BEF metric uses light output of the lamp and ballast system instead of ballast

electrical output power in its calculation of the efficiency of a ballast. To measure relative light

output, ANSI C82.2-1984 directs the user to measure the photocell output

7 of the test ballast

operating a reference lamp and the light output of a reference ballast operating the same

reference lamp. Dividing photocell output of the test ballast by the photocell output of the

reference ballast yields relative light output or ballast factor (BF). Concurrent with measuring

relative light output, the user is directed to measure ballast input power. BEF is then calculated

by dividing relative light output by input power. A ballast that produces more light than another

ballast with the same input power will have a larger BEF.

C. Drawbacks of Existing BEF Test Procedure

In response to the framework document for the fluorescent lamp ballast standards

rulemaking, DOE received numerous written and verbal comments from interested parties on the

usage of ballast efficacy factor as the metric for describing the energy consumption of

fluorescent lamp ballasts. The National Electrical Manufacturers Association (NEMA) 

commented that in previous rulemakings regarding efficiency of ballasts, the variation in BEF

measurements was less of an issue because the range of efficiency in the market was much 

larger. The spread in the measured energy efficiency between magnetic and electronic ballasts, 

7 The photocell output of a light source is measured in units of watts. Photocell output (watts) is one method of

measuring the light output of a light source. Through the remainder of this document, DOE refers to the output of a

fluorescent lamp as "light output," even though the existing test procedure indicates measuring the light with 

photocell output.

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for example, was much larger than the measurement variation inherent to the existing test
 

procedure. However, in the current market, the spread in efficiency between ballasts has a much 

smaller range. (NEMA, Public Meeting Transcript, No. 9 at p. 23, pp. 56-57) NEMA commented

that DOE should change the metric away from BEF because BEF measurements made in

accordance with the current fluorescent lamp ballast test procedure (appendix Q) can be shown

to have a measurement uncertainty on the order of 5 percent. NEMA stated that when measuring

the same ballast at different test laboratories with different examples of the same reference lamp, 

the spread in test results is similar to the range of T8 ballast BEFs observed in the market today.

NEMA reasoned that in order to have meaningful verification of a standard DOE would need a

metric that delineates between the products on the market. According to NEMA, the ballast

industry would be challenged to come to consensus on a standard when so much variation

existed in the data. (NEMA, Public Meeting Transcript, No. 9 at p. 23, pp. 35-36, pp. 56-58; 

NEMA8

, No. 11 at p. 2) 

DOE understands NEMA's concerns regarding the measurement uncertainty related to

the BEF measurement method under the existing fluorescent lamp ballast test procedure. The

measurement uncertainty would negatively impact DOE's ability to set standards for ballasts, as

it could be difficult to distinguish between typical and high-efficiency ballasts. DOE agrees with 

NEMA's description that the range of efficiencies of ballasts available in the market have in

general decreased and acknowledges the need for a test method or metric that reduces systematic

error and generates more reliable test results. Reduced variation in test procedure calculations

8 A notation in the form NEMA, No. 11 at p. 2'' identifies a written comment that DOE has received and has

included in the docket of this rulemaking or a written docket submission. This particular notation refers to a

comment: (1) Submitted by NEMA; (2) in document number 11 in the docket of this rulemaking; and appearing on

page 2.

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will allow for more precise standard setting and certification, compliance, and enforcement
 

testing. DOE is proposing a test procedure that is designed to reduce systematic error and

enhance energy conservation standard-setting capabilities.

NEMA also stated that lamp manufacturing variations will create variations in measured

BEF values. (NEMA, Public Meeting Transcript, No. 9 at p. 38; NEMA, No. 11 at p. 6; GE, 

Public Meeting Transcript, No. 9 at p. 43) DOE agrees that a number of factors, in particular the

manufacturing variability of lamps, can contribute to producing this uncertainty. Due to lamp

manufacturing variability and in order to reduce the performance variation among those lamps

selected for testing, industry standards referenced in the test procedure specify a narrower range

of operating conditions for reference lamps. ANSI C82.1-1977 (referenced by ANSI C82.2-

1984) specifies that a reference lamp must not vary more than 2.5 percent from the lamp

parameters given in the ANSI C78 Series (1972 edition and 1975 supplement) for fluorescent

lamp electrical characteristics. Even this narrowed variation allowed in the measured lamp

power, however, has a significant impact on the variation in BEF. Changes in measured lamp

input power result in disproportionate changes to the numerator (ballast factor) and the

denominator (input power) in the BEF metric. The percent change in ballast factor is not as great

as the percent change in ballast input power for a given change in measured lamp input power.

Consequently, the same ballast will generate different values of BEF when tested on reference

lamps with different measured power.

GE commented that in addition to reference lamp manufacturing variation, BEF can vary

depending on the testing facility. (GE, Public Meeting Transcript, No. 9 at p. 43) DOE agrees

that deviations in test facility environmental conditions can result in dissimilarities in measured

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BEF. ANSI C82.2-1984 (incorporated in the existing test procedure) allows ambient temperature

to vary ± 1 degrees Celsius (OC) from 25 OC. Through testing, DOE has shown ambient

temperature to have an effect on BEF measurements. Specifically, DOE found that changes in

ambient temperature as small as 1 OC resulted in changes in BEF as much as 1.5 percent.

NEMA commented that the BEF measurement requires photometric measurements of a

reference lamp attached to the test ballast; thus, BEF values cannot be compared across ballasts

that operate different lamp types. A more appropriate metric would not depend on lamp

parameters or requirements. (NEMA, Public Meeting Transcript, No. 9 at p. 38, pp. 124-125; 

NEMA, No. 11 at p. 6) NEMA also stated that an alternative metric that is comparable across all

instant-start or programmed-start ballasts and capable of including lamp types yet to be

developed would be preferable to the existing test procedure using BEF. (NEMA, Public

Meeting Transcript, No. 9 at pp. 76-77, p. 99) NEMA further commented that some lamps do not

have ANSI standards governing their operating characteristics. Considerable variation in lamp

operating conditions exists among manufacturers for these lamps because the industry has not

reached a formal consensus. (NEMA, Public Meeting Transcript, No. 9 at pp. 76-77) NEMA

suggested that DOE consider an alternative metric based on measuring ballast input and output

electrical power as discussed in section III.E. (NEMA, Public Meeting Transcript, No. 9 at p. 32, 

pp. 37-38)

DOE recognizes that BEF is not comparable across all ballasts. BEF is measured and

calculated using fluorescent lamps that vary in measured power, thereby impacting ballast input

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power. As a consequence, BEF is dependent on lamp type9

. DOE plans to organize the covered

ballasts into different product classes based on consumer utility and energy efficiency

differences. Because DOE will consider a separate energy conservation standard for each of

these product classes, the test procedure must make comparisons in energy efficiency possible

within a product class. However, the existing BEF method does not allow for such comparisons

in all circumstances, as explained in the following paragraph. DOE recognizes that comparison

across product classes may also be useful for consumers of fluorescent lamp ballasts. DOE

addresses this issue in its discussion of the resistor-based BE method in section III.E.1.

In the ongoing fluorescent lamp ballast standards rulemaking, DOE has tentatively

determined there is no distinct consumer utility difference between T8 and T12 ballasts. As a

result, DOE is considering grouping T8 and T12 ballasts in the same product class. Due to the

difference in rated powers of the reference lamps, however, measured BEF values for T8 and

T12 ballasts are not comparable. Because DOE plans to subject certain T8 and T12 ballasts to

the same energy conservation standard (by including these ballasts in the same product class), 

DOE agrees that amendments to the existing active mode test procedure to allow for greater

comparability across lamp types is warranted. Therefore, in this notice DOE proposes to revise

the test procedure such that the reported BEF for a T12 ballast will be comparable to the reported

BEF for a T8 ballast. These proposed revisions are discussed in further detail in section III.F.5.

DOE also agrees that the revised test procedure and metric should be able to encompass

newly-developed lamps. The industry has not come to consensus on operating specification

standards for some of these new, reduced-wattage lamps. Without consistent industry standards

9 Lamp type describes a grouping of lamps that have the same length, lumen package, base type, and diameter.

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for lamps, light-output-based testing of BEF can vary greatly. DOE proposes to test ballasts
 

while operating one representative load, characterizing the lamp wattage most commonly

operated. The development and marketing of new, reduced-wattage lamps (with or without ANSI

standards) is not a concern because today's test procedure proposes to specify a particular lamp

and ballast combination for testing. See section III.F.2 for additional detail on DOE's

preliminary decision to test ballasts while operating a load characteristic of the most common

wattage lamp.

NEMA commented that lamp filament heating introduces variability into the existing

BEF measurement (NEMA, Public Meeting Transcript, No. 9 at p. 39). DOE agrees the existing

ballast test procedure is unclear on whether or not electrode heating should be used in the

reference circuit. Electrode heating is known to increase the efficiency of a lamp, which means

the same amount of input power produces more light. Consequently, the ballast factor of a test

ballast tends to be smaller if the reference circuit uses electrode heating compared to a reference

circuit without electrode heating. DOE agrees that the current test procedure inserts some

variability into the measurement of BF and consequently BEF due to the apparent flexibility in

the use of reference circuit heating. In today's proposed test procedure, DOE addresses this issue

by specifying that electrode heating should always be used in the reference circuit for medium

bipin, recessed double contact, and miniature bipin lamps. Electrode heating should not be used

in the reference circuit for single pin lamps. As discussed in section III.E.3, DOE believes

specifying whether electrode heating should be used in the reference case limits opportunity for

introducing variation in the test procedure. DOE also understands that the efficiency change due

to electrode heating may vary from lamp to lamp. DOE believes the variation to be relatively

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small, though it does not have quantitative data to characterize this variation among lamps. DOE
 

invites comment on reasonable techniques to reduce this source of variation.

NEMA also commented that filament heating should be taken into account in comparison

of ballasts with different starting methods. (NEMA, Public Meeting Transcript, No. 9 at p. 39) 

DOE is aware starting method can impact the measurement of ballast output power. Ballasts that

employ constant electrode heating generate smaller BEF values than ballasts without constant

electrode heating. Because BEF considers the light output of a ballast, constant cathode heating

tends to decrease BEF because some of the ballast output power is used for purposes other than

light production. From a system viewpoint, however, BEF reflects the loss in lighting efficiency

due to electrode heating. Contrary to NEMA, DOE does not believe that power dissipated by the

lamp electrodes should be included in the measurement of output power as this power is not used

directly toward the primary function of producing light. DOE notes that it will consider setting

specific standards for ballasts that employ electrode heating based on any potential consumer

utility differences10 in the ongoing fluorescent lamp ballast standards rulemaking.

NEMA also indicated T8 ballasts are particularly impacted by measurement uncertainty

because much of the T8 ballast market is high-frequency electronic and T8 lamps are first

operated on a low-frequency (60-hertz) reference ballast during BEF testing. NEMA asserted

that lamps increase in efficiency when switching from low- to high-frequency operation, but that

10 In the fluorescent lamp ballast standards rulemaking, DOE has tentatively determined that while rapid-start

ballasts do not offer distinct utility compared to instant-start ballasts, programmed-start ballasts do offer distinct

utility compared to instant-start ballasts. DOE found that consumers frequently use rapid-start ballasts as

replacements for instant-start ballasts. Programmed-start ballasts, however, can increase lamp lifetime for frequent

on/off cycling applications (e.g. for use with occupancy sensors), providing consumer utility. Therefore, DOE has

tentatively determined to group rapid-start ballasts and instant-start ballast in the same product class and place

programmed-start ballasts in a separate product class.

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all lamps will not gain exactly the same amount of efficiency. NEMA mentioned it could provide
 

data to show error of several percent when the same ballast is tested at different labs with 

different lamps due to the high-frequency to low-frequency comparison. (NEMA, Public

Meeting Transcript, No. 9 at p. 26, p. 39) 

DOE agrees that random error is introduced into the measurement and calculation of BEF

due to variation in lamp efficiency gains when switching from magnetic to electronic ballasts. In

general, when a lamp is run at high-frequency (electronic ballasts), the lamp requires less power

to produce the same amount of light when compared to a low-frequency (magnetic) ballast.

Electronic ballasts run at high frequency, so they tend to display higher BEF values than lowfrequency magnetic ballasts. Part of this difference is due to the lamp operating at a lower rated

wattage (increased efficiency), while the remainder is due to improvements in the electrical

efficiency of the ballast. ANSI does not specify high-frequency reference conditions for 32W 

F32T8, 60W F96T12/ES, 95W F96T12HO/ES, and 110W F96T12HO fluorescent lamps.

Another source of variation in the existing test procedure is lamp and ballast wiring for

rapid- and programmed-start ballasts. These ballasts have two wires connected to the pins on

each end of the lamp. One of the two wires supplies power to the lamp arc, and the second

provides power to the electrode. Depending on which pin the lamp arc wire is connected to, the

current supplied to the lamp arc will encounter different amounts of resistance. The difference in

resistance is due to the position on the lamp electrode where the current starts and finishes the

lamp arc. When this position (hotspot) is in the center of the electrode, wiring differences do not

change the measured BEF. However, when the hotspot is closer to one end or the other of the

electrode, the current encounters varied resistances based on the distance it must travel through 

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the electrode. Because ballast wires are not identified as delivering energy to the lamp arc or
 

electrode and the position of the hotspot is unknown, this source of variation cannot be

eliminated.

At the framework document public meeting, DOE received comments that ballast

manufacturers and independent test labs use light output measurements for calculating ballast

factor for both rapid-start and instant-start ballasts. (GE, Public Meeting Transcript, No. 9 at p.

73; Philips, Public Meeting Transcript, No. 9 at p. 74) ANSI C82.2-1984 suggests the usage of

power measurements for instant-start systems, but common industry practice has been the usage

of light output measurements for all ballast starting methods. Ballast factor can be calculated

either as a ratio of test and reference circuit light output or as a ratio of measured lamp power.

DOE notes that power measurements are somewhat impractical to conduct on ballasts that

employ electrode heating because these ballasts use two wires to connect to a lamp electrode.

The presence of additional wires requires more measurements to determine output power which 

introduces error into the results. DOE believes this technique introduces significant error through 

capacitance to ground and loading effects on ballasts that use electrode heating. As discussed in

section III.E.3, DOE believes that one way to reduce this error would be to require light-output

measurements to be used for all ballast types.

D. Efficiency Metric for Fluorescent Lamp Ballasts

A joint comment (hereafter the "Joint Comment") submitted by ASAP, the American

Council for an Energy-Efficient Economy (ACEEE), the Alliance to Save Energy (ASE), the

Natural Resources Defense Council (NRDC), the Northeast Energy Efficiency Partnerships

(NEEP), and the Northwest Power and Conservation Council (NPCC) suggested that DOE

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consider a metric other than BEF that permits comparison between different lamp wattages, 

ballast types, and numbers of lamps operated by a ballast. (Joint Comment, No. 12 at p. 1) 

NEMA also recommended that DOE consider changing the metric away from BEF and toward

an alternate metric. (NEMA, No. 11 at p. 2, pp. 11-12) NEMA suggested if DOE cannot change

the metric from BEF, it should develop a test procedure that requires the measurement of some

other metric unrelated to lamp lumen output, such as ballast efficiency11 or relative system

efficacy12

, and then give correlations to BEF so that BEF can still be used in standard-setting.

The New York State Energy Research and Development Authority (NYSERDA) also

recommended consideration of RSE as an alternative metric. (NYSERDA, No. 9, pp. 27-28) 

NEMA asked if DOE might accept a NEMA- and ANSI-supported method of measuring BE, 

and correlating BE measurements with BEF values. (NEMA, Public Meeting Transcript, No. 9 at

p. 32, pp. 37-38)

The energy conservation standard is specified using the metric of ballast efficacy factor.

42 USC 6295(g)(5), (g)(8) In this rulemaking, DOE proposes measuring an alternate metric

(ballast efficiency) and using a set of correlation functions so that BEF values can be reported.

Acuity Brands Lighting also commented that much of the marketplace (end-users, 

lighting designers, architects, and electrical engineers) do not use the BEF metric and may not

have knowledge of it. Acuity Brands indicated that luminaire manufacturers are the primary

users of BEF values, using them in ballast purchasing decisions for selection of products

11 Ballast efficiency aims to capture the electrical efficiency of a ballast by eliminating usage of lamps and

photometric measurements in the test method. Ballast efficiency equals ballast output power divided by ballast input

power. See section III.E.4.

12 Relative system efficacy provides a greater range of comparability among ballast types in comparison to ballast

efficacy factor. RSE is based on the BEF metric and creates minimal incremental testing burden. See section III.E.4.

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compliant with regulations. Acuity Brands also indicated that a change in metric would not
 

impact the end-user as much it may impact luminaire manufacturers. (Acuity Brands Lighting, 

Public Meeting Transcript, No. 9 at pp. 45-46) DOE understands that the lighting design process

involves metrics other than BEF. Lamp, ballast, and luminaire combinations may be more or less

efficient when analyzed as a complete system. End-users may make their purchasing decisions

from this system viewpoint. DOE appreciates this comment; however, DOE proposes the use of

transfer equations to convert BE values to BEF for consistency with use of the BEF metric in 42

USC 6295(g)(5) and (g)(8).

The Joint Comment suggested that an alternate metric should account for all power loads

served by the ballast, including lamp arc power, cathode power, and standby power

consumption. (Joint Comment, No. 12 at p. 1) DOE understands the importance of capturing all

power loads served by a fluorescent lamp ballast. DOE notes that BEF does capture all power

modes listed by the Joint Comment (lamp arc power and cathode power) except for standby

mode consumption. However, DOE does not believe it is feasible to incorporate standby power

into the BEF metric. The BEF metric relates light output (relative to a reference system) to input

power. Ballasts that produce more light using the same input wattage have a larger BEF value.

Standby mode power, however, performs a different function. Instead of using power for light

output, standby mode power is used to facilitate activation or deactivation of other functions

(active mode functions, i.e., light output) by a remote switch. Because BEF is a measure of light

output divided by input power and not energy consumption, DOE does not believe it is feasible

to incorporate a measure of standby mode energy use into the BEF metric for active mode energy

consumption. While DOE's preliminary determination of the scope of coverage in the

fluorescent lamp ballasts standards rulemaking does not include ballasts capable of operating in

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standby mode, if the scope of coverage changes to include these ballasts, DOE will set separate
 

standby mode energy conservation standards. Test procedures for the measurement of standby

mode energy consumption for fluorescent lamp ballasts can be found in Appendix Q.

E. Test Procedure Improvement Options

Given that alternative methods of testing may result in reduced measurement variation

compared to the existing test procedure for BEF, DOE considered three new methods for

measuring the efficiency of a ballast and one improved version of the existing method. The first

method is called the resistor-based ballast efficiency method, and requires first measuring an

estimate of ballast electrical efficiency when operating a resistor load and then converting the

estimate to BEF. The second method, called the lamp-based ballast efficiency method, involves

measuring ballast efficiency using a lamp as the ballast load and then converting that BE to BEF.

The third method makes small changes to the existing test procedure to improve the precision of

BEF measurement. The fourth method measures relative system efficacy, which is a variation of

ballast efficacy factor that is more comparable across ballast types. While DOE proposes the first

method to be used as the new test procedure for determination of fluorescent lamp ballast energy

consumption, DOE is still considering all of these options for improvement of the test procedure

and therefore invites comments on all alternative methods. The following sections discuss the

merits and drawbacks of the four methods.

1. Resistor-Based Ballast Efficiency Correlated to Ballast Efficacy Factor

NEMA suggested at the framework document public meeting for the fluorescent lamp

ballast standards rulemaking that DOE should consider using the BE metric. (NEMA, Public

Meeting Transcript, No. 9 at p. 32, pp. 37-38) Following the public meeting, DOE participated in

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the NEMA task force on ballast efficiency through June 2009. Through a series of conference
 

calls and meetings, DOE learned about the resistor-based BE method and participated in its

development for four-foot 32W MBP T8 normal ballast factor ballasts. Using the data gathered

and methodology used in the NEMA task force DOE then continued development of the

proposed test procedure for other lamp types. DOE defined additional resistor values, conducted

extensive testing for both BE and BEF in many product classes, created transfer equations so that

BEF values could be reported, and specified instrumentation specifications in its development of

the proposed test procedure.

Ballast efficiency equals lamp arc power divided by ballast input power. Ballast

efficiency aims to capture the electrical efficiency of a ballast by eliminating usage of lamps and

photometric measurements. Instead of using a lamp and measuring light output, the resistorbased BE method uses resistors (a resistor load bank) to simulate the lamp and makes an

electrical measurement of power through the arc-resistor. Because a resistor can be manufactured

with much smaller performance tolerances than a fluorescent lamp, the resistor introduces much 

less variation into the operating characteristics of the ballast.

NEMA commented that a BE measurement does not require lamp electrical and

photometric measurements and, thus, is both easier to execute and more accurate. NEMA also

stated that BE measurements have lower measurement variation (on the order of 1 to 2 percent) 

between test facilities and do not require ANSI standards for lamps that the ballast is designed to

operate. NEMA believes that the ballast efficiency metric could be used to compare all ballasts

of a given type (e.g., all instant-start ballasts, all programmed-start ballasts), regardless of the

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lamp types that the ballasts support (including lamp types yet to be developed). (NEMA, Public

Meeting Transcript, No. 9 at pp. 25-27, p. 36, pp. 76-77, pp. 100-101) 

DOE agrees that ballast efficiency would likely show less variation than BEF and would

allow for more equitable comparison among ballasts operating different numbers of lamps or

lamp wattages. As discussed in section III.C, much of the variation inherent in the existing test

procedure is due to variation among reference lamps. The resistor-based BE method reduces

much of the measurement variation due to reference lamps by using a resistor load bank to

simulate the load placed on a ballast during the measurement of input and output power.

Decreased measurement variation allows for more precise standard setting and certification, 

compliance, and enforcement testing. DOE acknowledges that the BE metric would allow for

comparability across large portions of the ballast market and that such comparability provides

benefit to consumers. DOE proposes conversion to BEF values, however, to measure energy

efficiency in a repeatable manner that provides comparison for products in the same product

class and that is also consistent with the statutory metric set forth at 42 USC 6295(g)(5) and

(g)(8).

DOE notes that use of ANSI standards would be required for lamps in today's proposed

test method because of the need to define the ballast factor of a ballast. Ballast factor is a

necessary input to the transfer equations between BE and BEF as discussed in section III.F.5.

Because DOE proposes to test a ballast using only one lamp type, however, new lamps without

ANSI standards will not affect the test procedure. The test procedure indicates using currentlyavailable and ANSI-specified lamps for the measurement and calculation of ballast factor.

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While NEMA commented that BE is the best descriptor for instant-start energy efficiency
 

measurements, NEMA also stated that electrode heating effects should be taken into account for

rapid-start and programmed-start systems (NEMA, Public Meeting Transcript, No. 9 at pp. 37-

39). The use of electrode heating impacts the ratio of ballast input power to power dissipated in

the lamp arc. Unlike instant-start ballasts, programmed-start and rapid-start ballasts use a portion

of the ballast input power to heat the electrodes. Ion bombardment at the electrode (known as

sputtering) during the voltage pulse deteriorates the lamp electrode over time. Electrode heating

reduces the magnitude of the voltage pulse required to start a lamp, thereby increasing lamp

lifetime for applications that require frequent on and off switching. Because the resistor-based

BE test method measures only the power across the lamp arc resistor, measured output power

(lamp arc power) for ballasts such as rapid-start and some programmed-start ballasts tends to be

smaller than the true total ballast output power. Instant-start ballasts are less affected by this

issue because these ballasts do not employ electrode heating. From a lighting efficiency

perspective, the BE metric captures the percentage of input power utilized for lighting in the

output stage. DOE believes accounting for output power in this way is useful because it does

indicate that instant-start ballasts use a greater percentage of input power in the direct production

of light. The fluorescent lamp ballast standards rulemaking will consider the impact of starting

method on consumer utility and will set energy conservation standards accordingly.

DOE investigated the possibility of measuring the total output power of a ballast for the

BE metric to include electrode heating and lamp arc power. To measure the total output power

across the entire resistor load bank, a user needs to measure the electrode and lamp arc voltage

separately. DOE found this measurement to introduce too much error through capacitance to

ground and loading effects on the ballast during high-frequency operation. Accordingly, DOE

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has tentatively concluded that reducing the number of measurements to ensure a more accurate
 

measurement is the more reasonable approach. Therefore, DOE proposes measuring the voltage

drop across the lamp arc resistor and the input current to the resistor load bank to calculate

output power for the ballast efficiency metric.

GE commented that ballast manufacturers do not have control over the performance of a

lamp or the measurement variation associated with the usage of reference lamps in the existing

test procedure. GE noted that the resistor-based BE metric allows ballast designers to meet a

specification that is independent of lamp variation. (GE, Public Meeting Transcript, No. 9 at p.

43) DOE understands that ballast designers would prefer ballast energy efficiency to be

measured independently from a lamp. DOE agrees that measured BEF is subject to variations in

measured lamp wattage and intends to reduce this source of variation. Today's proposed test

procedure reduces the effect of reference lamp variation on variation in BEF.

DOE also believes that industry is starting to adopt BE method. NEMA has already

initiated the usage of BE in its Premium Ballast Program, where BE is used in an alternative

verification procedure. NEMA invited DOE and other interested parties to participate in the

investigation process of the BE metric. (NEMA, Public Meeting Transcript, No. 9 at p. 41, pp.

48-50, p. 53; NEMA, No. 11 at p. 3) In particular, NEMA indicated that it has been studying the

measurement variation of ballast efficiency through ballast testing and wished to collaborate

directly with DOE. NEMA went on to mention that lamp manufacturers as well as the technical

coordinators for ANSI C82.11 and the ANSI C82.11 Annex are involved and that lamp

manufacturers are aware of the BE effort and have not voiced any resistance to the concept.

(NEMA, Public Meeting Transcript, No. 9 at pp. 23-25, p. 42, p. 45, p. 48, pp. 54-55) ASAP

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stated that DOE's participation could speed the metrics replacement process and that the
 

presence of non-industry experts would increase ASAP's confidence in the new metric. (ASAP, 

Public Meeting Transcript, No. 9 at p. 47, p. 49) 

DOE participated in the NEMA task force on ballast efficiency by taking part in

conference calls, providing technical expertise, and participating in ballast testing. NEMA

measured ballast efficiency using the resistor-based BE method through a round robin activity

(involving multiple ballast manufacturers and independent test labs) for ballasts that operate

32W, 4-foot medium bipin T8 lamps. Using these data, the task force honed the details of the test

method and examined the level of variation present in the data. DOE's involvement with the

NEMA task force was for the purpose of participating in round robin testing. Once testing was

complete, DOE finalized development of today's proposed test procedure.

DOE believes the resistor-based ballast efficiency method reduces measurement

variation, in comparison to the existing test method, to a greater extent than RSE or the improved

light-output-based test procedure. DOE prefers a test procedure with reduced variation as it will

allow for more precise standard setting and certification, compliance, and enforcement testing.

DOE invites comment on the effectiveness of the resistor-based BE test method and its expected

improvement in measurement variation.

2. Lamp-Based Ballast Efficiency Correlated to Ballast Efficacy Factor

As an alternative to the resistor-based ballast efficiency method (with results correlated

through transfer equations to BEF) discussed in the previous section, DOE also considered using

a similar method using a lamp (rather than a resistor load bank) as the ballast load. This

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arrangement has several potential advantages over today's proposed method. As ballasts are
 

designed to operate lamps, not resistors, testing the efficiency of a ballast while operating a lamp

may provide for a more accurate representation of power consumption and efficiency than when

operating a resistor. For example, a lamp is a dynamic load which changes impedance in

response to being operated at different powers. In order to account for this effect using the

resistor-based ballast efficiency method, DOE proposes using separate resistors for different bins

of ballast factor (as discussed in section III.F.5). Using a lamp load to test ballast efficiency, 

would allow manufacturers to use a single lamp to act as the appropriate load for ballasts of all

ballast factors. Also, as discussed in section III.F.8, DOE found that several ballasts are

incompatible with the resistor-based method of testing ballast efficiency. In order to provide a

viable test procedure for these ballasts, DOE proposes that manufacturers use the light outputbased test to measure BEF directly. Using lamp-based ballast efficiency method could maintain

a consistent testing procedure across these ballast types. Below is a brief summary of the lampbased ballast efficiency (correlated to ballast efficacy factor) test method.

Similar to the resistor-based ballast efficiency method, in the lamp-based ballast

efficiency method, input and output power measurements would be simultaneously taken by the

technician while the ballast is operating a lamp (specified by the test procedure). To calculate

ballast efficiency, the technician would divide the measured output power by the measured input

power. More specifically, a lamp would be seasoned at least 12 hours prior to testing to ensure

stable electrical characteristics. The lamp and ballast pairing would be selected based on DOE's

determination of the most common wattage lamp a ballast operates and the maximum number of

lamps a ballast is designed to operate. The lamp or lamps, selected for consistency with the

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specifications in ANSI C78.81-2005, would be mounted in a standard strip fixture according to
 

ANSI C82.1-2004 and ANSI C78.81-2005. Ballast and output power would be measured using a

suitable power analyzer and current probe. DOE would consider the same specifications as

proposed the resistor-based method as follows. Instrumentation for current, voltage, and power

measurements would be selected in accordance with ANSI C78.375-1997 Section 9, which 

specifies that instruments should be "of the true RMS type, essentially free from wave form

errors, and suitable for the frequency of operation." Instrument performance could be further

specified within the guidelines of the ANSI C78.375-1997 and ANSI C82.2-2002. Specifically, 

current would be measured using a galvanically isolated current probe/monitor with frequency

response between 40 Hertz (Hz) and 20 MHz. In addition, voltage would be measured directly

by a power analyzer with a maximum 100 picofarad (pF) capacitance to ground and have

frequency response between 40 Hz and 1 MHz.

Once the ballast is connected to the lamp and fixture, the ballast would be energized at its

highest rated input voltage and the lamp and ballast system would be stabilized for up to one

hour (at least fifteen minutes) as determined in ANSI C78.375-1997. Within one hour of

energizing the ballast and after the lamp and ballast system have stabilized, the technician would

record the input power and sum of the output powers measured for each lamp. The technician

would then divide the total output power by the input power to yield BE. Finally, if DOE were to

adopt the lamp-based BE method, similar to the resistor-based BE method, DOE would establish 

correlation relationships between BE and BEF.

While DOE recognizes the several advantages to the lamp-based BE method (discussed

earlier), DOE tentatively believes that testing for BE using resistor load instead of a lamp load

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would result in reduced measurement variation by eliminating lamp-to-lamp variability. At this
 

time, DOE does not have test data to support the validity of the lamp-based BE method or for the

generation of appropriate transfer equations to correlate lamp-based BE to BEF. DOE requests

additional information on this alternative lamp-based BE method, including repeatability and

reproducibility statistics and test data. DOE also invites comment on the burden that the lampbased BE method imposes for testing.

3. Improvements to Existing Test Procedure

As an alternative to the ballast efficiency methods (with results correlated through 

transfer equations to BEF), DOE considered modifying certain aspects of the existing test

procedure. DOE believes that some of the measurement variation inherent in the existing test

procedure can be reduced without making fundamental changes. The measurement variation in

BEF can be attributed to operating conditions, electrode heating in the reference circuit, variation

in measured power of reference lamps, inconsistent output power measurements in determining

ballast factor, and ambient temperature. DOE investigated methods for improving the

requirements governing these specifications.

The Illuminating Engineering Society of North America (IESNA) Lighting

Measurements Testing & Calculation Guide (LM) IESNA LM-9-1999 describes several options

for operating a reference lamp. DOE believes that the industry is not uniform in its selection of

operating conditions, which results in potential for varied BEF measurements. Under

Electrical Settings (section 8.0), IESNA LM-9-1999 states "measurements may be taken with the

lamp operating and stabilized at the specified input volts to the reference circuit or, alternatively, 

measurements may be taken with the lamp stabilized, at the rated lamp power or at a specified

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current." These different operating conditions can lead to varying reference ballast light outputs
 

for the calculation of ballast factor. For example, if the reference ballast operates the reference

lamp such that it produces less light, the ballast factor and BEF of the test ballast will increase. If

ballast operators run the reference circuit only at the specified input voltage to the reference

circuit, DOE believes the test procedure will be more reproducible between test facilities because

only a single operating condition will be permitted. DOE believes using the specified input

voltage to the reference circuit is the best option because it is the most common operating

condition used by industry and simplest to execute. DOE also notes that the most recent test

procedure final rule for general service fluorescent lamps also specifies testing lamps at a

constant and specified input voltage. 74 FR 31829, 31834 (July 6, 2009).

The existing ballast test procedure is unclear as to whether electrode heating should be

used in the reference circuit. Electrode heating is known to increase the efficiency of a lamp, 

which means the same amount of input power produces more light. Compared to a reference

circuit that employs electrode heating, the ballast factor of the test ballast tends to be larger if the

reference circuit does not use electrode heating. An issue arises when instant-start ballasts (no

electrode heating) are compared to a reference circuit that uses electrode heating. The additional

lamp efficiency in the reference circuit decreases the ballast factor and BEF for an instant-start

ballast compared to a test method that uses no electrode heating in the reference circuit.

Although DOE acknowledges the effect on BEF due to electrode heating in the reference circuit

for instant-start test ballasts, it notes there are no industry supported standards defining reference

circuit operating conditions for medium bipin, miniature-bipin, and recessed double contact

lamps without electrode heating. These lamps are specified in ANSI standards according to

operation with reference ballasts using electrode heating, but instant-start, rapid-start, or

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programmed-start ballasts can operate these lamps. One cannot simply remove electrode heating
 

from the circuit, as it would alter the way the ballast operates the lamp. Without industry

standards, DOE is unable to quantify the effect new operating conditions might have on ballast

factor. DOE expects the effect on BEF as a result of increased of lamp efficiency in the reference

circuit to be relatively small and consistent among all instant-start ballasts such that no particular

product is affected to a greater or lesser extent than any other product. DOE believes that

requiring electrode heating in the reference circuit for all ballasts that operate medium bipin, 

miniature-bipin, and recessed double contact lamps would limit potential variation between test

facilities.

The existing test procedure specifies that the reference lamp electrical characteristics

must not vary more than 2.5 percent from the specifications in the ANSI C78 Series (1972

Edition and 1975 Supplement) for fluorescent lamp electrical characteristics. While this spread

in operating conditions is less than the general requirements for the manufacturing of fluorescent

lamps, it still leads to much of the variation in ballast input power and BEF. Tightening the

tolerance on lamp electrical characteristics to ± 1 percent of the specifications found in the ANSI

C78 Series (1972 Edition and 1975 Supplement) would decrease measurement variation due to

variability in measured lamp power. DOE believes this change alone could result in a large

reduction in measurement variation.

Decreasing the tolerance for ambient temperature would also reduce measurement

variation. Differences in ambient temperature change the effective load a lamp places on a

ballast which affects BEF through changes in the input power measurement. DOE found that

changes in ambient temperature as small as 1OC resulted in changes in BEF as large as 1.5

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percent. DOE believes limiting ambient temperature to 25OC ± 0.5OC would reduce the
 

measurement variation of BEF.

In response to the fluorescent lamp ballast standards rulemaking framework document, 

DOE also received several comments related to the ANSI standard referenced by the current

fluorescent lamp ballast test procedure. In written and verbal comments, NEMA acknowledged

that ANSI C82.2-1984 cited in the current fluorescent lamp ballast test procedure is intended

only for low-frequency ballasts and, thus, can be confusing for technicians attempting to test

high-frequency electronic ballasts. NEMA indicated that ANSI is creating an update of ANSI

C82.11-2002 and the associated C82.11-2002 Annex (collectively known as ANSI C82.11 

Consolidated-200213

) that specifies an appropriate measurement method for high-frequency

electronic ballasts. (NEMA, Public Meeting Transcript, No. 9 at pp. 71-73; NEMA, No. 11 at p.

2) 

DOE agrees that the ANSI C82.2-1984 cited in the current test procedure may be

confusing for high-frequency ballast operation. Thus, DOE believes updating ANSI C82.2-1984

to ANSI C82.2-200214 and indicating the use of ANSI C82.11-2002 and ANSI C82.11 Annex 

would improve the clarity of the electronic ballast test method. DOE believes these changes

would reduce measurement inconsistencies but not affect the measured energy efficiency of the

ballast. Specifically, DOE believes the input power measurement of ANSI C82.2-2002 reduces

the interference of instrumentation on the input power measurement as compared to ANSI

C82.2- 1984. DOE also believes, however, that because modern instrumentation does not

13 American National Standards for Lamp Ballasts - High Frequency Lamp Ballasts - Supplements," approved

January 17, 2002. 14

 "American National Standards for Lamp Ballasts - Method of Measurement of Fluorescent Lamp Ballasts," 

approved June 6, 2002.

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significantly interfere with input power measurements, the differences between the input power

measurements of the two test procedures are negligible. DOE believes ANSI C82.2-2002 should

be used as the guide for measurement for both high- and low-frequency ballasts. For ballast

operating conditions, DOE believes ANSI C82.1-2004 should be used for low-frequency (60 Hz)

ballasts and ANSI C82.11 Consolidated-2002 for high-frequency ballasts. As discussed later in

section III.F.9, while DOE is proposing to adopt the resistor-based BE test method for

compliance with any future amended standards (using transfer equations so BEF values can be

reported), DOE also proposes updating the ANSI C82.2-1984 reference in the existing test

procedure for purposes of compliance with the existing standards. DOE invites comment on this

issue.

In the existing test procedure, ballast factor can be calculated either as a ratio of test and

reference circuit light output or as a ratio of measured lamp power. Requiring light output

measurements to be used for all starting methods in the calculation of ballast factor should

reduce measurement variation and increase the consistency and comparability of results. In

instant-start systems, power measurements are possible because fewer measurements are

required to measure lamp power. For programmed-start and rapid-start ballasts, two wires attach 

to each end of the lamp, requiring additional voltage and current measurements compared to the

instant-start system. During high-frequency operation, these extra measurements make it difficult

to accurately capture lamp power due to capacitance and loading effects on the ballast. For this

reason, light output measurements are used for rapid-start and programmed-start ballasts for the

measurement of ballast factor. Although the existing test procedure indicates the usage of power

measurements for instant-start ballasts, industry practice has been to use light output

measurements for all starting methods. DOE believes the use of light output for the measurement

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of ballast factor for all ballast types would render the values of BF more consistent between
 

testing facilities.

Many ballasts are capable of operating lamps with different lamp wattages. For example, 

a ballast designed to operate two four-foot 32W medium bipin (MBP) T8 lamps can also operate

two 30W, 28W, or 25W lamps. The BEF will vary based on the rated wattage of the lamp

operated by the ballast. When a ballast operates a lamp with a lower rated wattage, BEF tends to

increase due to reduced ballast input power. In an improved light-output-based test procedure, 

DOE would specify particular lamp-and-ballast combinations for testing such that a ballast is

only tested while operating one specific load. DOE believes this method would mitigate testing

burden on manufacturers, provide a representative measurement of ballast energy consumption, 

and make the test procedure more flexible to new lamp-and-ballast combinations. See section

III.F.2 for additional detail on using one lamp (resistor) and ballast combination for testing.

To test every lamp-and-ballast combination, manufacturers would need to purchase and

maintain the requisite number of reference lamps (or in the case of the resistor-based BE method, 

resistors) for every lamp wattage that a ballast can operate. In the example mentioned above, this

would require six lamps (or resistors) in addition to the two required for the 32W lamp. For

ballasts that operate more than two lamps, the impact on manufacturers is more significant.

Furthermore, ANSI standards do not exist for every reduced wattage lamp. Because industry has

not reached a consensus regarding the performance characteristics of each lamp, DOE did not

choose a resistor to represent those lamps for which an industry standard does not exist. Thus, to

mitigate the testing burden on manufacturers, in the fluorescent lamp ballast standards

rulemaking, DOE is considering setting standards based on the ballast operating the most

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common lamp wattage. Consequently, the test procedure only requires one lamp-and-ballast
 

combination to be tested in each product class. See section III.F.2 for additional discussion on

why DOE believes testing a ballast while operating one representative load is a reasonable means

of determining the efficiency of a ballast.

Similar to lamp wattage, ballasts are designed to operate a certain maximum number of

lamps. Many ballasts can operate fewer than the maximum number of lamps. As discussed in

section III.F.2, DOE found testing a ballast on all its possible loads (possible numbers of lamps) 

was unnecessary. DOE believes requiring testing of fluorescent lamps ballasts while operating

the maximum number of lamps for which the ballast is designed would reduce testing burden on

manufacturers and produce representative energy consumption measurements. Therefore, this

test procedure would not require testing of ballasts with every possible number of lamps it can

operate.

Some ballasts are also capable of operating at multiple input voltages (universal voltage

ballasts). The existing energy conservation standards require ballasts to be tested at both 120 V 

and 277 V, which increases the testing burden on manufacturers. The Joint Comment suggested

testing these multi-voltage ballasts at 277 V for commercial ballasts and 120 V for residential

ballasts. (Joint Comment, No. 12 at p. 5) DOE believes that 277 V is the most common input

voltage for commercial ballasts and that 120 V is the most common for residential ballasts.

Therefore, DOE agrees with the Joint Comment and has tentatively concluded that a revised

light-output-based test procedure should test all universal voltage commercial ballasts at 277 V 

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and universal voltage residential ballasts at 120 V15

. Ballasts capable of operating only at a single

voltage would be tested at the rated ballast input voltage.

DOE believes the aforementioned improvements to the existing test procedure would

decrease measurement variation. Furthermore, DOE does not believe the changes would result in

significantly increased testing burden for manufacturers. DOE believes, however, that the

proposed resistor-based BE method reduces measurement variation to a greater extent than the

improved light-output-based test procedure while also imposing only a nominal increase in

testing burden. DOE invites comment on the effectiveness of the improved light-output-based

test procedure to reduce measurement variation and on the burden it imposes for testing.

4. Relative System Efficacy

DOE considered the RSE metric as another alternative to the existing BEF test procedure.

The RSE metric is intended to normalize the existing metric of BEF to rated lamp efficacy to

make it more comparable across ballasts operating different numbers of lamps and different lamp

wattages. DOE received comments suggesting use of the RSE metric in response to the

framework document for the fluorescent lamp ballast standards rulemaking.

NEMA, NYSERDA, and the Joint Comment recommended the investigation of RSE as a

potential replacement for the BEF metric. According to comments, the relative system efficacy

metric would allow comparisons to be made across different ballast types, thereby enabling the

usage of fewer product classes in the energy conservation standard. (NYSERDA, Public Meeting

15 ANSI C82.77-2002 specifies commercial ballasts must have a power factor greater than 0.9, while residential

fluorescent ballasts (with an input power below 120 W) must have a power factor of 0.5 or greater. Residential

ballasts are designed and labeled for use in residential applications.

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Transcript, No. 9 at pp. 27-28, p. 75; NEMA, Public Meeting Transcript, No. 9 at p. 100; Joint
 

Comment, No. 12 at pp. 6-7) 

Relative system efficacy is equal to BEF divided by 100 and multiplied by total rated

lamp power. RSE provides a greater range of comparability among ballast types in comparison

to BEF. Because RSE is based on the BEF metric, it creates minimal incremental testing burden

over the existing test procedure. RSE allows for improved comparison among ballasts designed

to operate different number of lamp systems and ballasts designed to operate different lamp

wattages. Lamp and ballast systems operating more lamps or higher-rated-wattage lamps tend to

have lower BEF values. When these lower BEF values are multiplied by correspondingly larger

total-rated-lamp powers, the resulting value is more comparable across different product classes..

NEMA stated that it is attempting to correlate the BE and RSE metrics to the existing

BEF metric. NEMA also stated that the RSE metric is likely to be more closely correlated to BE

than the BEF metric is to BE. (NEMA, Public Meeting Transcript, No. 9 at p. 28, p. 33) DOE

believes NEMA may be correct in its prediction that RSE is more closely correlated to BE than

BEF to BE. However, DOE proposes the use of transfer equations to convert BE values to BEF

for consistency with use of the BEF metric in 42 USC 6295(g)(5) and (g)(8). Therefore, DOE did

not consider correlating RSE to BE as an option for this proposed test procedure.

Although the RSE metric improves on the BEF metric through increased comparability

between product classes with minimal incremental burden, DOE believes RSE would ultimately

have the same measurement uncertainty associated with the existing test procedure or the

improved light-output based test procedure. In particular, because RSE includes the usage of

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reference lamps in test measurements, RSE is based on the same varied inputs as BEF. This
 

rulemaking's test procedure revision is intended to reduce measurement variation, and DOE

believes the proposed resistor-based BE method reduces measurement variation to a greater

extent than RSE. DOE invites comment on its tentative decision not to adopt RSE as a potential

test method.

F.Proposed Test Procedure

In consideration of the comments and analysis discussed above, today's proposed test

procedure for measuring active mode power consumption is the resistor-based BE method, with 

results correlated to BEF through the use of transfer equations. This method consists of the

following steps: (1) measurement of input power to the ballast; (2) measurement of simulated

lamp arc power to estimate ballast output power; and (3) correlation of the ballast efficiency

metric to BEF. DOE believes the resistor-based BE method results in the largest reduction in

measurement variation over the existing test procedure. Interested parties are invited to comment

on the proposed resistor-based ballast efficiency method, the lamp-based ballast efficiency

method, the improvements to the BEF method, and the RSE method described in section III.E, or

on any other procedures they believe would be appropriate.

In the sections 1 through 8 that follow, DOE discusses the language proposed for a new

appendix Q1 to subpart B of 10 CFR part 430 (hereafter "appendix Q1"). The new appendix Q1

will contain the new test procedure that correlates measured BE to BEF that will be used for the

purposes of compliance with future amended standards. Section 9 describes an update to the

existing test procedure in appendix Q to subpart B of 10 CFR part 430. The change to appendix 

Q updates an industry reference from ANSI C82.2-1984 to the current ANSI C82.2-2002. DOE

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proposes to create a separate appendix Q1 for the proposed new test procedure. DOE will retain
 

the existing BEF test procedure for compliance with existing standards and, once amended

standards become effective, for use with ballasts that cannot operate resistors. Section 10

discusses amendments DOE is proposing regarding references to ANSI C82.2-2002.

1. Test Conditions

DOE proposes that prior to measurement, the ballasts would be thermally conditioned at

room temperature (25OC ± 2OC) for at least 4 hours. During this conditioning period, ballasts are

not operating or energized. Providing time for thermal conditioning helps to generate

reproducible results as electrical products' performance characteristics tend to change in

response to temperature.

In addition, DOE proposes that ballasts be tested using the electrical supply

characteristics found in section 4 of ANSI C82.2-2002 with the following changes: (1) ballasts

capable of operating at a single voltage would be tested at the rated ballast input voltage; (2) 

users of universal voltage ballasts would disregard the input voltage directions in section 4.1 of

ANSI C82.2-2002 that indicate a ballast capable of operating at multiple voltages should be

tested at both the lowest and highest USA design center voltage; and (3) manufacturers use the

most recent revisions to the normative references associated with ANSI C82.2-2002. Instead of

testing universal voltage ballasts at the voltages indicated in ANSI C82.2-2002, DOE believes

that testing ballasts at a single voltage is more appropriate and less burdensome. DOE believes

277 V is the most common input voltage for commercial ballasts and that 120 V is the most

common for residential ballasts. Therefore, DOE proposes that all universal voltage commercial

ballasts be tested at 277 V and that universal voltage residential ballasts be tested at 120 V.

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2. Test Setup
 

The resistor load bank is a network of resistors used to model the load placed on a ballast

by a fluorescent lamp. It consists of five resistors, two for each of the two electrodes and one for

the lamp arc. In a lamp, current can arc from one electrode to the other from any two positions

(known as hotspots) on the lamp electrodes. The position can be different each time the current

flow alternates from one direction to the other. The exact position determines the effective

resistance of the electrode by determining the distance through which current must travel in the

electrode. If the hotspots are at the ends of the electrodes for an instant-start system, the total

electrode resistance will be greater than if the hotspots are both at the center of the electrode.

When the arc begins at the center of the electrode, the length of the resistor is divided in half, 

creating a circuit with two equivalent resistors in parallel. The hotspots' positions change over

time, but the design of the resistor load bank is limited to one fixed position. Therefore, DOE

needed to select a position for the hotspot, and model the resistor load bank accordingly.

The selection of the hotspot position was based largely on the design of rapid-start and

programmed-start ballasts because the position of the hotspot impacts the measured value of BE.

These ballasts use two wires to carry ballast output power to the lamp. One of these wires

supplies power for electrode heating, while the other provides power for the lamp arc. Electrode

heating requires significantly less power than the lamp arc, so different levels of current and

voltage exist in the two ballast wires leading to the lamp. Because these two wires are not labeled

by the respective loads they serve, the user does not know which wire is which. With two

different resistors, depending on which wire was attached to the larger or smaller resistor, the

circuit would display two different output powers. Therefore, DOE modeled a lamp with the

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hotspot in the middle of the electrode so that the resistance of each path would be equal. Section
 

III.F.7 describes how DOE determined resistor values for each type of lamp.

DOE proposes that the ballast be connected to a main power source and to the resistor

load bank according to the ballast manufacturer's wiring instructions. Where the wiring diagram

indicates connecting the ballast wire to a lamp, the lead would be connected to a resistor load

bank. Ballast wire lengths would be unaltered from the lengths supplied by the ballast

manufacturer to accurately capture the ballast efficiency of the product in its original

manufactured form. Wires running from the load bank to the power analyzer would be kept loose

or unbundled and at a minimal working length, to reduce error introduced to the ballast circuit

because of current bypassing the ballast.

DOE also proposes that the ballast be connected to the resistor load bank associated with 

the most common wattage lamp the ballast is designed to operate. In many cases, a ballast can

operate several reduced wattage lamps in addition to the most common variety. For example, 

ballasts designed to operate four-foot MBP T8 lamps can operate 32 W, 30 W, 28 W, and 25 W

lamps. Because ballasts operate differently when connected to different loads, a single resistor

load bank is unable to simulate the load induced by all lamp wattages. To test every lamp-andballast combination, manufacturers would need to purchase and maintain the requisite number of

reference lamps (or in the case of the proposed method, resistors and lamps) for every lamp

wattage that a ballast can operate. Maintaining this number of lamps and resistors would impose

a significant burden on manufacturers. Additionally, ANSI standards do not exist for every

reduced wattage lamp. Because industry has not reached a consensus regarding the performance

characteristics of each lamp, DOE could not choose a resistor to represent those lamps for which 

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an industry standard does not exist. Thus, to mitigate the testing burden on manufacturers, the
 

proposed test procedure would only require one lamp-and-ballast combination to be tested in

each product class. Therefore, DOE proposes a test procedure based on the ballast operating the

most common lamp wattage, resulting in a ballast efficiency that represents the way the product

is primarily used in the market and reducing the testing burden on manufacturers.

DOE proposes to test fluorescent lamp ballasts operating the maximum number of lamps

for which they are designed. Many ballasts can operate fewer than the maximum number of

lamps they are designed to operate. DOE compared the BEF of a ballast operating the maximum

number of lamps for which it was designed to a ballast operating the same number of lamps but

which was designed to operate more lamps. For example, a 4-lamp ballast operating two lamps

has a similar efficiency to a 2-lamp ballast operating two lamps. When operating the same

number of lamps, DOE found no correlation between the ballasts capable of operating different

maximum numbers of lamps and BEF. Therefore, today's proposed test procedure requires

testing of a ballast only while it is operating the number of resistor load banks equal to the

maximum number of lamps for which it was designed.

In response to the framework document for the fluorescent lamp ballast standards

rulemaking, the Joint Comment stated that DOE should establish performance requirements at

specific dimming levels (such as 100, 75, 50, and 25 percent) such that dimming ballasts can be

consistently compared. (Joint Comment, No. 12 at p. 5) DOE agrees that a test procedure for

dimming ballasts should specify the dimming level or levels at which ballast efficiency should be

tested. The preliminary determination of the scope of coverage in the fluorescent lamp ballast

standards rulemaking, however, does not include dimming ballasts because these ballasts have an

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overall market share of about one percent and are already used in energy-saving systems. Thus, 

DOE did not include them in the preliminary scope of coverage. If DOE determines in the

fluorescent lamp ballast standards rulemaking that the scope of coverage should include

dimming ballasts, DOE will develop a test procedure for these ballasts. DOE invites comment on

potential methods of measurement for determining the efficiency of dimming ballasts in the

event dimming ballasts are added to the scope of coverage in the ongoing fluorescent lamp

ballast standards rulemaking.

Ballast wiring is different depending on starting method. Instant-start ballasts have only

one wire connecting the ballast to each end of the load, while rapid-start and programmed-start

ballasts have two wires connected to each end. The second wire in rapid-start and programmedstart systems is used for electrode heating. The resistor load banks have two input wires

connected to two electrode resistors. In this test procedure, DOE proposes that the single output

wire on an instant-start ballast be shorted with the two input electrode resistors to be consistent

with current industry practice. DOE notes that this circuit topology is consistent with the wiring

of lamp-and-ballast systems for bipin lamps. For example, a four-foot 32 W MBP T8 lamp has

two pins that are shorted together with the ballast output wire using a jumper wire or an adapter.

A programmed-start ballast would not need to be shorted together because the ballast uses two

wires for ballast output between the ballast and the lamp.

DOE proposes that the power analyzer voltage leads be attached to the wires leading to

and from the main power source for input voltage measurements and that the current probe be

placed around the same wires for input current. The power analyzer should have at least one

channel per lamp plus one additional channel for the ballast input power measurement. Figure 1 

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shows the instrumentation placement for the output power measurement for ballasts that operate
 

MBP, recessed double contact (RDC), and miniature-bipin (miniBP) lamps and Figure 2 shows

placement for ballasts that operate single pin (SP) lamps.

Figure 1. Instrumentation Placement for Ballasts that Operate MBP, RDC, and MiniBP

Lamps

Figure 2. Instrumentation Placement for Ballasts that Operate SP Lamps 

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3. Test Method
 

ANSI C82.2-2002 specifies operating the reference lamp with the test ballast for less than

30 seconds to reduce the effect of lamp restabilization on light output and to give the ballast less

time to increase in temperature. Following the protocol established in ANSI C82.2-2002, a lamp

is first stabilized on a reference ballast and then transferred to a test ballast without being

extinguished. The output of a fluorescent lamp remains relatively constant (steady-state) when

operated under defined conditions. When these defined conditions change (e.g., switching from a

reference ballast to a test ballast) the lamp output characteristics also change. This change is not

immediate, so by limiting the time the test ballast is driving the reference lamp, the reference

lamp is kept as close as possible to its reference conditions. In addition, as a ballast operates, it

increases in temperature until it reaches steady-state, though it may take more than thirty minutes

for a ballast to increase from room temperature to steady-state temperature. Limiting test ballast

operation to thirty seconds limits the increase in ballast temperature. DOE believes that over the

course of thirty seconds, the change in lamp operating characteristics has a more significant

impact on light output than changes in ballast temperature.

For the proposed resistor-based test procedure, DOE found that one minute of operation

was required to provide sufficient time to prepare for the data capture while maintaining the

ballast and resistor load bank near room temperature. DOE recognizes that it is extending the

time of operation compared to the procedures outlined in ANSI C82.2-2002, but it does not

believe the additional 30 seconds allow for a significant increase in temperature of the ballast or

in the resistance of the resistor load bank. As previously stated, DOE believes the main driver in

ANSI's decision to limit operation to 30 seconds was the change in lamp operating

characteristics, not ballast temperature. DOE proposes that after one minute of data capture the

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ballast be switched off, so that the resistor load bank duty cycle not exceed 50 percent (that is, 

for every operational minute, the load should be rested for one minute) to minimize any issue

with thermal drift of the resistor load bank. Thermal drift describes the phenomenon of a resistor

exhibiting a different resistance in response to a change in its internal temperature. DOE believes

that operating a resistor load bank for one minute followed by one minute of zero power will

sufficiently reduce the opportunity for the resistor load bank deviate from its room temperature

resistance rating.

During data acquisition, the power analyzer should measure the input voltage and current

and the output voltage and current according to the setup described in section III.F.2. DOE

proposes that the measured input parameters be voltage (RMS16

), current (RMS), power, and

power factor measured in accordance with ANSI C82.2-2002. The measured output parameters

would include lamp arc resistor voltage, current, and power. Instrumentation for current, voltage, 

and power measurements would be selected in accordance with ANSI C78.375-199717 Section 9, 

which specifies that instruments should be "of the true RMS type, essentially free from wave

form errors, and suitable for the frequency of operation." DOE proposes to further specify

instrument performance within the guidelines of the ANSI C78.375-1997 and ANSI C82.2-2002.

Specifically, current would be measured using a galvanically isolated current probe/monitor with 

frequency response between 40 Hertz (Hz) and 20 MHz. In addition, voltage would be measured

directly by a power analyzer with a maximum 100 picofarad (pF) capacitance to ground and

have frequency response between 40 Hz and 1 MHz.

16 Root mean square (RMS) voltage is a statistical measure of the magnitude of a voltage signal. RMS voltage is

equal to the square root of the mean of all squared instantaneous voltages over one complete cycle of the voltage

signal. 17

 "American National Standard for Fluorescent Lamps - Guide for Electrical Measurements," approved September

25, 1997.

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In addition to making electrical input and output measurements, today's proposed test
 

procedure would also require measurement of ballast factor for the conversion to BEF. As

discussed in the ballast factor section of III.F.5, ballast factor affects the apparent load placed on

a ballast by a lamp, and consequently the measured BEF. BF helps assign a ballast to a particular

product class, and it must be determined empirically. DOE proposes that ballast factor be

measured in accordance with ANSI C82.2-2002 section 12, with a few modifications. Because

the measurement of ballast factor requires a reference lamp, DOE proposes to adopt some of the

improvements to the existing test procedure described in section III.E.3. DOE believes

specifying particular electrical operating conditions, clarifying in which circumstances electrode

heating should be used in the reference circuit, and using light output measurements instead of

power measurements for all ballasts will reduce variation in the measurement of BF. These

changes are discussed in greater detail below.

First, DOE notes that there are several options for operating a reference lamp as

described in IESNA LM-9-1999. As described in section III.E.3, DOE proposes operating the

reference lamp at the specified input voltage to the reference circuit. This method is the simplest

to execute and the most common practice in industry. In addition, DOE adopted this method in

the test procedure final rule for general service fluorescent lamps. 74 FR 31829, 31834 (July 6, 

2009). Second, the existing ballast test procedure is unclear on whether electrode heating should

be used in the reference circuit for all ballasts. As described in section III.E.3, the presence or

absence of electrode heating in the reference circuit changes the light output of the reference

lamp on the reference circuit, thereby changing the measured value of BF. DOE proposes that

electrode heating be used in the reference circuit for all ballasts that operate bipin or recessed

double contact lamps (MBP, mini-BP, RDC). Single-pin lamps should not use heating in the

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reference circuit because these ballasts are not capable of undergoing electrode heating and are
 

designed for use with instant-start ballasts. Third, although the existing test procedure requires

the usage of power measurements for instant-start ballasts, industry practice has been to use light

output measurements for all starting methods. DOE proposes the use of light output for the

measurement of ballast factor for all ballast types to make the values of BF more consistent.

In addition, because DOE is considering establishing a ballast efficiency (correlated to

BEF) test procedure based on operation of a lamp at the most common wattage, DOE proposes

that ballast factor also be measured using the most common wattage lamp. Ballast factor should

be measured using a reference lamp with the nominal wattage indicated in section III.F.7 for a

given ballast type. This nominal wattage also represents the type of lamp the resistor load bank

simulates. Testing each ballast with only the most common wattage lamp produces test results

that are most representative of how the end users operate fluorescent lamp ballasts.

DOE does not believe that the usage of reference lamps for the purpose of ballast factor

determination creates significant measurement variation. DOE believes that variations in

measured lamp power affect ballast input power to a much greater extent than ballast factor.

DOE invites comment on the variation of ballast factor due to lamp manufacturing variations and

its effect on the measurement variation of BE converted to BEF.

4. Calculations

As described in Equation 1 below, ballast efficiency is equal to output power divided by

input power.

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Output Power BE = Eq. 1

Input Power

DOE proposes to relate ballast efficacy factor to the measured ballast efficiency through 

the empirically derived transfer equations discussed in section III.F.5.

5. Transfer Equations - General Method

A system of transfer equations is needed for correlating BE to BEF consistent with 42

USC 6295(g). DOE determined the transfer equations empirically by testing ballasts using both 

the proposed resistor-based BE and existing BEF test methods. DOE then plotted the results and

computed a linear regression to generate an equation for BEF as a function of BE.

The existing test procedure for fluorescent lamp ballasts allows for ballasts to operate the

reference lamps under multiple operating modes. The user may operate at constant lamp current, 

voltage, or power. DOE used constant input voltage to the reference circuits for all of its BEF

measurements and for lamp resistor determination. DOE believes this to be the most common

industry practice. Therefore, the transfer equations that convert BE to BEF reflect this decision.

Because factors like number of lamps, ballast factor, starting method, and lamp diameter

affect the correlation between BE and BEF, DOE considered individual transfer equations for

each product class proposed in the fluorescent lamp ballast standards rulemaking. The following

paragraphs discuss each of the factors considered in the transfer equation development process.

DOE invites comment on the transfer equations.

Number of Lamps

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The number of lamps operated by a ballast has a disparate effect on the BE and BEF
 

metrics. BEF decreases for ballasts operating increased number of lamps. This is because ballast

input power increases (denominator) but the ballast factor (numerator) does not necessarily

change. In contrast, BE changes much less with varying numbers of lamps because the

numerator and denominator change by roughly proportional amounts. Therefore, DOE parsed the

data into groupings based on the number of lamps the ballast operates. Within these groupings, 

DOE plotted BE versus BEF and computed a linear regression to generate an equation for BEF

as a function of BE.

Ballast Factor

For a given ballast type, ballast factor tends to increase with increased ballast input

power. As ballast input power increases, so does the ballast output power and consequently the

light output. When a lamp is running at a higher lamp current and power (representative of a

ballast with a high BF), lamp impedance decreases and the apparent load the lamp places on the

ballast decreases. Therefore, a high BF ballast operating a resistor that simulates normal BF

loading will measure a higher BE than when running a load of the appropriate resistance. To

account for this change in apparent load with a resistor load bank, DOE identified two options:

(1) modify resistor values to account for the change in apparent load due to lamp current and BF; 

or (2) conduct all testing with one resistor representing normal BF but develop separate transfer

equations for three different ranges of ballast factors (called bins).

18

18 DOE proposes three ballast factor bins: low, normal, and high. Low-ballast factor ballasts have a ballast factor of

0.78 or less; ballasts designed with a ballast factor between 0.78 and 1.10 are normal-ballast factor; and high-ballast

factor ballasts were defined to have a ballast factor of 1.10 or higher.

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For option one, DOE would need to determine resistor values for multiple ballast factors
 

for each ballast type. By appropriately matching resistance to BF, the test procedure would more

accurately model the change in apparent load as a function of ballast factor. This method would

create an additional burden on DOE at the outset of the test procedure and an even more

significant burden on manufacturers. For example, if in order to obtain measurable improvement

in testing accuracy compared to option 2, DOE were to assign a separate resistor value to each 

ballast factor in the low ballast factor product class for 4-foot T8 MBP ballasts, DOE would need

to specify four specific resistor values. Specification of multiple resistors based on ballast factor

would require the manufacturer to purchase many more resistors than a test procedure that used

one resistor for all ballast factors. To limit the impact on manufacturers, DOE could determine

resistor values for two to three commonly used BFs per ballast type and establish bins around

these ballast factors. Keeping the number of BF-specific resistor values to a minimum would

decrease manufacturer burden but still be more burdensome than option 2 without offering any

appreciable improvement in testing accuracy compared to option 2.

Option two specifies that ballasts of all BFs are tested using the same resistor value.

Under this approach, ballasts designed with a ballast factor different that the ballast factor

simulated by the resistor load bank would be operating a load that is non-representative of the

effective load placed on the ballast by a real lamp. When testing ballasts of all ballast factors

using one resistor, all else held constant, as BF increases, measured BE will tend to increase as

well. Because the measured BE will not accurately describe lamp arc power divided by ballast

input power, DOE would need to create a scaling technique. DOE can develop transfer equations

for converting measured BE to BEF that correspond to bins of ballast factors. Transfer equations

could be developed for particular ranges of BF so that DOE can define different relationships

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between measured BE and BEF for different BF bins. DOE proposes to use three bins because
 

ballasts currently offered in the market are generally centered on three different ballast factors.

DOE proposes this option because DOE believes it appropriately balances accurate scaling based

on ballast factor with the reduced burden on manufacturers as a result of using one resistor for all

ballast factors.

DOE notes that placing ballasts into three bins based on BF results in the measured

efficiency of the ballasts with the lowest BF in a particular bin to be relatively smaller than the

higher end of the BF bin. Low BF ballasts tend to measure a lower BE than a high BF ballast

when operating the same resistor because of the effects of current on lamp impedance discussed

previously. This could potentially encourage the industry to produce ballasts at the upper ends of

these bins, as the associated energy conservation standard would be less stringent for the higher

BF models. DOE invites comment on this issue.

DOE considered two mitigating strategies for reducing the market interference resulting

from specifying a small number of BF bins. One possible solution to this problem is to increase

the number of BF bins to reduce the range in BF within a bin. DOE was not able to assemble

enough data based on the ballast factors currently offered in the market to increase the number of

BF bins. The ballast market tends to clump around two to three popular ballast factors, rendering

empirical determination of transfer equations for intermediate ballast factors infeasible. DOE

also considered creating a continuous function of BE as a function of BF to normalize BE values

for the deviation in measured BE as a result of running a ballast on unrepresentative resistive

load. These normalized BE values would then be used as inputs to a single transfer equation

developed from data obtained by testing ballasts with the ballast factor that the resistive load

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bank simulates. Similar to efforts to increase the number of BF bins, however, DOE found that
 

the market provided insufficient data for scaling. With only two to three BFs in the data set, 

DOE could not be certain of the relationship between BF and measured BE.

Accordingly, based upon the above considerations, DOE has tentatively decided to

proceed with option two by developing three transfer equations relating to three different ballasts

factor bins. DOE tested ballasts of high-, normal-, and low-ballast factor varieties for each ballast

type to develop an equation for BEF as a function of BE specific to the ballast factor type (high, 

normal, or low). DOE plotted BE and BEF data for a given BF bin (high-, normal-, or low-BF

bins) and calculated a linear regression to determine an equation for BEF as a function of BE for

the given BF.

Starting Method

Starting method also impacts the correlation between BE and BEF. Instant-start ballasts

are in general more efficient than rapid-start and programmed-start ballasts. Because instant-start

ballasts do not supply electrode heating, there are fewer losses in the ballasts' internal circuitry

and more of the output power goes to the lamp arc. Rapid-start and programmed-start ballasts

use part of their output power to heat the lamp electrodes. In short, starting method has nonlinear

effects on the light-output-based measurement of BEF and the BE-based measurement of BEF

such that specific transfer equations are required for each starting method. Therefore, DOE

parsed the data into groupings based on starting method. Within these groupings, DOE plotted

BE versus BEF and computed a linear regression to generate an equation for BEF as a function

of BE. In the fluorescent lamp ballast standards rulemaking, DOE plans to consider grouping

instant-start and rapid-start ballasts in the same product class and programmed-start ballasts in a

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separate product class based on consumer utility. To create BEF values which are comparable for
 

product classes with instant-start and programmed-start ballasts, DOE proposes to use one

transfer equation for converting BE to BEF. This decision was made on the basis that ballasts of

the same BE should have the same BEF.

Lamp Diameter

In the fluorescent lamp ballast standards rulemaking, DOE has tentatively determined

that there is no distinct consumer utility difference between T8 and T12 ballasts. As a result, 

DOE is grouping T8 and T12 ballasts in the same product class. At the 2008 public meeting, 

NEMA commented that BEF measurement requires photometric measurements of a reference

lamp attached to the test ballast; thus, BEF values cannot be compared across ballasts that

operate different lamp types. (NEMA, Public Meeting Transcript, No. 9 at pp. 124-125; NEMA, 

No. 11 at p. 6) DOE agrees that under the existing test procedure, the BEF values measured for

T8 and T12 ballasts are not comparable because the reference lamps for these ballasts have

different rated power. Because certain T8 and T12 ballasts would be subject to the same energy

conservation standard (in the preliminary analysis of the fluorescent ballast standards rulemaking

these ballasts are in the same product class), DOE proposes to amend the test procedure such that

the reported T12 ballast BEF would be comparable to the reported BEF for a T8 ballast. To

achieve this, DOE first developed transfer equations based on data for T8 ballasts in a given

product class. To generate T12 ballast BEF values which are comparable to T8 ballast BEF

values, DOE proposes using the transfer equations developed for the relevant T8 ballasts to

generate a BEF for T12 ballasts. As such, a T12 ballast BE value would be used as an input to

the relevant T8 transfer equation. The T8 transfer equation would then output a T12 ballast BEF

value comparable to BEF values for T8 ballasts. DOE made this decision based on the

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assumption that T8 and T12 ballasts with the same BE should have the same BEF when
 

reporting compliance with energy conservations standards.

6. Transfer Equations - Testing, Analysis, and Results

In the fluorescent lamp ballast standards rulemaking, DOE has preliminarily categorized

ballasts into 70 product classes. In today's test procedure, DOE proposes to generate separate

transfer equations for each product class. DOE targeted representative product classes and

certain key product classes for extensive testing with the expectation that scaling would be

required to establish transfer equations for the remaining product classes. DOE found strong

correlation between BE and BEF for the product classes indicated in Table III.1.

DOE believes a linear relationship should exist between BE and BEF for ballasts of the

same ballast factor, starting method, number of lamps, and lamp type. All ballasts under these

constraints send the same amount of output power to a lamp, and therefore, ballasts of different

efficiency vary in input power only. A more efficient ballast requires less input power to yield

the same output power as a less efficient ballast. Because both BE and BEF are proportional to

the same expression (the inverse of input power), a linear relationship should exist between the

two metrics. The test data indicated a linear relationship between BE and BEF, consistent with 

DOE's expectation. Although DOE tested mostly electronic ballasts, which are generally more

efficient than their magnetic counterparts, DOE believes the linear relationship between BE and

BEF should exist across all values of BE and BEF. As such, DOE developed linear relationships

between BE and BEF such that the equation passed through the origin (a BE of zero should

correspond to a BEF of zero). DOE developed transfer equations in the form BEF = slope * BE, 

establishing a slope for each product class for the conversion of BE to BEF.

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Table III.1 Transfer Equation Development Method by Product Class 

Ballast and Lamp

Type

Starting 

Method

Ballast

Factor

Number of Lamps

One Two Three Four Five Six 

Four-Foot MBP, 

and Two-Foot UShaped

IS and RS

(not PS) 

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Four-Foot T5

MiniBP SO All

High 37 38 --- --- --- ---

Normal 39 40 --- --- --- ---

Low 41 42 --- --- --- ---

Four-Foot T5

MiniBP HO All All 43 44 45 46 --- ---

Eight-Foot SP

Slimline All

High 47 48 --- --- --- ---

Normal 49 50 --- --- --- ---

Low 51 52 --- --- --- ---

Eight-Foot RDC

HO

IS and RS All 53 54 --- --- --- ---

PS All 55 56 --- --- --- ---

Residential Ballast, 

Four-Foot MBP, 

and Two-Foot UShaped

IS and RS

(not PS) All 57 58 59 60 --- ---

PS All 61 62 63 64 --- ---

Sign Ballast All All 65 66 67 68 69 70

Gray shading indicates the slope is based on test data directly. Gray shading with diagonal

lines indicates the slope is based on a relationship between total rated lamp power and slope.

All other product classes (not shaded) have slopes based on scaling relationships. DOE tested

ballasts for BE and BEF in underlined product classes.

*IS = Instant-start; RS = Rapid-start; PS = Programmed-start

Based on the test data for 4-foot 32W MBP T8 ballasts, DOE established scaling ratios

for ballast factor type, number of lamps operated, and starting method. For ballast factor type, 

DOE calculated the ratio of the slopes for product classes 2 and 14 compared to product class 8 

and used these ratios for scaling all other normal ballast factor product classes to their high and

low ballast factor counterparts. For starting method, DOE employed a similar technique to the

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ballast factor type scaling method. DOE calculated the ratio of the slopes for product class 8 and
 

product class 26 to establish a relationship between the combined instant- and rapid-start ballast

product classes and the programmed-start product classes. Again, DOE based scaling for all

other combined instant- and rapid-start ballast product classes to their programmed-start

counterparts on this ratio between instant- and rapid-start ballast and programmed-start ballasts.

For number of lamps operated by a ballast, DOE fit a power regression equation to the slopes for

4-foot MBP T8 instant- and rapid-start normal BF ballasts that operate one, two, or three lamps

(product classes 7, 8, and 9). DOE used the equation to extrapolate the slopes for products

classes 10, 11, and 12 (four, five, and six lamps) DOE then used the slopes for product classes 7

through 12 to establish ratios between the slopes for ballasts that operate 1, 3, 4, 5, or 6 lamps

and the slope for ballasts that operate 2 lamps. Again, DOE based scaling for all other 2 lamp, 

normal BF ballasts to their 1, 3, 4, 5, and 6 lamp counterparts on the number of lamps ratios

generated with product classes 7 through 12.

DOE focused its testing on 4-foot 32W MBP T8 ballasts for the establishment of scaling

ratios between BF, number of lamps, and starting method. DOE tested smaller quantities of

ballasts from other product classes, but found 8-foot T8 SP slimline ballasts to have a strong

correlation between BE and BEF in the available dataset. For 4-foot T5 SO, 4-foot T5 HO, 8-

foot RDC HO, and sign ballasts, DOE developed a relationship between total rated lamp power

and the slope of the line relating BE to BEF. Total rated lamp power is the sum of the rated lamp

wattages (as defined in 10 CFR 430.2) operated by a particular ballast. DOE fit a power

regression equation to the slopes and total rated input powers for product classes19 7, 8, 9, 49, 

and 50. Using this relationship, DOE extrapolated and interpolated slopes for product classes

19 Product classes are identified by numbers in Table III.1.

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product classes 39, 40, 43 through 46, 53, 54, and 65 through 70. DOE estimated the slopes
 

based on total rated lamp power for these product classes because there was insufficient

correlation in the test data to establish a slope. DOE invites comment on its scaling technique for

number of lamps operated by a ballast, starting method, ballast factor, and total rated lamp

power.

Table III.2 lists the slope of the line developed by DOE for converting measured BE to

BEF. Using the equation BEF = slope * BE, measured BE is converted to BEF.

Table III.2 Transfer Equation Slopes 

Ballast

and Lamp

Type

Starting 

Method*

Ballast

Factor

Number of Lamps

One Two Three Four Five Six 

Four-Foot

MBP, and

Two-Foot

U-Shaped

IS and

RS (not

PS) 

High 3.233 1.624 1.081 0.812 0.650 0.542

Normal 3.378 1.697 1.129 0.849 0.679 0.566

Low 3.430 1.723 1.147 0.862 0.690 0.575

PS

High 3.204 1.610 1.071 0.808 0.644 0.537

Normal 3.348 1.682 1.119 0.844 0.673 0.561 

Low 3.400 1.708 1.137 0.857 0.684 0.570

Four-Foot

T5

MiniBP

SO

All

High 2.910 1.584 --- --- --- ---

Normal 3.041 1.655 --- --- --- ---

Low 3.088 1.680 --- --- --- ---

Four-Foot

T5

MiniBP

HO

All All 1.703 0.927 0.649 0.504 --- ---

Eight-Foot

SP

Slimline

All

High 1.653 0.841 --- --- --- ---

Normal 1.727 0.878 --- --- --- ---

Low 1.754 0.892 --- --- --- ---

Eight-Foot

RDC HO

IS and

RS (not

PS) 

All 1.128 0.614 --- --- --- ---

PS All 1.138 0.619 --- --- --- ---

Residential

Ballast, 

Four-Foot

MBP, and

Two-Foot

U-Shaped

IS and

RS (not

PS) 

All 3.357 1.686 1.122 0.853 --- ---

PS All 3.328 1.671 1.113 0.846 --- ---

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Sign

Ballast All All 0.888 0.483 0.338 0.263 0.216 0.184

Gray shading indicates the slope is based on test data directly. Gray shading with diagonal lines indicates the

slope is based on a relationship between total rated lamp power and slope. All other product classes (not shaded) 

have slopes based on scaling relationships. DOE tested ballasts for BE and BEF in underlined product classes.

*IS = Instant-start; RS = Rapid-start; PS = Programmed-start

7. Resistor Value Determination

The resistor-based BE method requires a resistive load bank to be used in place of a lamp

during ballast operation. Therefore, DOE determined20 the resistive value corresponding to

different lamp types operating at conditions described in ANSI C78.81-2005.

21 In some cases, 

the resistor value was calculated from data published in ANSI C78.81-2005. ANSI C78.81-2005

provides electrical characteristics of lamps under either high-frequency or low-frequency

operation. For T8 and T12 lamps, ANSI C78.81-2005 provides electrical characteristics for lowfrequency operation, and for T5 lamps, the standard provides characteristics for high-frequency

operation. Since electronic ballasts operate in high-frequency, DOE needed to empirically

determine high-frequency resistances for testing electronic ballasts that operate T8 and T12

lamps. Since all T5 ballasts currently offered in the market are electronic, DOE did not need to

empirically determine resistor values for low-frequency operation. DOE determined one resistor

value per lamp and did not modify the resistance based on each individual different ballast

factors as discussed in section III.F.5. Table III.3 lists the resistor values determined empirically

and those specified by ANSI C78.81-2005.

20 DOE determined the simulated lamp arc resistor value at BF=0.88 for 4-foot 32 W MBP T8 ballasts because 0.88 

was used in the NEMA round robin and is the most common BF for this ballast type.
 21 American National Standards for Electric Lamps, Double-Capped Fluorescent Lamps - Dimensional and
 

Electrical Characteristics," approved August 11, 2005.
 

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Table III.3 Simulated Lamp Resistor Values
 

Ballast Type Nominal 

Lamp

Wattage

Lamp

Diameter 

and Base 

Low-Frequency

Operation 

Resistance (Ohms)

High-Frequency

Operation Resistance 

(Ohms)

Electrode 

(R1I2E)

Lamp

Arc 

(Rarc)

Electrode 

(R1I2E)

Lamp Arc 

(Rarc)

Ballasts that operate one, two, 

three, four, five, or six straightshaped lamps (commonly referred

to as 4-foot medium bipin lamps) 

with medium bipin bases, a

nominal overall length of 48 

inches, a rated wattage of 25 W or

more, and an input voltage at or

between 120 V and 277 V 

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one, two, 

three, four, five, or six U-shaped

lamps (commonly referred to as

2-foot U-shaped lamps) with 

medium bipin bases, a nominal

overall length between 22 and 25

inches, a rated wattage of 25 W or

more, and an input voltage at or

between 120 V and 277 V 

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one or two

rapid-start lamps (commonly

referred to as 8-foot high output

lamps) with recessed double

contact bases, a nominal overall

length of 96 inches and an input

voltage at or between 120 V and

277 V

86 T8 HO

RDC

N/A N/A 4.75 538 

95 T12 HO

RDC

1.6 131 1.6 204

Ballasts that operate one or two

instant-start lamps (commonly

referred to as 8-foot slimline

lamps) with single pin bases, a

nominal overall length of 96

inches, a rated wattage of 52 W or

more, and an input voltage at or

between 120 V and 277 V 

59 T8 slimline

SP

N/A* 876 N/A* 1256

60 T12

slimline SP

N/A* 313 N/A* 431 

Ballasts that operate one or two

straight-shaped lamps (commonly

referred to as 4-foot miniature

bipin standard output lamps) with 

miniature bipin bases, a nominal

length between 45 and 48 inches, 

a rated wattage of 26 W or more, 

and an input voltage at or

between 120 V and 277 V 

28 T5 MiniBPN/A N/A 20 950

Ballasts that operate one, two, 

three, or four straight-shaped

lamps (commonly referred to as

4-foot miniature bipin high output

lamps) with miniature bipin

54 T5 MiniBPN/A N/A 4 255

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bases, a nominal length between

45 and 48 inches, a rated wattage

of 49 W or more, and an input

voltage at or between 120 V and

277 V

Ballasts that operate one, two, 

three, or four straight-shaped

lamps (commonly referred to as

4-foot medium bipin lamps) with 

medium bipin bases, a nominal

overall length of 48 inches, a

rated wattage of 25 W or more, an

input voltage at or between 120 V 

and 277 V, a power factor of less

than 0.90, and that are designed

and labeled for use in residential

applications

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one, two, 

three, four, five, or six rapid-start

lamps (commonly referred to as

8-foot high output lamps) with 

recessed double contact bases, a

nominal overall length of 96

inches, an input voltage at or

between 120 V and 277 V, and

that operate at ambient

temperatures of 20 OF or less and

are used in outdoor signs

86 T8 HO

RDC

N/A N/A 4.75 538 

110 T12 HO

RDC

1.6 166 1.6 275

MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, 

respectively.

* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.

ANSI C78.81-2005 specifies the electrode resistance a lamp manufacturer must achieve

through design and manufacturing. Electrode resistance is assumed to be the same for lowfrequency and high-frequency operation because a tungsten filament (lamp electrode) has high 

impedance at both frequencies. For the lamp arc, the ANSI standard provides electrical

characteristics for either high or low frequency, depending on the lamp type. By dividing lamp

arc wattage by the square of lamp current, DOE calculated the resistance of the lamp arc resistor.

Where lamp specification sheets do not specify electrical characteristics for the desired

frequency of operation, DOE determined resistor values empirically. DOE empirically

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determined resistor values for high-frequency operation of 32 W F32T8, 60 W F96T12/ES, 95 W
 

F96T12HO/ES, and 110 W F96T12HO lamps. To determine the resistor values empirically, 

DOE first measured the light output of a reference lamp operated by a reference ballast at low

frequency. Next, DOE connected the same reference lamp to a reference ballast operating at high 

frequency. By adjusting the voltage and current provided to the lamp, DOE achieved the same

light output for high-frequency operation as measured in low-frequency operation. Then, DOE

calculated the apparent resistance of the lamp under high-frequency operation using measured

current and voltage.

DOE notes that the measurement of lamp arc power is slightly different than actual lamp

arc power due to the empirical method of determining the resistor value. DOE calculated the

lamp arc resistor using measured lamp voltage and current at a predetermined light output. Part

of this voltage is applied across the lamp electrodes, so the calculated lamp arc resistor value

tends to be slightly larger than reality. DOE believes the increase in calculated lamp arc

resistance due to voltage drop in the electrodes to be minimal in comparison to the true lamp arc

resistance. Because DOE cannot measure lamp electrode resistance independently of the lamp

arc, DOE was unable to account for this problem. Design of the fluorescent lamp prevents DOE

from making this measurement. In addition, DOE does not identify the resistance for a discrete

electrode resistor for ballasts that operate eight-foot slimline SP lamps because DOE could not

determine this value empirically and ANSI C78.81-2005 does not list the resistance. In effect, 

the empirical resistor value determination method includes the resistance of the electrodes in the

resistance of the lamp arc resistor. Because the SP lamps only have one pin, the electrodes and

lamp arc are all connected in series. When DOE measured the resistance for the "lamp arc

resistor," DOE was unable to separate the resistance of the electrodes from the lamp arc due to

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design of a fluorescent lamp. While it was necessary to use electrode resistors in medium bipin, 

miniature-bipin, and recessed double contact lamps to allow for an electrode heating circuit, 

single-pin lamps do not have this functionality and are only designed for use with instant-start

ballasts. Therefore, the lamp arc resistor for single-pin lamps includes the effective resistance of

the entire lamp in a single resistor.

In addition, today's proposed high-frequency lamp arc resistor values for ballasts that

operate one, two, three, four, five, or six straight-shaped and U-shaped lamps with medium bipin

bases, a nominal overall length of 48 inches, a rated wattage of 25 W or more, and an input

voltage at or between 120 V and 277 V are based on a ballast factor of 0.88. This value resulted

from DOE's participation in the NEMA round robin testing for the development of the resistorbased BE method. DOE selected a resistor for four-foot MBP ballasts that represented a 0.88 

ballast factor, which is the most common ballast factor for this ballast type. For other ballast

types, DOE used the electrical characteristics in ANSI C78.81-2005 to develop high-frequency

lamp arc resistor values. These characteristics correspond to a ballast factor of 1.0. DOE does not

believe that the quality of the test procedure is affected by the use of a different ballast factor for

the 4-foot T8 MBP ballasts. DOE invites comment on this issue.

8. Non-Operational Ballasts When Connected to a Resistor

During the testing process, DOE targeted certain product classes spanning ranges of

ballast factor, starting method, lamp type, and number of lamps for extensive testing of both BEF

and BE. See section III.F.6 for additional detail on the specific product classes chosen for testing.

DOE selected several ballasts, ranging from one to approximately fifteen, within each chosen

product class and tested three samples of each ballast. As part of its testing process for

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developing transfer equations between BEF and BE, DOE identified seven different ballast
 

models that did not operate the resistor load bank. Therefore, DOE was therefore unable to

calculate these ballasts' BE. These ballasts were from different product classes and different

manufacturers. In some cases, all three examples of a particular ballast did not operate a resistor, 

while in the other cases only one or two ballast examples did not operate a resistor. DOE also

confirmed that the ballasts did operate properly when connected to fluorescent lamps. DOE does

not know specifically why some ballasts do not operate resistor load banks. It appears these

ballasts sensed the load was not a real fluorescent lamp and turned off. For ballasts found to not

operate resistors, DOE proposes that manufacturers use the existing BEF test procedure found in

appendix Q. In addition, DOE is considering an alternative proposal in which it would include

improvements to the light-output-based test procedure in the procedure for ballasts that do not

operate resistors. DOE believes this would improve the precision of the BEF measurements for

ballasts that do not operate resistors. The improved light-output-based test procedure could be

outlined as a separate section in Appendix Q1 only for use with ballasts that do not operate

resistors. DOE invites comment on why some ballasts do not operate when connected to a

resistor load bank.

9. Existing Test Procedure Update

As discussed in III.E.2, DOE proposes to update the reference in the existing test

procedure (appendix Q) from ANSI C82.2-1984 to ANSI C82.2-2002, and to specify that where

ANSI C82.2-2002 references ANSI C82.1-1997, the operator shall use ANSI C82.1-2004 for

testing low-frequency ballasts and shall use ANSI C82.11-2002 for high-frequency ballasts.

These changes to the existing test procedure to modernize the ANSI reference would be effective

30 days following publication of the test procedure final rule. DOE does not believe the updated

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standard will impose increased testing burden, nor will it alter the measured BEF of fluorescent
 

lamp ballasts. Because the active mode and standby mode test procedures now both reference

ANSI C82.2-2002, DOE proposes to both update the reference and reorganize the test procedure

outlined in appendix Q for clarity.

10.References to ANSI C82.2-2002

As stated, in this NOPR DOE is proposing amendments to the fluorescent lamp ballast

test procedure that would incorporate references to ANSI C82.2-2002 into appendix Q and

appendix Q1. In examining the ANSI standard, DOE found that within ANSI C82.2-2002 there

are references other ANSI standards. In particular, section 2 of ANSI C82.2-2002 states that

"when American National Standards referred to in this document [ANSI C82.2-2002] are

superseded by a revision approved by the American National Standards Institute, Inc. the

revision shall apply." Revisions to these normative standards could potentially impact

compliance with energy conservation standards by changing the tested value for energy

efficiency. Therefore, DOE proposes to specify the particular versions of the ANSI standards

that would be used in conjunction with ANSI C82.2-2002. DOE proposes to use ANSI C78.81-

2005, ANSI C78.901-2005, ANSI C82.1-2004, ANSI C82.11-2002, and ANSI C82.13-2002 in

support of ANSI C82.2-2002. All other normative references would be as directly specified in

ANSI C82.2-2002. These specifications would apply to the ANSI C82.2-2002 references in

Appendix Q and to the ANSI C82.2-2002 references in Appendix Q1. DOE conducted testing in

development of today's proposed test procedure for Appendix Q1 in accordance with the

aforementioned industry references.

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G. Burden to Conduct the Proposed Test Procedure
 

EPCA requires that [a]ny test procedures prescribed or amended under this section shall

be reasonably designed to produce test results which measure energy efficiency, energy use * * * 

or estimated annual operating cost of a covered product during a representative average use cycle

or period of use * * * and shall not be unduly burdensome to conduct.'' (42 U.S.C. 6293(b)(3)).

Today's proposed test procedure seeks to calculate the efficiency of a ballast by computing the

ratio of ballast output power (simulated lamp arc power) to ballast input power. This ratio is then

converted to ballast efficacy factor, the statutorily required efficiency metric. DOE believes its

proposed method minimizes burden on manufacturers while still achieving an effective test

procedure.

DOE sought to reduce manufacturer burden wherever possible. As described in section

III.F.2, DOE chose to test each ballast type using only one resistor load bank instead of using a

different load for each ballast factor and number of lamps associated with a ballast. DOE

believes this choice reduces burden on the manufacturer. In addition, the proposed test procedure

requires no additional measurement instrumentation beyond what ballast manufacturers use for

the existing test procedure and other general uses. The required measurement of ballast factor is

no different than the procedure manufacturers already use for reporting BF in their literature. The

use of resistors for measuring ballast input power and lamp arc power, however, does impose a

small incremental burden compared to the existing test procedure. DOE estimates the initial

purchase cost of resistors for a two-lamp ballast to be about $1000 to $2000 and does not believe

this additional materials burden is unreasonable due to the low cost and the fact that the materials

cost can be amortized over the span of many years because the resistors maintain integrity over a

long lifespan. The test procedure imposes a minimal incremental labor burden of about 30 to 60

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minutes for a two-lamp ballast over the existing test procedure to measure BE using the ballastresistor setup. For these reasons, even for small ballast manufacturers, DOE believes the testing

burden is not unduly burdensome. DOE invites comment on this issue.

H. Impact on Measured Energy Efficiency

In any rulemaking to amend a test procedure, DOE must determine "to what extent, if

any, the proposed test procedure would alter the measured energy efficiency . . . of any covered

product as determined under the existing test procedure." (42 U.S.C. 6293(e)(1)) If DOE

determines that the amended test procedure would alter the measured efficiency of a covered

product, DOE must amend the applicable energy conservation standard accordingly. (42 U.S.C.

6293(e)(2)) This proposed active mode test procedure does impact the reported BEF value. Some

products will test with higher or lower efficiency based on the new test procedure because of the

transfer equation between the measured parameters and the reported BEF value. DOE is

currently amending energy conservation standards for fluorescent lamp ballasts in the fluorescent

lamp ballast standards rulemaking. In that rulemaking, DOE will consider standards based on

the measured efficiency of the ballast in accordance with the test procedure proposed in this

active mode test procedure rulemaking consistent with 42 U.S.C. 6293(e)(2). DOE will use test

data that it collects in the course of both this test procedure rulemaking and the fluorescent lamp

ballast standards rulemaking when setting energy conservation standards for fluorescent lamp

ballasts.

I. Certification and Enforcement

Ballast manufacturers are currently not required to submit compliance statements and

certification reports. In this rulemaking, DOE proposes to require fluorescent lamp ballast

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manufacturers to follow the certification and enforcement requirements summarized in subpart F
 

of 10 CFR part 430.

DOE regulations at 10 CFR 430.62(a)(4) describe the format and content of a

certification report for consumer products. DOE proposes to include fluorescent lamp ballasts in

the list of products for which certification reports are required (along with specific energy

consumption metrics). The revised submission of data section will indicate that ballast

manufacturers should report ballast efficacy factor and power factor in certification reports. The

definition of "basic model" can be found at 10 CFR 430.2; the fluorescent lamp ballast test

procedure can be found in 10 CFR part 430, subpart B, Appendix Q, and the sampling plan can

be found at 10 CFR 430.24(q). Manufacturers would be required to follow all other provisions of

subpart F of 10 CFR part 430 for certification and enforcement applicable to all covered ballasts.

DOE proposes that certification statements and compliance reports be submitted in

accordance with the existing energy conservation standards one year after publication of this

rulemaking (publication approximately June 30, 2011). In addition, DOE proposes that

certification statements and compliance reports be submitted in accordance with the revised

energy conservation standards and possible expansion of scope of coverage one year after these

standards become effective (effective date of standards approximately June 30, 2014).

IV. Procedural Issues and Regulatory Review

A. Executive Order 12866

Today's proposed rule has been determined to not be a "significant regulatory action" 

under Executive Order 12866, "Regulatory Planning and Review," 58 FR 51735 (Oct. 4, 1993).

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Accordingly, this action was not subject to review under that Executive Order by the Office of
 

Information and Regulatory Affairs (OIRA) of the Office of Management and Budget (OMB).

B. National Environmental Policy Act

In this proposed rule, DOE proposes test procedure amendments that it expects will be

used to develop and implement future energy conservation standards for ballasts. DOE has

determined that this rule falls into a class of actions that are categorically excluded from review

under the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and DOE's

implementing regulations at 10 CFR part 1021. Specifically, this proposed rule would amend the

existing test procedures without affecting the amount, quality or distribution of energy usage, 

and, therefore, would not result in any environmental impacts. Thus, this rulemaking is covered

by Categorical Exclusion A5 under 10 CFR part 1021, subpart D, which applies to any

rulemaking that interprets or amends an existing rule without changing the environmental effect

of that rule. Accordingly, neither an environmental assessment nor an environmental impact

statement is required.

C. Regulatory Flexibility Act

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

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

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

impact on a substantial number of small entities. As required by Executive Order 13272, "Proper

Consideration of Small Entities in Agency Rulemaking," 67 FR 53461 (August 16, 2002), DOE

published procedures and policies on February 19, 2003, to ensure that the potential impacts of

its rules on small entities are properly considered during the DOE rulemaking process. 68 FR

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7990. DOE has made its procedures and policies available on the Office of the General
 

Counsel's website: http://www.gc.doe.gov.

The Small Business Administration (SBA) has set size thresholds for manufacturers of

fluorescent lamp ballasts that define those entities classified as "small businesses" for the

purposes of the RFA. DOE used the SBA's small business size standards to determine whether

any small manufacturers of fluorescent lamp ballasts would be subject to the requirements of the

rule. 65 FR 30836, 30850 (May 15, 2000), as amended at 65 FR 53533, 53545 (September 5, 

2000) and codified at 13 CFR part 121. The size standards are listed by North American

Industry Classification System (NAICS) code and industry description and are available at

http://www.sba.gov/idc/groups/public/documents/sba homepage/serv sstd tablepdf.pdf.

Fluorescent lamp ballast manufacturing is classified under NAICS 335311, "Power,

Distribution, & Specialty Transformer Manufacturing." The SBA sets a threshold of 750

employees or less for an entity to be considered as a small business for this category.

To better assess the potential impacts of the proposed standards for fluorescent lamp

ballasts on small entities, DOE conducted a more focused inquiry of the companies that could be

small manufacturers of fluorescent lamp ballasts. During its market survey, DOE used all

available public information to identify potential small manufacturers. DOE's research involved

several industry trade association membership directories, product databases, individual

company websites, and marketing research tools (e g. ., Dunn and Bradstreet reports) to create a

list of every company that manufactures or sells fluorescent lamp ballasts covered by this

rulemaking. DOE reviewed all publicly-available data and contacted select companies on its list, 

as necessary, to determine whether they met the SBA's definition of a small business

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manufacturer of covered fluorescent lamp ballasts. DOE screened out companies that did not
 

offer fluorescent lamp ballasts covered by this rulemaking, did not meet the definition of a

"small business," or are foreign owned and operated. Ultimately, DOE identified approximately

15 fluorescent lamp ballast manufacturers that produce covered fluorescent lamp ballasts and can

potentially be considered small businesses.

The proposed rule includes revisions to appendix Q and appendix Q1, as well as

certification reporting requirements. The revisions to appendix Q update an industry reference

and do not change the test method or increase testing burden. The only difference between the

two test procedures relates to the interference of testing instrumentation. Specifically, the input

power measurement of ANSI C82.2-2002 reduces the interference of instrumentation on the

input power measurement as compared to ANSI C82.2- 1984. The vast majority of companies

and testing facilities, however, already employ modern instrumentation that does not

significantly interfere with input power measurements. Thus, updating this industry reference

would not impose additional financial burden in terms of labor or materials. The proposed test

procedure in appendix Q1 imposes a minimal incremental burden compared to the existing test

procedure and industry practices. For a 2-lamp ballast, the new procedure requires a small

increase in the labor burden of 30 to 60 minutes and a relatively small increase in materials costs

($1000 to $2000 initial purchase price). Finally, DOE estimates that the proposed certification

reporting requirements would average 30 hours per response.

To analyze the testing burden impacts described above on small business manufacturers, 

DOE identified small business manufacturers of fluorescent lamp ballasts included in the

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preliminary scope of coverage considered in the fluorescent lamp ballast standards rulemaking as
 

described above. DOE sought to examine publically available financial data for these companies

to compare revenue and profit to the anticipated testing burden associated with this proposed test

procedure. DOE determined that all the identified small business manufacturers were privately

owned, and as a result, financial data was not publically available. Instead, DOE estimated

testing burden for a small business with 0.1 percent market share of covered fluorescent lamp

ballasts and revenue of approximately one million dollars. DOE assumed that this small

manufacturer would sell approximately 30 basic models of a single ballast type. Based on the

assumptions stated in the previous paragraphs, DOE estimated that the annual testing costs for

this small business would be about $10,000, constituting 1 percent of annual revenue. Including

the 30 hours per response for certification reporting, DOE believes this to be a small percentage

of revenue and not a significant impact.

On the basis of the foregoing, DOE tentatively concludes and certifies that this proposed

rule would not have a significant impact on a substantial number of small entities. Accordingly, 

DOE has not prepared a regulatory flexibility analysis for this rulemaking. DOE will provide its

certification and supporting statement of factual basis to the Chief Counsel for Advocacy of the

Small Business Administration for review under 5 U.S.C. 605(b).

D. Paperwork Reduction Act

This rule contains a collection-of-information requirement subject to the Paperwork

Reduction Act (PRA) which has been approved by OMB under control number 1910-1400.

Public reporting burden for compliance reporting for energy and water conservation standards is

estimated to average 30 hours per response, including the time for reviewing instructions, 

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searching existing data sources, gathering and maintaining the data needed, and completing and

reviewing the collection of information. Send comments regarding this burden estimate, or any

other aspect of this data collection, including suggestions for reducing the burden, to DOE (see

ADDRESSES) and by e-mail to Christine J. Kymn@omb.eop.gov.

Notwithstanding any other provision of the law, no person is required to respond to, nor

shall any person be subject to a penalty for failure to comply with, a collection of information

subject to the requirements of the PRA, unless that collection of information displays a currently

valid OMB Control Number.

E. Unfunded Mandates Reform Act of 1995

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) (Pub. L. 104-4) requires

each Federal agency to assess the effects of Federal regulatory actions on State, local, and Tribal

governments and the private sector. For proposed regulatory actions likely to result in a rule that

may cause expenditures by State, local, and Tribal governments, in the aggregate, or by the

private sector of $100 million or more in any one year (adjusted annually for inflation), section

202 of UMRA requires a Federal agency to publish estimates of the resulting costs, benefits, and

other effects on the national economy. (2 U.S.C. 1532(a), (b)) UMRA also requires Federal

agencies to develop an effective process to permit timely input by elected officers of State, local, 

and Tribal governments on a proposed "significant intergovernmental mandate." In addition, 

UMRA requires an agency plan for giving notice and opportunity for timely input to small

governments that may be affected before establishing a requirement that might significantly or

uniquely affect them. On March 18, 1997, DOE published a statement of policy on its process

for intergovernmental consultation under UMRA. 62 FR 12820. (This policy is also available at

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http://www.gc.doe.gov). Today's proposed rule contains neither an intergovernmental mandate, 

nor a mandate that may result in the expenditure of $100 million or more in any year, so these

requirements do not apply.

F. Treasury and General Government Appropriations Act, 1999

Section 654 of the Treasury and General Government Appropriations Act, 1999

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment for any

proposed rule that may affect family well-being. Today's proposed rule would not have any

impact on the autonomy or integrity of the family as an institution. Accordingly, DOE has

concluded that it is unnecessary to prepare a Family Policymaking Assessment.

G. Executive Order 13132

Executive Order 13132, "Federalism," 64 FR 43255 (August 4, 1999) imposes certain

requirements on agencies formulating and implementing policies or regulations that preempt

State law or that have Federalism implications. The Executive Order requires agencies to

examine the constitutional and statutory authority supporting any action that would limit the

policymaking discretion of the States and to carefully assess the necessity for such actions. The

Executive Order also requires agencies to have an accountable process to ensure meaningful and

timely input by State and local officials in the development of regulatory policies that have

Federalism implications. On March 14, 2000, DOE published a statement of policy describing

the intergovernmental consultation process it will follow in the development of such regulations.

65 FR 13735. DOE has examined this proposed rule and has determined that it would not have a

substantial direct effect on the States, on the relationship between the national government and

the States, or on the distribution of power and responsibilities among the various levels of

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government. EPCA governs and prescribes Federal preemption of State regulations as to energy
 

conservation for the products that are the subject of today's proposed rule. States can petition

DOE for exemption from such preemption to the extent, and based on criteria, set forth in EPCA.

(42 U.S.C. 6297(d)) No further action is required by Executive Order 13132.

H. Executive Order 12988

With respect to the review of existing regulations and the promulgation of new

regulations, section 3(a) of Executive Order 12988, "Civil Justice Reform," 61 FR 4729 (Feb. 7, 

1996), imposes on Federal agencies the general duty to adhere to the following requirements: (1) 

Eliminate drafting errors and ambiguity; (2) write regulations to minimize litigation; (3) provide

a clear legal standard for affected conduct rather than a general standard; and (4) promote

simplification and burden reduction. Section 3(b) of Executive Order 12988 specifically requires

that Executive agencies make every reasonable effort to ensure that the regulation: (1) Clearly

specifies the preemptive effect, if any; (2) clearly specifies any effect on existing Federal law or

regulation; (3) provides a clear legal standard for affected conduct while promoting

simplification and burden reduction; (4) specifies the retroactive effect, if any; (5) adequately

defines key terms; and (6) addresses other important issues affecting clarity and general

draftsmanship under any guidelines issued by the Attorney General. Section 3(c) of Executive

Order 12988 requires Executive agencies to review regulations in light of applicable standards in

sections 3(a) and 3(b) to determine whether they are met or it is unreasonable to meet one or

more of them. DOE has completed the required review and determined that, to the extent

permitted by law, the proposed rule meets the relevant standards of Executive Order 12988.

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I. Treasury and General Government Appropriations Act, 2001
 

Section 515 of the Treasury and General Government Appropriations Act, 2001 (Pub. L.

106-554; 44 U.S.C. 3516 note) provides for agencies to review most disseminations of

information to the public under guidelines established by each agency pursuant to general

guidelines issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002), 

and DOE's guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has reviewed today's

proposed rule under the OMB and DOE guidelines and has concluded that it is consistent with 

applicable policies in those guidelines.

J. Executive Order 13211

Executive Order 13211, "Actions Concerning Regulations That Significantly Affect

Energy Supply, Distribution, or Use," 66 FR 28355 (May 22, 2001), requires Federal agencies to

prepare and submit to OMB, a Statement of Energy Effects for any proposed significant energy

action. A "significant energy action" is defined as any action by an agency that promulgated or is

expected to lead to promulgation of a final rule, and that: (1) Is a significant regulatory action

under Executive Order 12866, or any successor order; and (2) is likely to have a significant

adverse effect on the supply, distribution, or use of energy; or (3) is designated by the

Administrator of OIRA as a significant energy action. For any proposed significant energy

action, the agency must give a detailed statement of any adverse effects on energy supply, 

distribution, or use should the proposal be implemented, and of reasonable alternatives to the

action and their expected benefits on energy supply, distribution, and use. Today's regulatory

action to amend the test procedure for measuring the energy efficiency of fluorescent lamp

ballasts is not a significant regulatory action under Executive Order 12866. Moreover, it would

not have a significant adverse effect on the supply, distribution, or use of energy, nor has it been

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designated as a significant energy action by the Administrator of OIRA. Therefore, it is not a
 

significant energy action, and, accordingly, DOE has not prepared a Statement of Energy Effects.

K. Executive Order 12630

Pursuant to Executive Order 12630, "Governmental Actions and Interference with 

Constitutionally Protected Property Rights," 53 FR 8859 (March 15, 1988), DOE has determined

that this rule would not result in any takings that might require compensation under the Fifth 

Amendment to the United States Constitution.

L. Section 32 of the Federal Energy Administration Act of 1974

Under section 301 of the Department of Energy Organization Act (Pub. L. 95-91; 42

U.S.C. 7101), DOE must comply with section 32 of the Federal Energy Administration Act of

1974, as amended by the Federal Energy Administration Authorization Act of 1977. (15 U.S.C.

788; FEAA) Section 32 essentially provides in relevant part that, where a proposed rule

authorizes or requires use of commercial standards, the notice of proposed rulemaking must

inform the public of the use and background of such standards. In addition, section 32(c) requires

DOE to consult with the Attorney General and the Chairman of the Federal Trade Commission

(FTC) concerning the impact of the commercial or industry standards on competition. The

proposed rule incorporates testing methods contained in the following commercial standards:

ANSI C82.2-2002, Method of Measurement of Fluorescent Lamp Ballasts. While today's

proposed test procedure is not exclusively based on ANSI C82.2-2002, one component of the test

procedure, namely measurement of ballast factor, adopts a measurement technique from ANSI

C82.2-2002 without amendment. The Department has evaluated these standards and is unable to

conclude whether they fully comply with the requirements of section 32(b) of the FEAA, (i.e., 

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that they were developed in a manner that fully provides for public participation, comment, and
 

review). DOE will consult with the Attorney General and the Chairman of the FTC concerning

the impact of these test procedures on competition, prior to prescribing a final rule.

V. Public Participation 

A. Attendance at Public Meeting

The time, date and location of the public meeting are listed in the DATES and

ADDRESSES sections at the beginning of this NOPR. To attend the public meeting, please

notify Ms. Brenda Edwards at (202) 586-2945. As explained in the ADDRESSES section, 

foreign nationals visiting DOE headquarters are subject to advance security screening

procedures.

B. Procedure for Submitting Requests to Speak

Any person who has an interest in the topics addressed in this notice, or who is a

representative of a group or class of persons that has an interest in these issues, may request an

opportunity to make an oral presentation at the public meeting. Such persons may hand-deliver

requests to speak to the address shown in the ADDRESSES section at the beginning of this

notice between 9:00 a.m. and 4:00 p.m., Monday through Friday, except Federal holidays.

Requests may also be sent by mail or email to: Ms. Brenda Edwards, U.S. Department of

Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW., 

Washington, DC 20585-0121, or Brenda.Edwards@ee.doe.gov. Persons who wish to speak

should include in their request a computer diskette or CD in WordPerfect, Microsoft Word, PDF, 

or text (ASCII) file format that briefly describes the nature of their interest in this rulemaking

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and the topics they wish to discuss. Such persons should also provide a daytime telephone
 

number where they can be reached.

DOE requests that those persons who are scheduled to speak submit a copy of their

statements at least one week prior to the public meeting. DOE may permit any person who

cannot supply an advance copy of this statement to participate, if that person has made

alternative arrangements with the Building Technologies Program in advance. When necessary, 

the request to give an oral presentation should ask for such alternative arrangements.

C. Conduct of Public Meeting

DOE will designate a DOE official to preside at the public meeting and may also employ

a professional facilitator to aid discussion. The public meeting will be conducted in an informal, 

conference style. The meeting will not be a judicial or evidentiary public hearing, but DOE will

conduct it in accordance with section 336 of EPCA (42 U.S.C. 6306). There shall not be

discussion of proprietary information, costs or prices, market share, or other commercial matters

regulated by U.S. anti-trust laws.

DOE reserves the right to schedule the order of presentations and to establish the

procedures governing the conduct of the public meeting. A court reporter will record the

proceedings and prepare a transcript.

At the public meeting, DOE will present summaries of comments received before the

public meeting, allow time for presentations by participants, and encourage all interested parties

to share their views on issues affecting this rulemaking. Each participant may present a prepared

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general statement (within time limits determined by DOE) before the discussion of specific
 

topics. Other participants may comment briefly on any general statements. At the end of the

prepared statements on each specific topic, participants may clarify their statements briefly and

comment on statements made by others. Participants should be prepared to answer questions

from DOE and other participants. DOE representatives may also ask questions about other

matters relevant to this rulemaking. The official conducting the public meeting will accept

additional comments or questions from those attending, as time permits. The presiding official

will announce any further procedural rules or modification of procedures needed for the proper

conduct of the public meeting.

DOE will make the entire record of this proposed rulemaking, including the transcript

from the public meeting, available for inspection at the U.S. Department of Energy, 6th Floor, 

950 L'Enfant Plaza, SW., Washington, DC 20024, (202) 586- 2945, between 9:00 a.m. and 4:00

p.m., Monday through Friday, except Federal holidays. The official transcript will also be posted

on the Webpage at http://www1.eere.energy.gov/buildings/appliance standards/residential/

fluorescent lamp ballasts.html.

D. Submission of Comments

DOE will accept comments, data, and information regarding the proposed rule no later

than the date provided at the beginning of this notice. Comments, data, and information

submitted to DOE's e-mail address for this rulemaking should be provided in WordPerfect, 

Microsoft Word, PDF, or text (ASCII) file format. Stakeholders should avoid the use of special

characters or any form of encryption, and wherever possible, comments should include the

electronic signature of the author. Comments, data, and information submitted to DOE via mail

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or hand delivery/courier should include one signed paper original. No telefacsimiles (faxes) will
 

be accepted.

According to 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 including all the information believed to be confidential, and one copy of the

document with the information believed to be confidential deleted. DOE will make its own

determination as to the confidential status of the information and treat it according to its

determination.

Factors of interest to DOE 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 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

upon which such information might lose its confidential nature due to the passage of time; and

(7) why disclosure of the information would be contrary to the public interest.

E. Issues on Which DOE Seeks Comment

Although comments are welcome on all aspects of this rulemaking, DOE is particularly

interested in receiving comments and views of interested parties concerning the following issues:

1. All Aspects of the Existing Test Procedure for Active Mode Energy Consumption

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DOE invites comment on all aspects of the existing test procedure for fluorescent lamp
 

ballasts for active mode energy consumption that appear at 10 CFR part 430, subpart B, 

appendix Q ("Uniform Test Method for Measuring the Energy Consumption of Fluorescent

Lamp Ballasts").

2. Appropriate Usage of ANSI Standards

DOE seeks comment on the appropriate use of ANSI C82.2-2002, ANSI C82.11 

Consolidated-2002, and ANSI C82.1-2004. See section III.E.3 for further detail.

3.Method of Measurement for Dimming Ballasts

DOE seeks comment on potential methods of measurement to determine the efficiency of

dimming ballasts if DOE decides to include them in the scope of energy conservation standards.

See section III.F.2 for further detail.

4.Resistor-based Ballast Efficiency Test Method

DOE seeks comment on the effectiveness of the proposed resistor-based BE test method

and its expected improvement in measurement variation. See section III.E.1 for further details.

5. Alternative Approaches to Amending the Test Procedure

DOE seeks comment from interested parties who do not support the proposed resistorbased ballast efficiency method on the lamp-based BE method and the light-output-based and

RSE test procedures (see sections III.E.2, III.E.3, and III.E.4 for further detail), or any other

procedure they believe is appropriate.

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6. Ballasts that do not Operate Resistors

DOE seeks comment on why some ballasts do not operate when connected to a resistor

load bank and DOE's proposal to measure BEF directly (as a light output measurement) for these

ballasts. DOE invites comment on other approaches to test these ballasts. See section III.F.8 for

further detail.

7.Ballast Factor Variation Due to Variations in Measured Lamp Power

DOE recognizes that in order to correlate measured BE to BEF using DOE's proposed

test procedure, the BF of the test ballast must be determined. DOE seeks comment on DOE's

approach to use light output-based measurement to determine ballast factor and the resulting

variation in ballast factor due to lamp manufacturing variations. DOE also requests comment on

impact of this variation in BF on the calculated BEF (according to the proposed test procedure).

See section III.F.3 for further detail.

8. Ballast Factor Binning

DOE seeks comment on the effect of DOE's approach of using a single resistor value for

measuring ballasts of all ballast factors (for a particular ballast) and correlating measured BE to

correlated BEF using transfer equations specific to ballast factor bins. See section III.F.5 for

further detail.

9. Transfer Equations

DOE seeks comment on the transfer equations developed to convert BE to BEF. See

section III.F.5 for further detail.

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10. Scaling Transfer Equations
 

DOE seeks comment on the transfer equation scaling techniques (across number of lamps

operated by a ballast, starting method, ballast factor, and total rated lamp power) used for

product classes in which there was insufficient correlation in the test data to establish a slope.

See section III.F.6 for further detail.

11.Burden on Manufacturers and Testing Facilities

DOE seeks comment on its assessment of the anticipated burden imposed by the

proposed test method. See section III.G for further detail.

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VI. Approval of the Office of the Secretary
 

The Secretary of Energy has approved publication of this proposed rule.

List of Subjects in 10 CFR Part 430

Administrative practice and procedure, Confidential business information, Energy conservation, 

Household appliances, Imports, Incorporation by reference, Intergovernmental relations, Small

businesses.

Issued in Washington, DC on February 12, 2010.

Cathy Zoi

Assistant Secretary

Energy Efficiency and Renewable Energy

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For the reasons stated in the preamble, DOE is proposing to amend Part 430 of Chapter II
 

of Title 10, Code of Federal Regulations as set forth below:

PART 430-ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS

1. The authority citation for Part 430 continues to read as follows:

 Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.

2. Section 430.3 is amended by:

a. Revising paragraphs (c)(5), (c)(7) and (c)(11) by adding at the end of the paragraphs

the words "and Appendix Q1 of subpart B".

b. Redesignating paragraphs (c)(11) as (c)(12); (c)(12) as (c)(15); and (c)(13) as (c)(16).

c. Adding new paragraphs (c)(11), (c)(13) and (c)(14 ).

These revisions and additions read as follows:

§ 430. 3 Materials incorporated by reference.

* * * * *

(c) * * *

(11) ANSI C82.1-2004, Revision of ANSI C82.1-1997 ("ANSI C82.1"), American National

Standard for Lamp Ballast - Line-Frequency Fluorescent Lamp Ballast, approved November 19, 

2004; IBR approved for Appendix Q of subpart B and Appendix Q1 of subpart B.

* * * * * 

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(13) ANSI C82.11-2002, Revision of ANSI C82.11-1993 ("ANSI C82.11"), American National
 

Standard for Lamp Ballasts - High-frequency Fluorescent Lamp Ballasts, approved January 17, 

2002; IBR approved for Appendix Q of subpart B and Appendix Q1 of subpart B.

(14) ANSI C82.13-2002 ("ANSI C82.13"), American National Standard for Lamp Ballasts -

Definitions for Fluorescent Lamps and Ballasts, approved July 23, 2002; IBR approved for
 

Appendix Q of subpart B and Appendix Q1 of subpart B.
 

* * * * * 

3. Section 430.23 is amended by revising paragraph (q) to read as follows:
 

§ 430.23 Test procedures for the measurement of energy and water consumption. 

* * * * * 

(q) Fluorescent �amp �allasts. (1) The Estimated Annual Energy Consumption (EAEC) for

fluorescent lamp ballasts, expressed in kilowatt-hours per year, shall be the product of:

 (i) The input power in kilowatts as determined in accordance with section 3.1.3.1 of

appendix Q to this subpart before the compliance date of the amended standards for fluorescent

lamp ballasts or section 7.1.2.2 of appendix Q1 to this subpart beginning on the compliance date

of the amended standards for fluorescent lamp ballasts; and

 (ii) The representative average use cycle of 1,000 hours per year, the resulting product

then being rounded off to the nearest kilowatt-hour per year.

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 (2) Ballast Efficacy Factor (BEF) shall be as determined in section 4.2 of appendix Q of
 

this subpart before the compliance date of the amended standards for fluorescent lamp ballasts or

section 8.3 of appendix Q1 to this subpart beginning on the compliance date of the amended

standards for fluorescent lamp ballasts.

 (3) The Estimated Annual Operating Cost (EAOC) for fluorescent lamp ballasts, 

expressed in dollars per year, shall be the product of:

 (i) The representative average unit energy cost of electricity in dollars per kilowatt-hour

as provided by the Secretary, 

(ii) The representative average use cycle of 1,000 hours per year, and

(iii) The input power in kilowatts as determined in accordance with section 3.1.3.1 of

appendix Q to this subpart before the compliance date of the amended standards for fluorescent

lamp ballasts or section 7.1.2.2 of appendix Q1 to this subpart beginning on the compliance date

of the amended standards for fluorescent lamp ballasts, the resulting product then being rounded

off to the nearest dollar per year.

 (4) Standby power consumption of certain fluorescent lamp ballasts shall be measured in

accordance with section 3.2 of appendix Q to this subpart.

* * * * * 

4. Appendix Q to Subpart B of Part 430 is amended by:

a. Adding an introductory paragraph after the Appendix heading.

b. Revising sections 1.15, 1.16, and 1.17.

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* * � � �

c. Removing section 2.1, redesignating section 2.2 as section 2, and revising redesignated
 

section 2.

d. Redesignating sections 3.1, 3.2, 3.3, 3.3.1, 3.3.2, 3.3.3, 3.4, 3.4.1, and 3.4.2 as sections

3.1.1, 3.1.2, 3.1.3, 3.1.3.1, 3.1.3.2, 3.1.3.3, 3.1.4, 3.1.4.1, and 3.1.4.2, respectively.

e. Revising redesignated sections 3.1.1, 3.1.2, 3.1.3.1, 3.1.3.2, 3.1.3.3, 3.1.4.1, and 3.1.4.2.

f. Redesignating sections 3.5, 3.5.1, 3.5.2, 3.5.3, 3.5.3.1, 3.5.3.2, 3.5.3.3, and 3.5.3.4 as

sections 3.2, 3.2.2, 3.2.3, 3.2.4, 3.2.4.1, 3.2.4.2, 3.2.4.3, and 3.2.4.4, respectively.

g. Adding sections 3.1 and 3.2.1.

h. Revising section 4..

These revisions and additions read as follows:

Appendi� � to Subpart B of Part 430�Uniform Test Method for Measuring the Energy 

Consumption of Fluorescent Lamp Ballasts 

Appendix Q is effective until the compliance date of the amended standards for fluorescent lamp

ballasts. After this date, all fluorescent lamp ballasts shall be tested using the provisions of

Appendix Q1 except where Appendix Q1 specifies use Appendix Q for testing certain ballasts

that do not operate resistors.

1. Definitions.

* * * 

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1.15 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

C82.2-2002 (incorporated by reference; see � 430.3).

1.16 Power input means the power consumption in watts of a ballast an fluorescent lamp or

lamps, as determined in accordance with the test procedures specified in ANSI C82.2-2002

(incorporated by reference; see � 430.3).

1.17 Relative lig�t output means the light output delivered through the use of a ballast divided by

the light output of a reference ballast, expressed as a percent, as determined in accordance with 

the test procedures specified in ANSI C82.2-2002 (incorporated by reference; see � 430.3).

* * * * * 

2. Test Conditions. The measurement of standby mode power need not be performed to

determine compliance with energy conservation standards for fluorescent lamp ballasts at this

time. The above statement will be removed as part of a rulemaking to amend the energy

conservation standards for fluorescent lamp ballasts to account for standby mode energy

consumption, and the following shall apply on the compliance date for such requirements. The

test conditions for testing fluorescent lamp ballasts shall be done in accordance with ANSI

C82.2-2002 (incorporated by reference; see � 430.3). Any subsequent amendment to this

standard by the standard setting organization will not affect the DOE test procedures unless and

until amended by DOE. The test conditions for measuring active mode energy consumption are

described in sections 4, 5, and 6 of ANSI C82.2-2002. The test conditions for measuring standby

power are described in sections 5, 7, and 8 of ANSI C82.2-2002. Fluorescent lamp ballasts that

are capable of connections to control devices shall be tested with all commercially available

compatible control devices connected in all possible configurations. For each configuration, a

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separate measurement of standby power shall be made in accordance with section 4 of the test
 

procedure.

3. * * * 

3.1 Active Mode Energy Efficiency Measurement

3.1.1 The test method for testing the active mode energy efficiency of fluorescent lamp ballasts

shall be done in accordance with ANSI C82.2-2002 (incorporated by reference; see � 430.3).

Where ANSI C82.2-2002 references ANSI C82.1-1997, the operator shall use ANSI C82.1 

(incorporated by reference; see � 430.3) for testing low-frequency ballasts and ANSI C82.11 

(incorporated by reference; see � 430.3) for high-frequency ballasts.

3.1.2 �nstrumentation. The instrumentation shall be as specified by sections 5, 7, 8, and 15 of

ANSI C82.2-2002 (incorporated by reference; see �430.3).

3.1.3 * * *

3.1.3.1 �nput Power. Measure the input power (watts) to the ballast in accordance with ANSI

C82.2-2002 (incorporated by reference; see �430.3), section 4.

3.1.3.2 �nput �oltage. Measure the input voltage (volts) (RMS) to the ballast in accordance with 

ANSI C82.2-2002 (incorporated by reference; see �430.3), section 3.2.1 and section 4.

3.1.3.3 �nput Current. Measure the input current (amps) (RMS) to the ballast in accordance with 

ANSI C82.2-2002 (incorporated by reference; see �430.3), section 3.2.1 and section 4.

3.1.4 * * *

3.1.4.1 Measure the light output of the reference lamp with the reference ballast in accordance

with ANSI C82.2-2002 (incorporated by reference; see �430.3), section 12.

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3.1.4.2 Measure the light output of the reference lamp with the test ballast in accordance with 

ANSI C82.2-2002 (incorporated by reference; see �430.3), section 12.

3.2. * * * 

3.2.1 The test for measuring standby mode energy consumption of fluorescent lamp ballasts

shall be done in accordance with ANSI C82.2-2002 (incorporated by reference; see � 430.3).

* * * * * 

4. Calculations.

4.1 Calculate relative light output:

Where:
 

photocell output of lamp on test ballast is determined in accordance with section 3.1.4.2, 

expressed in watts, and photocell output of lamp on ref. ballast is determined in accordance with 

section 3.1.4.1, expressed in watts.
 

4.2. Determine the Ballast Efficacy Factor (BEF) using the following equations:

(a) Single lamp ballast

(b) Multiple lamp ballast
 

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Where:
 

Input power is determined in accordance with section 3.1.3.1, 

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 3.1.3.1, 

Input voltage is determined in accordance with section 3.1.3.2, expressed in volts, and
 

Input current is determined in accordance with section 3.1.3.3, expressed in amps.
 

5. Appendix Q1 is added to Subpart B of Part 430 to read as follows:

Appendi� �1 to Subpart B of Part 430-Uniform Test Method for Measuring the Energy 

Consumption of Fluorescent Lamp Ballasts 

Appendix Q1 is effective on the compliance date of the amended standards for fluorescent lamp

ballasts. Prior to this date, all fluorescent lamp ballasts shall be tested using the provisions of

Appendix Q.

1. If the operator determines that a ballast does not operate a resistor load bank, then the

operator should use the test procedure described in Appendix Q to Subpart B of Part 430. To

determine that a ballast does not operate a resistor load bank, the input power, voltage, or

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current to the ballast should equal zero when tested in accordance with this Appendix Q1 to
 

Subpart B of Part 430.

2.	 Where ANSI C82.2-2002 (incorporated by reference; see � 430.3) references ANSI C82.1-

1997, the operator shall use ANSI C82.1 (incorporated by reference; see � 430.3) for testing

low-frequency ballasts and shall use ANSI C82.11 (incorporated by reference; see � 430.3) 

for high-frequency ballasts.

3.	 Definitions

3.1. Commercial ballast is a fluorescent lamp ballast that is not a residential ballast as

defined in Section 3.8 and meets technical standards for non-consumer RF lighting

devices as specified in subpart C of 47 CFR part 18.

3.2.	 Electrode �eating refers to power delivered to the lamp by the ballast for the purpose

of raising the temperature of the lamp electrode or filament. ANSI standards generally

refer to this process as cathode heating.

3.3.	 Hig�-fre�uency ballast is as defined in ANSI C82.13 (incorporated by reference; see �

430.3).

3.4.	 �nstant-start is the starting method used instant-start systems as defined in ANSI

C82.13 (incorporated by reference; see � 430.3).

3.5.	 �ow-fre�uency ballast is a fluorescent lamp ballast that operates at a supply frequency

of 50 to 60 Hz and operates the lamp at the same frequency as the supply.

3.6.	 Programmed-start is the starting method used in programmed start systems as defined

in ANSI C82.13 (incorporated by reference; see � 430.3).

3.7.	 Rapid-start is the starting method used in rapid-start type systems as defined in ANSI

C82.13 (incorporated by reference; see � 430.3).

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3.8. Residential ballast is a fluorescent lamp ballast designed and labeled for use in
 

residential applications. Residential ballasts must meet the technical standards for

consumer RF lighting devices as specified in subpart C of 47 CFR part 18.

3.9.	 Resistor load bank means a network of resistors used to model the load placed on a

fluorescent lamp ballast by a fluorescent lamp.

3.10.	 RMS is the root mean square of a varying quantity.

4. Instruments

4.1. All instruments shall be as specified by ANSI C82.2-2002 (incorporated by reference; 

see � 430.3).

4.2. Power Analyzer. In addition to the specifications in ANSI C82.2-2002 (incorporated by

reference; see § 430.3), the power analyzer shall have a maximum 100 pF capacitance to

ground and frequency response between 40 Hz and 1 MHz.

4.3. Current Probe. In addition to the specifications in ANSI C82.2-2002 (incorporated by

reference; see § 430.3), the current probe shall be galvanically isolated and have

frequency response between 40 Hz and 20 MHz.

5. Test Setup

5.1. The ballast shall be connected to a main power source and to the resistor load bank

according to the manufacturer's wiring instructions. Where the wiring diagram indicates

connecting the ballast lead to a lamp, the lead should be connected to a resistor load

bank.

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5.1.1. Figures 1 and 2 illustrate the resistor load bank used to model one fluorescent
 

lamp. The four resistors labeled as R1/2E represent the electrodes, and Rarc represents

the lamp arc.

5.1.2. Wire lengths between the ballast and resistor load bank shall be the length 

provided by the ballast manufacturer.
 

5.2. A ballast shall be tested using one resistor load bank to simulate one lamp. A ballast

shall be connected to the number of resistor load banks equal to the maximum number of

lamps a ballast is designed to operate.

5.3. A ballast designed to operate a lamp at high-frequency (as defined in section 3.3) shall

use a resistor with resistance that simulates high-frequency operation. A ballast designed

to operate a lamp a low-frequency (as defined in section 3.5) shall use a resistor with 

resistance that simulates low-frequency operation.

5.4. A ballast shall be tested with a resistor load bank with the resistances indicated in Table

A.

5.5. Power Analyzer

5.5.1. The power analyzer shall have n+1 channels where n is the number of lamps a

ballast operates.

5.5.2.	 Output Voltage. Leads from the power analyzer should attach to each resistor load

bank according to Figure 1 for rapid- and programmed-start ballasts and Figure 2

for instant-start ballasts.

5.5.3.	 Output Current. A current probe shall be positioned on each resistor load bank

according to Figure 1 for rapid- and programmed-start ballasts and Figure 2 for

instant-start ballasts.

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Table A - Simulated Lamp Resistor Values
 

Ballast Type Nominal 

Lamp

Wattage

Lamp

Diameter 

and Base 

Low-Frequency

Operation Resistance 

(Ohms)

High-Frequency

Operation Resistance 

(Ohms)

Electrode 

(RlI2E)

Lamp

Arc 

(Rarc)

Electrode 

(RlI2E)

Lamp Arc 

(Rarc)

Ballasts that operate one, two, 

three, four, five, or six straightshaped lamps (commonly referred

to as 4-foot medium bipin lamps) 

with medium bipin bases, a

nominal overall length of 48 

inches, a rated wattage of 25W or

more, and an input voltage at or

between 120V and 277V 

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one, two, 

three, four, five, or six U-shaped

lamps (commonly referred to as

2-foot U-shaped lamps) with 

medium bipin bases, a nominal

overall length between 22 and 25

inches, a rated wattage of 25W or

more, and an input voltage at or

between 120V and 277V 

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one or two

rapid-start lamps (commonly

referred to as 8-foot high output

lamps) with recessed double

contact bases, a nominal overall

length of 96 inches and an input

voltage at or between 120V and

277V 

86 T8 HO

RDC

N/A N/A 4.75 538 

95 T12 HO

RDC

1.6 131 1.6 204

Ballasts that operate one or two

instant-start lamps (commonly

referred to as 8-foot slimline

lamps) with single pin bases, a

nominal overall length of 96

inches, a rated wattage of 52W or

more, and an input voltage at or

between 120V and 277V 

59 T8 

slimline

SP

N/A* 876 N/A* 1256

60 T12

slimline

SP

N/A* 313 N/A* 431 

Ballasts that operate one or two

straight-shaped lamps (commonly

referred to as 4-foot miniature

bipin standard output lamps) with 

miniature bipin bases, a nominal

length between 45 and 48 inches, 

a rated wattage of 26W or more, 

and an input voltage at or

between 120V and 277V 

28 T5 MiniBPN/A N/A 20 950

Ballasts that operate one, two, 

three, or four straight-shaped

lamps (commonly referred to as

54 T5 MiniBPN/A N/A 4 255

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4-foot miniature bipin high output

lamps) with miniature bipin

bases, a nominal length between

45 and 48 inches, a rated wattage

of 49W or more, and an input

voltage at or between 120V and

277V 

Ballasts that operate one, two, 

three, or four straight-shaped

lamps (commonly referred to as

4-foot medium bipin lamps) with 

medium bipin bases, a nominal

overall length of 48 inches, a

rated wattage of 25W or more, an

input voltage at or between 120V 

and 277V, a power factor of less

than 0.90, and that are designed

and labeled for use in residential

applications

32 T8 MBP 5.75 439 5.75 760

34 T12 MBP 4.8 151 4.8 204

Ballasts that operate one, two, 

three, four, five, or six rapid-start

lamps (commonly referred to as

8-foot high output lamps) with 

recessed double contact bases, a

nominal overall length of 96

inches, an input voltage at or

between 120V and 277V, and that

operate at ambient temperatures

of 20 OF or less and are used in

outdoor signs

86 T8 HO

RDC

N/A N/A 4.75 538 

110 T12 HO

RDC

1.6 166 1.6 275

MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, 

respectively.

* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.

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Figure 1 Instrumentation Placement for Ballasts that Operate MBP� RDC� and MiniBP

Lamps

Figure 2 Instrumentation Placement for Ballasts that Operate SP Lamps 

6. Test Conditions

6.1. The test conditions for testing fluorescent lamp ballasts shall be done in accordance with 

ANSI C82.2-2002 (incorporated by reference; see § 430.3). DOE further specifies that

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the following revisions of the normative references indicated in ANSI C82.2-2002) 

should be used in place of the references directly specified in ANSI C82.2-2002� ANSI

C78.81 (incorporated by reference; see § 430.3), ANSI C78.901 (incorporated by

reference; see § 430.3), ANSI C82.1 (incorporated by reference; see § 430.3), ANSI

C82.3 (incorporated by reference; see § 430.3), ANSI C82.11 (incorporated by

reference; see § 430.3), and ANSI C82.13 (incorporated by reference; see § 430.3). All

other normative references shall be as specified in ANSI C82.2-2002.

6.2. Temperature Stabilization. Ballasts shall be thermally conditioned for at least 4 hours at

room temperature (25 ± 2OC), with normal room or lab ventilation.

6.3. �nput Voltage. The directions in ANSI C82.2-2002 (incorporated by reference; see §

430.3) section 4.1 should be ignored with the following directions for input voltage used

instead. For commercial ballasts capable of operating at multiple voltages, the ballast

shall be tested 277V ± 0.1�. For ballasts designed and labeled for residential

applications and capable or operating at multiple voltages, the ballast shall be tested at

120V ± 0.1�.

6.4. Duty Cycle. The duty cycle shall be no more than 50�. For every operational minute, 

the resistor load bank shall be rested at zero power for at least one minute.

7. Test Method

7.1. �allast Efficiency.

7.1.1. The ballast shall be connected the appropriate resistor load bank and to

measurement instrumentation as indicated by the Test Setup in section 5.

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7.1.2. The ballast shall be operated for one minute followed by an instantaneous data
 

capture of the parameters described in sections 7.1.2.1 through 7.1.2.4.

7.1.2.1. Output Power. The power analyzer shall calculate output power by

capturing voltage across the each lamp arc resistor using the setup described in

5.5.2 and current to the lamp according to the setup described in 5.5.3 and

summing the power for each lamp.

7.1.2.2. �nput Power. Measure the input power (watts) to the ballast in accordance

with ANSI C82.2-2002 (incorporated by reference; see § 430.3), section 7.

7.1.2.3. �nput Voltage. Measure the input voltage (volts) (RMS) to the ballast in

accordance with ANSI C82.2-2002 (incorporated by reference; see § 430.3), 

section 3.2.1 and section 4.

7.1.2.4. �nput Current. Measure the input current (amps) (RMS) to the ballast in

accordance with ANSI C82.2-2002 (incorporated by reference; see § 430.3), 

section 3.2.1 and section 4.

7.2. �allast Factor.

7.2.1. ANSI C82.2-2002 (incorporated by reference; see § 430.3) shall be further

specified for the purpose of measuring ballast factor by the following�

7.2.1.1. The reference lamp shall be operated at the specified input voltage to the

reference circuit.

7.2.1.2. Electrode heating shall be used in the reference circuit for all ballasts that

operate bipin (MBP, mini-BP) or recessed double contact (RDC) lamps as

indicated in Table A. Electrode heating shall not be used in the reference

circuit for single pin lamps.

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7.2.1.3. Light output measurements shall be used for all ballasts, including instantstart ballasts. Power measurements shall not be used.

7.2.2.	 Measure the light output of the reference lamp with the reference ballast in

accordance with ANSI C82.2-2002 (incorporated by reference; see § 430.3), section

12, using section 7.2.1 to further specify ANSI C82.2-2002. The reference lamp

shall have the nominal wattage corresponding to the test ballast as indicated in

Table A.

7.2.3.	 Measure the light output of the reference lamp with the test ballast in accordance

with ANSI C82.2-2002 (incorporated by reference; see § 430.3), section 12, using

section 7.2.1 to further specify ANSI C82.2-2002 The reference lamp shall have the

nominal wattage corresponding to the test ballast as indicated in Table A.

8. Calculations

8.1. Calculate ballast factor (BF)�

Photocell output of lamp on test ballast Ballast Factor = x100

Photocell output of lamp on reference ballast

Where� photocell output of lamp on test ballast is determined in accordance with section

7.2.2, expressed in watts, and photocell output of lamp on reference ballast is determined

in accordance with section 7.2.3, expressed in watts.

8.2. Calculate ballast efficiency (BE).

8.3. Calculate ballast efficacy factor (BEF). Multiply BE by the appropriate conversion

factor in Table B. BEF = conversion factor x BE
 

Table B - Conversion Factor� BE to BEF 

Ballast

and Lamp

Starting 

Method 

Ballast

Factor Number of Lamps

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Type One Two Three Four Five Six 

Four-Foot

MBP, and

Two-Foot

U-Shaped

IS and

RS (not

PS) 

High 3.233 1.624 1.081 0.812 0.650 0.542

Normal 3.378 1.697 1.129 0.849 0.679 0.566

Low 3.430 1.723 1.147 0.862 0.690 0.575

PS

High 3.204 1.610 1.071 0.808 0.644 0.537

Normal 3.348 1.682 1.119 0.844 0.673 0.561 

Low 3.400 1.708 1.137 0.857 0.684 0.570

Four-Foot

T5

MiniBP

SO

All

High 2.910 1.584 --- --- --- ---

Normal 3.041 1.655 --- --- --- ---

Low 3.088 1.680 --- --- --- ---

Four-Foot

T5

MiniBP

HO

All All 1.703 0.927 0.649 0.504 --- ---

Eight-Foot

SP

Slimline

All

High 1.653 0.841 --- --- --- ---

Normal 1.727 0.878 --- --- --- ---

Low 1.754 0.892 --- --- --- ---

Eight-Foot

RDC HO

IS and

RS (not

PS) 

All 1.128 0.614 --- --- --- ---

PS All 1.138 0.619 --- --- --- ---

Residential

Ballast, 

Four-Foot

MBP, and

Two-Foot

U-Shaped

IS and

RS (not

PS) 

All 3.357 1.686 1.122 0.853 --- ---

PS All 3.328 1.671 1.113 0.846 --- ---

Sign

Ballast All All 0.888 0.483 0.338 0.263 0.216 0.184

* IS = Instant-start; RS = Rapid-start; PS = Programmed-start

**High ballast factor� BF � 1.10; Normal ballast factor� 0.78 � BF �1.10; Low ballast factor� BF � 0.78.

8.4. Calculate Power Factor (PF).

Input Power Power Factor = Input Voltagex Input Current

Where� input power is determined in accordance with section 7.1.2.2, input voltage is

determined in accordance with section 7.1.2.2 and input current in determined in

accordance with section 7.1.2.3

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6. Section 430.62 is amended by revising paragraph (a)(1), and adding new paragraphs
 

(a)(4)(xxv) and (a)(6) to read as follows�

§ 430.62 Submission of data. 

(a)(1) Except as provided in paragraph (a)(2) and (a)(6) of this section, each manufacturer or

private labeler before distributing in commerce any basic model of a covered product subject to

the applicable energy conservation standard or water conservation standard (in the case of

faucets, showerheads, water closets, and urinals) set forth in subpart C of this part shall certify by

means of a compliance statement and a certification report that each basic model(s) meets the

applicable energy conservation standard or water conservation standard (in the case of faucets, 

showerheads, water closets, and urinals) as prescribed in section 325 of the Act. The compliance

statement, signed by the company official submitting the statement, and the certification report(s) 

shall be sent by certified mail to� Department of Energy, Office of Energy Efficiency and

Renewable Energy, Office of Codes and Standards, Forrestal Building, 1000 Independence

Avenue, SW, Washington, DC 20585-0121.

* * * * * 

(4) * * * 

(xxv) Fluorescent Lamp Ballasts, the ballast efficacy factor (BEF) and the ballast power factor
 

(PF).
 

* * * * * 

(6) Each manufacturer or private labeler of a basic model of a covered fluorescent lamp ballast
 

shall file a compliance statement and a certification report to DOE using the test procedure
 

described in Appendix Q to Subpart B of Part 430 within 1 year of publication of the fluorescent
 

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lamp ballast test procedure and energy conservation standard final rulemaking. Furthermore, 

each manufacturer or private labeler of a basic model of a covered fluorescent lamp ballast shall

file a compliance statement and a certification report to DOE using the test procedure described

in Appendix Q1 to Subpart B of Part 430 before within 4 years of publication of the fluorescent

lamp ballast test procedure and energy conservation standards final rulemaking..

* * * * * 

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