3-i CHAPTER 3. MARKET AND TECHNOLOG Y ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3-1
3.1.1 Definitions

................................ ................................ ............................................ 3-1
3.1.1.1 Ballast Efficacy Factor ............................................................................. 3-1
3.1.1.2 Ballast Luminous Efficiency .................................................................... 3-1
3.1.1.3 Fluor escent Lamp

................................ ..................................................... 3-2
3.1.1.4 Fluorescent Lamp Ballast ........................................................................ 3-3
3.1.2 Replacement Ballast

................................ ............................................................. 3-3
3.2 MARKET ASSESSMENT .............................................................................................. 3-4
3.2.1 Trade Associations ............................................................................................... 3-4
3.2.2 Manufacturers and Market Share ......................................................................... 3-5
3.2.2.1 Small Businesses ...................................................................................... 3-5
3.2.3 Regulatory Programs ........................................................................................... 3-6
3.2.3.1 Federal En ergy Conservation Standards .................................................. 3-6

3.2.3.2 California Energy Commission

................................ ................................ 3-9
3.2.3.3 Canadian Energy Efficiency Standards ................................................... 3-9
3.2.3.4 European Energy Efficiency Standards ................................................. 3-11

3.2.4 Non

- Regulatory Initiatives

................................ ................................................. 3-11
3.2.4.1 Federal Energy Management Program .................................................. 3-11

3.2.4.2 Consortium for Energy Efficiency ......................................................... 3-12

3.2.4.3 NEMA Prem ium .................................................................................... 3-13

3.2.4.4 ENERGY STAR .................................................................................... 3-13
3.2.4.5 Energy Efficient Commercial Building Deduction ................................ 3-14
3.2.4.6 Northeast Energy Efficiency Partnerships ............................................. 3-14

3.2.5 Historical Shipments .......................................................................................... 3-14
3.3 TECHNOLO GY ASSESSMENT .................................................................................. 3-21
3.3.1 Basic Structure of Fluorescent Lamps ............................................................... 3-21
3.3.2 Electrical Characteristics of a Fluorescent Discharge L amp ............................. 3-22
3.3.3 Fluorescent Lamp Ballast Overview .................................................................. 3-23
3.3.3.1 Starting Method ..................................................................................... 3-24
3.3.3.2 Ballast Factor ......................................................................................... 3-25
3.3.3.3 Ballast Efficacy Factor ........................................................................... 3-25
3.3.3.4 Ballast Luminous Efficiency .................................................................. 3-25
3.3.3.5 Power Factor .......................................................................................... 3-26
3.3.3.6 Total Harmonic Distortion ..................................................................... 3-26
3.3.3.7 Electromagnetic Interference ................................................................. 3-27
3.3.3.8 Safety ..................................................................................................... 3-27
3.3.4 Fluorescent Lamp Ballast Technology Options ................................................. 3-28
3.3.4.1 Magnetic Ballasts ................................................................................... 3-28
3.3.4.2 Electronic Ballasts ................................................................................. 3-29
3.3.4.3 Impro ved Components ........................................................................... 3-32

3.3.4.4 Improved Circuit Design........................................................................ 3-333- ii 3.4 PRODUCT CLASSES ................................................................................................... 3-34
3.4.1 Power versus Efficiency Relationship ............................................................... 3-35
3.4.2 Starting Method ................................................................................................. 3-36
3.4.3 Lumen Package .................................................................................................. 3-36

3.4.4 Sign Ballasts

................................ ................................ ....................................... 3-37
3.4.5 Product Classes .................................................................................................. 3-37
REFERENCES .......................................................................................................................... 3-39

LIST OF TABLES

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts ...................................................... 3-6
Table 3.2.2 2000 Ballast Rule St andards for Fluorescent Lamp Ballasts .................................... 3-7 Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts ........................................... 3-8 Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts ............................................... 3-10 Table 3.2.5 Federal Energy Management Program Efficiency Recommendation .................... 3-12
Tabl e 3.2.6 CEE High- Performance T8 Ballast Specifications ................................................. 3-12 Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications .................................................. 3-13
Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U- Shaped Ballasts and Lamps
and Four-Foot T12 MBP and Two-Foot U- Shaped Ballasts and Lamps ................................... 3-17 Table 3.2.9 Shipments of Eight- Foot Slimlin e T8 and Eight- Foot SP Slimline T12 Ballasts and Lamps ......................................................................................................................................... 3-18 Table 3.2.10 T12 High- Output Ballast Market Share ................................................................ 3-19
Table 3.3.1 C ommon Linear Fluorescent Lamp Nomenclature ................................................ 3-22 Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and
Associated Characteristics ......................................................................................................... 3-30 Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp Ballasts

................................ ................................ ................................ .................................................... 3-35 Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp Ballasts 3-
35 Table 3.4.3 Product Classes for Fluorescent Lamp Ballasts ...................................................... 3-38

LIST OF FIGURES

Figure 3.2.1 2005 Ballast Market Share .................................................................................... 3-15 Figure 3.2.2 Magnetic and Electronic Ballast Market Share ..................................................... 3-16 Figure 3 .2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps ................................. 3-17 Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight- Foot SP Slimline T12 Ballasts . 3-18 Figure 3.2.5 Shipments of Residential Ballasts ......................................................................... 3-20 Figure 3.2.6 Shipments of T5 High- Output Ballasts ................................................................. 3-21 Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp ............................................... 3-23 Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast ................................... 3-283- iii Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp ............................ 3-29 Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast ............................................. 3-30 Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram ..................... 3-303-1 CHAPTER 3. MARKET AND TECHNOLOG Y ASSESSMENT

3.1 INTRODUCTION

This chapter consists of three sections: the market asse ssment, the technology assessment, and product classes. The market assessment provides an overall picture of the market for the products concerned, including the nature of the products, industry structure, and manufacturer market shares; regulatory and non- regulatory efficiency improvement programs; and market trends and quantities of products sold. The technology assessment identifies a list of technologies to consider in the screening analysis. The product classes section discusses the product classes the U.S. Department of Energy ( DOE ) considered using for this rulemaking and how they were developed.

The information DOE gathers from the market and technology assessment serves as resource material for use throughout the rulemaking. DOE considers both quant itative and qualitative information from publicly available sources and interested parties.

3.1.1 Definitions

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

As part of this energy conservation standards rulemaking, DOE is considering extending coverage to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following sections describe in more detail the definitions in EPCA for fluorescent lamp ballasts and note DOE’s interpretation of the definitio ns. Please see the notice of proposed rulemaking ( NOPR ) Federal Register notice for this rulemaking for more discussion on DOE’s consideration of additional fluorescent lamp ballasts and its interpretation of EPCA’s definitions.

3.1.1.1 Ballast Efficacy Factor

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

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

C82.2–1984.

3.1.1.2 Ballast Luminous Efficiency

In the fluorescent lamp ballast active mode test procedure supplementary notice of proposed rulemaking ( SNOPR ), DOE proposed a new metric for describing the performance of a fluorescent lamp ballast called ballast luminous efficiency (BLE). After the effective date of any standards promulgated by this fluorescent lamp ballast standards rulemaking, ballasts would be tested using the new BLE procedure, not the existing procedure which measures ballast efficac y3-2 factor ( BEF ) procedure. Information on the active mode test procedure can be found on DOE’s
website. a

Ballast luminous efficiency BLE means the total fluorescent lamp arc power divided by the fluorescent lamp ballast input power multiplied by the appropr iate frequency adjustment
factor . BLE describes the percentage of ballast input power that is used in the lamp column to produce light. Power delivered to the lamp cathodes (filaments) is not included in the output
measurement and is considered a ballast l oss. This percentage is then multiplied by a frequency adjustment factor depending on the frequency at which a ballast operates a lamp. Low

- frequency operation of a lamp produces fewer lumens per lamp arc watt than high-frequency operation, so DOE uses an adjustment factor to account for the decrease in system efficacy. In general, the BLE metric results in reduced measurement variation, reduced testing burden, and a more straightforward efficiency metric than the existing BEF metric and test procedure.

3.1.1.3 Flu orescent Lamp

10 CFR 430.2 defines a fluorescent lamp as:

Fluorescent lamp means a low pressure mercury electric

- discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, includ ing only the following:

(1) any straight -shaped lamp (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases of nominal overall length of 48 inches and rated wattage of 25 or more; (2) any U -shaped lamp (commonly referred to as 2- foot U -shaped lamps) with medium bipin bases of nominal overall length between 22 and 25 inches and rated wattage of 25 or more; (3) any rapid start lamp (commonly referred to as 8 -foot high output lamps) with recessed double contact (RDC) bases of nominal overall length of 96 inches; (4) any instant start lamp (commonly referred to as 8

- foot slimline lamps) with single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; (5) any straight -shaped lamp (commonly referred to as 4-foot miniature bipin standard output lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches and rated wattage of 26 or more; and (6) any straight -shaped lamp (commonly referred to 4-foot miniature bipin high output lamps) with miniature bipin bases of nomin al overall length between 45 and 48 inches and rated wattage of 49 or more.

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

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

.3-3 3.1.1.4 Fluorescent Lamp Ballast

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

As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is proposing extending coverage to additional fluorescent lamp ballasts. In the NOPR Federal Register notice,

DOE proposes to extend coverage to the following list of fluorescent lamp ballasts:

(1) ballasts that operate 4

- foot medium bipin lamps with a rated wattage c of 25 watts (W) or more and an input voltage at or between 120 volts (V) and 277V; (2) b allasts that operate 2

- foot medium bipin U-shaped l amps with a rated wattage of

25W or more and an input voltage at or between 120V and 277V; (3) ballasts that operate 8-foot high output lamps with an input voltage at or between 120V and 277V; (4) ballasts that operate 8- foot slimline lamps with a rated wattage of 52W or more and an input voltage at or between 120V and 277V; (5) ballasts that operate 4

- foot mi niat ure bipin standard output lamps with a rated wattage of 26W or more and an input voltage at or between 120V and 277V; (6) ballasts that operate 4

- foot mi niature bipin high output lamps with a rated wattage of 49W or more and an input voltage at or between 120V and 277V; (7) ballasts that operate 4- foot medium bipin lamps with a rated wattage of 25W or more, an input voltage at or between 120V and 277V, a power factor (PF) of less than 0.90, and that are designed and labeled for use in residential applications;
and (8) ballasts that operate 8-foot high output lamps with an input voltage at or between 120V and 277V, that operate at ambient temperatures of 20 °F or less and are used in outdoor signs.

DOE is not proposing to expand the scope of coverage to include dimm ing ballasts beyond those which are already covered. The Energy Policy Act of 2005 (EPACT 2005) promulgated standards for d imming ballasts that operate certain energy saver lamps (one or two F34T12, two F96T12/ES, or two F96T12HO/ES). d

3.1.2 Replacement Ballast

Replacement ballast means a ballast that

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

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

d The standards promulgated by EPACT 2005 contained exemptions for ballasts designed for dimming to 50 percent
or l ess of its maximum output. However, these exemptions expired for ballasts manufactured after July 1, 2010 and sold by the manufacturer on or after October 1, 2010. 10 CFR 430.32(m)(6) and (m)(7).3-4 (1) is designed for use to replace an existing fluorescent lamp ballast in a previously installed luminaire; (2) is marked “FOR REPLACEMENT USE ONLY”; (3) is shipped by the manufacturer in packages containing not more than 10 fluorescent lamp ballasts; and (4) has output leads that when fully extended are a total length that is less than the length of the lamp with which the ballast is intended to be operated.

3.2 MARKET ASSESSMENT

The following market assessment identifies the manufa cturer trade association and domestic manufacturers of fluorescent lamp ballasts; discusses manufacturer market share, regulatory programs, and non- regulatory initiatives; defines product classes; provides historical shipment data, shipment projections, an d equipment lifetime estimates; and summarizes market performance data.

3.2.1 Trade Associations

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

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

• engaging in legislative work on energy and ligh ting issues;

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

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

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

• working with market transformation and environmental groups to advance market use of

energy

- efficient lighting technologies;

• advising DOE and the U.S. Environmental Protection Agency (EPA) on ENERGY STAR Buildings and ENERGY STAR voluntary product labeling programs; and3-5 • advocating market

- based approaches to enhance the use and penetration of energy

efficient technologies.”

3.2.2 Manufacturers and Market Share

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

• Acuity Brands Lighting

• Advance Transformer

• American Ballast

• Antron Compact
Electronics

• Axis Technologies

• Ballast Wise

• Bodine

• CEW

• Cooper Lighting

• EBW Electronics

• Espen Technology,

Inc.

• Etlin

- Daniels

• Fulham

• Fr ance • General Electric

Consumer &
Industrial

• Hatch Transformer

• Holophane

• Howard Industries

• Iota Engineering

• Keystone Technologies

• Lamar Lighting

• SOLA Ballasts

• Lighting Components

• Lightolier

• Lutron Electronics Company, Inc.

• MaxLite

• OSRAM Sylvania

• Pacific Lig hting and
Electric • PQL

• Radionic

• Robertson Worldwide

• Sage Lighting Ltd.

• SLI Lighting

• Sunpark Electronics Corp.

• Superior Lamps, Inc.

• TCP

• Ultrasave Lighting
Ltd.

• Universal Lighting Technologies

• Ventex

• Venture Lighting
International

• Wide- Lite

Four manufactur ers hold the majority of the domestic market share of fluorescent lamp ballasts

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

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

• Advance Transformer of Philips Lighting (herea fter “Philips”)

• Universal Lighting Technologies (hereafter “Universal”).

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

3.2.2.1 Small Businesses

Small businesses may be particularly affected by the promulgation of minimum energy conservation standards for fluorescent lamp ballasts. The Small Business Administration (SBA)
lists small business size stand ards that are matched to industries as they are described in the North American Industry Classification System (NAICS). A size standard is the largest that a
for -profit concern can be and still qualify as a small business for Federal Government programs.

T hese size standards are generally the average annual receipts or the average employment of a firm. For fluorescent lamp ballasts, the size standard is matched to NAICS code 335311, Power,3-6 Distribution, & Specialty Transformer Manufacturing , which has a size standard of 750 employees or fewer. 3

DOE studies the potential impacts on these small businesses in detail as part of the manufacturer impact analysis.

3.2.3 Regulatory Programs

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

3.2.3.1 Federal Energy Conservation Standards

EPCA (42 U.S.C. 6291–6309) established an energy conservation program for major household appliances. Additional amendments to EPCA gave DOE the authority to regulate the energy efficiency of several products, including certain fluorescent lamp ballasts. Amendments to EPCA in the National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Pub. L.100357, established energy conservation standards for fluorescent lamp ballasts. e (42 U.S.C. 6295(g)(5)) The standards promulgated by NAECA 1988 can be found in Table 3.2.1

. These amendments also required that DOE (1) conduct two rulemaking cycles to determine whether these standards should be amended; and (2) for each rulemaking cycle, determine whether the standards in effect for fluorescent lamp ballasts should be amended so that they would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B))

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ball ast Efficacy

Factor

One F40T12 Lamp 120 40 1.805

277 40 1.805

Two F40T12 Lamps 120 80 1.060

277 80 1.050

Two F96T12 Lamps 120 150 0.570

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

277 220 0.390

e B allasts are used primarily in the commercial and industr ial sectors. While Part B includes a range of consumer products that are use d primarily in the residential sector, such as refrigerators, dishwashers, and clothes washers

, Part B also includes several products used primarily in the commercial sector, inclu ding fluorescent lamp ballast s. ( Part C of Title III

– Certain Industrial Equipment , codified in the U.S. Code as Part A

- 1, concerns products used primarily in the commercial and industrial sectors, such as electric motors and pumps, commercial refrigerat ion equipment, and packaged terminal air conditioners and heat pumps. )3-7 On September 19, 2000, DOE published a final rule in the Federal Register that completed the first of the two rulemaking cycles to evaluate and amend the energy conservation standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”). 65 FR 56740. This rulemaking estab lished a consensus standard, representing an agreement between the fluorescent lamp ballast industry and energy-efficiency advocacy organizations. The standard levels DOE adopted replaced the ballast efficacy factors promulgated in NAECA 1988 for certain f luorescent lamp ballasts. The standard levels were intended to eliminate certain magnetic ballasts, which operate lamps at a line frequency of 60 Hertz (Hz), and are less efficient than electronic ballasts, which operate lamps at high frequency for ballast s that operate F40T12 and F96T12 lamps. f

Table 3.2.2 shows the standards codified by DOE

. 10 CFR 430.32(m)(3)

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

App lication for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F40T12 Lamp 120 40 2.29

277 40 2.29

Two F40T12 Lamps 120 80 1.17

277 80 1.17

Two F96T12 Lamps 120 150 0.63

277 150 0.63

Two F96 T12 HO Lamps 120 220 0.39

277 220 0.39

Due to the language in the consensus standard that DOE adopted in the 2000 Ballast Rule, it was still be possible for manufacturers to produce and sell magnetic ballasts for certain types of fluorescent lamps. In response, Cong ress promulgated new energy conservation standards for certain fluorescent lamp ballasts under the EPACT 2005, Pub. L. 10958. (EPACT section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)). On October 18, 2005, DOE published a
final rule in the Federal Reg ister codifying those new fluorescent lamp ballast standards into the Code of Federal Regulations at 10 CFR 430.32(m). 70 FR 60407. These standards established minimum ballast efficacy requirements for “energy saver” versions of full

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

f The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40W medium bipin lamps (F40T12) and two nominally 75W 8

- foot T12 single pin slimline lamps (F96T12).3-8 Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts

Application for Op eration of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F34T12 Lamp 120 34 2.61

277 34 2.61

Two F34T12 Lamps 120 68 1.35

277 68 1.35

Two F96T12/ES Lamps 120 120 0.77

277 120 0.77

Two F96 T12 HO/ES Lamps 120 190 0 .42

277 190 0.42

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as amended, include ballasts that are designed to operate one and two nominally 40W and 34W 4- foot T12 medium bipin lamps (F40T12 and F34T12), two nominally 75W and 60W 8-foot T12 single pin slimline lamps (F96T12 and F96T12/ES), and two nominally 110W and 95W 8-foot T12 RDC high output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 277 volts with an input current frequency of 60 Hz and a power factor of 0.90 or greater. 10 CFR 430.32(m). Ballasts that are excluded from regulation include (1) ballasts designed for dimming to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign or ballasts designed for use with two F96T12 HO/ES lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign, g (3) ballasts with a power factor of less than 0.90 and designed and labeled for use only in residential building applications, and (4) replacement ballasts as defined in paragraph (m)(4)(ii). h These exemptions expired for ballasts designed to operate one or two F34T12, two F96T12/ES, or two F96T12HO/ES lamps for ball asts manufactured after July 1, 2010 and sold by the manufacturer on or after October 1, 2010. 10 CFR 430.32(m)(2), (m)(4), and (m)(7).

On December 19, 2007, the President signed the Energy Independence and Security Act of 2007 (EISA 2007) (Pub. L. 110140), which makes numerous amendments to EPCA and directs DOE to undertake several new rulemakings for appliance energy efficiency standards. EISA 2007 did not amend standards for fluorescent lamp ballasts, but instead directed DOE to amend its test procedure for fluorescent lamp ballasts to incorporate a measure of standby mode and off mode energy consumption by March 31, 2009. (42 U.S.C. 6295(gg)(2)(B)(ii)) In addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate standby mode and off

g In 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly different than that contained in sections (m)(2) and (m)(4). In subsection (m)(7), ballasts designed for use with two F96T12HO/ES lamps at ambient temp eratures “of 20°F or less” and designated for use in an outdoor sign are exempt from the standards in paragraph (m)(5). The other sections require the ballast to be for ambient temperatures of negative 20°F
or less.

h The exclusion provided for replacement ballasts requires that they meet certain criteria to be considered a replacement ballast, such as being designed to replace an existing ballast in a previously installed luminaire and being marked “FOR REPLACEMENT USE ONLY.” This exclusion only applies to replacement ballasts manufactured on or before June 30, 2010. After that date, replacement ballasts will no longer be excluded. (10 CFR 430.32(m)(4)(ii)(A)) See appendix A of this TSD for the exact language of the exclusion for replacement ballasts.3-9 mode en ergy use in any amended or new standard adopted after July 1, 2010. Because this energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 2011, the requirement to incorporate standby mode energy use into the energy conservation standards analysis is applicable.

DOE published a final rule test procedure to comply with the standby mode and off mode energy use provisions from EISA 2007 that apply to fluorescent lamp ballasts that are (or could be) covered by this rulemaking. DOE stated in that final rule that standby mode energy use, as defined in EISA 2007, i is nonexistent for typical ballasts that operate on a switch or a motion sensor. DOE also stated that standby mode energy use is only applicable to ballasts with a lighti ng control system. One example of these new ballast designs is a DALI j

- enabled ballast.

DALI

- enabled ballasts exhibit standby power, as they have internal circuitry that is integral to the design of the ballast that remains on and active, even when the bal last is not driving any lamps. DOE noted that fluorescent lamp ballasts never meet the definition of “off mode.”

Pursuant to EPCA section 325(gg)(2)(A), 42 U.S.C. 6295(gg)(2)(A), DOE ha s considered whether to incorporate standby mode into a single amended or new metric. DOE is not proposing to include standby mode standards in this rulemaking. For more information, see
the NOPR Federal Register notice.

3.2.3.2 California Energy Commission

The California Energy Commission (CEC) specifies appliance standards that are “applicable as state law to the sale and offering for sale of appliances in California.” 4 The current standards took effect on August 9, 2009. The new regulations updated standards to match the current federal energy conservation standards with one excep tion. The CEC regulations maintain the exemption for ballasts designed to operate one or two F34T12, two F96T12/ES, or two F96T12HO/ES lamps that: (1) ballasts designed for dimming to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign, and (3) ballasts with a power factor of less than 0.90 and designed and labeled for use only in residential building applications.

3.2.3.3 Canadian Ener gy Efficiency Standards

i In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii), section 310 of EISA 2007 defines “active mode,” “off mode,” and “standby mode” as follows: “The term ‘active mode’ means the condition in which an energy

- using product

— (I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main functions.” “The term ‘off mode’ means the condition in which an energy

- using product

— (I) is connected to a main power source; and (II) is not providing any standby or active mode function .” “The term ‘standby mode’ means the condition in which an energy

- using product (I) is connected to a main power source; and (II) offers 1 or more of the following user

- oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous functions including information or status displays (including clocks) or sensor

- based functions.”
j DALI stands for Digital Add ressable Lighting Interface, which is a system that enables communication between a central lighting controls system and the individual components, including the ballasts.3-10 The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the energy efficiency of fluorescent lamp ballasts in Canada. In 1992, Parliament passed the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy

- using products, effective in February 1995. Fluorescent lamp ballasts were included in the first set of energy efficiency regulations, published in November 1994. 5 An amendment published in April 2003 updated Canada’s regulat ions to the minimum levels put forth in the 2000 Ballast Rule. It also proposed two effective dates: April 1, 2005 for new installations and April 1, 2010 for existing installations (replacement ballasts). 6 Amendment 9, published in the Canadian Gazette

Pa rt II on November 15, 2006, introduced standards for ballasts that operate energy- saving lamps and F32T8 lamps, modified the criteria for exempted ballasts, and repealed the effective date for fluorescent lamp ballasts. 7 Table 3.2.4 8 shows the current Canadian standards for fluorescent lamp ballasts.

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Wat tage |

W Minimum Ballast Efficacy Factor

One F40T12 Lamp * 120 40 2.29

277 40 2.29

347 40 2.22

One F34T12 Lamp 120 34 2.61

277 34 2.61

347 34 2.53

Two F40T12 Lamps 120 80 1.17

277 80 1.17

347 80 1.12

Two F34T12 Lamps 120 68 1.35

277 68 1.3 5

347 68 1.29

Two F96T12(IS) Lamps ** 120 150 0.63

277 150 0.63

347 150 0.62

Two F96T12(ES) Lamps 120 120 0.77

277 120 0.77

347 120 0.76

Two 110W F96T12 HO Lamps 120 220 0.390

277 220 0.390

347 220 0.380

Two F96T12 HO(ES) Lamps 120 190 0.42

277 190 0.42

347 190 0.41

Two F32T8 Lamps 120 64 1.250

277 64 1.230

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

The Canadian standards listed above apply to residential as well as commercial b allasts. Canadian standards consider an input voltage of 347V in addition to 120V and 277V, which is consistent with the Canadian electrical distribution network. Canadian standards also require a3-11 minimum power factor of 0.9 (consistent with U.S. standards ) for all ballasts except residential
ballasts.

3.2.3.4 European Energy Efficiency Standards

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

3.2.4 Non -Regulatory Initiatives

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

3.2.4.1 Federal Energy Management Program

FEMP helps Federal buyers identify and purchase energy efficient products including
certain fluorescent ballasts. Section 161 of EPACT 1992 encourages energy efficient Federal procurement. Section 104 of EPACT 2005 requires that each agency incorporate energy efficiency criteria consistent with ENERGY STAR and FEMP -designated products for “...all procurements involving energy consuming products and systems, including guides specifications, project specifications, and construction, renovation, and service contracts that include provision of energy consuming products and systems, and into the factors for the evaluation of offers received for the procurement.” Executive Order 13123 and Federal Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency, including all models that qualify for the ENERGY STAR product labeling program. 64 FR 30851, 30854 (June 8, 1999). FEMP provides recommendations for how to buy energy efficient fluorescent ballasts, including the products
shown in Table 3.2.5

. 9 FEMP offers buyers support tools such as efficiency guidelines, cost

effectiveness examples, and a cost calculator. FEMP also offers training, on

- site audits, demonstrations, and design assistance.3-12 Table 3.2.5 Federal Energy Management Program Effic iency Recommendation

Lamp Type Number of Lamps Recommended BEF Best Available BEF

Four

- Foot and U

- Tube Lamps

T8, 32 Watts 1 2.54 or higher 3.00

2 1.44 or higher 1.54

3 0.93 or higher 1.06

4 0.73 or higher 0.79

T12, 34 Watts 1 2.64 or higher 3.05

2 1.41 or higher 1.53

3 0.93 or higher 0.95 Eight

- Foot Lamps T8, 59 Watts 2 0.80 or higher 0.81 T12, 60 Watts 2 0.80 or higher 0.80

3.2.4.2 Consortium for Energy Efficiency

CEE has both a Residential Lighting Initiative and a High

- Performance Commercial
Li ghting Initiative. CEE launched its commercial lighting initiative in November 2004 to help identify and select energy efficient commercial lighting products and practices. Initial efforts focused on designating high-performance T8 lighting products. In January 2007, the initiative was expanded to include reduced-wattage T8 products. Table 3.2.6 and Table 3.2.7 summarize CEE’s specifications for high -performance and reduced- wattage T8 ballasts.

Table 3.2.6 CEE High -Performance T8 Ballast Specifications 10

Instant Start Ballast

Lamps Low BF BF≤ 0.85 Normal BF
0.85<BF<1.0 High BF
BF≥1.01

1 ≥ 3.08 ≥ 3.11 ≥ 3.03

2 ≥ 1.60 ≥ 1.58 ≥ 1.55

3 ≥ 1.04 ≥ 1.05 ≥ 1.04

4 ≥ 0.79 ≥ 0.80 ≥ 0.77

6 N/A N/A ≥ 0.52 Programmed Rapid Start Ballast

1 ≥ 2.84 ≥ 2.84 ≥ 2.95

2 ≥ 1.48 ≥ 1.47 ≥ 1.51

3 ≥ 0.97 ≥ 1.00 ≥ 1.00

4 ≥ 0.76 ≥ 0.75 ≥ 0.75

6 N/A N/A ≥ 0.50 Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total H armonic Distortion ≤
20%3-13 Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications 11

Instant Start Ballast, 28W Systems Lamps All BF Ranges

1 ≥ 3.52

2 ≥ 1.76

3 ≥ 1.16

4 ≥ 0.88 Instant Start Ballast, 2 5W Systems

1 ≥ 3.95

2 ≥ 1.98

3 ≥ 1.32

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

CEE created separate standards for normal wattage T8 ballasts based on ballast factor, which compares the ratio of light output of lamps operated by a specific ballast to the light output of the same lamps operated by a standard reference ballast. However, CEE chose not to create standards by ballast factor for reduced -wattage ballasts. Additionally, CEE did not specify performance based on input voltage. CEE’s specifications state that multi

- voltage ballasts must meet or exceed the listed BEF when operating on at least one of the intended operating voltages.

3.2.4.3 NEMA Premium

NEMA maintains a labeling program for “NEMA Premium” ballasts based on CEE’s specifications for high- efficiency 4 -foot T8 ballasts. The program is intended to promote energy efficiency and assist end

- users in identifying the most efficient ballasts on the market. 12 As of July 2010, NEMA’s websi te indicates that fluorescent lamp ballasts manufactured by Acuity Brands Lighting, Cooper Lighting,, Espen Technologies, GE, Hatch Transformers Inc., Holophane an Acuity Brands Company, Keystone Technologies, Philips Lighting Electronics North America, Os ram Sylvania, Robertson Worldwide, Sunpark Electronics Corp., and Universal Lighting Technologies all qualify for the NEMA Premium label.

The NEMA Premium label for fluorescent lamp ballasts is similar to NEMA’s existing program for motors. In November 200 4, NEMA released state -level shipment data that showed an increase in NEMA Premium motor shipments of 30 percent between 2001 and 2002 and 14 percent between 2002 and 2003. 13

3.2.4.4 ENERGY STAR

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency (EPA) designed to protect the environment by promoting energy efficient products and practices. 14 ENERGY STAR specifies criteria for residential lighting fixtures, which contain three parts: a lamp, a ballast, and the fixture that holds the lamp and ballast. Products that qualify for the ENERGY STAR label may not use magnetic ballasts in indoor fixtures. The ENERGY STAR specifications also define criteria for lamp start time, power factor, lamp current crest factor, ballast operating temperature, electromagnetic interference, frequency, transient protection, end of life protection, dimming, and safety. 153-14 3.2.4.5 Energy Efficient Commercial Building Deduction

EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 179D), which established a tax deduction for building owners who incur expenses for energy efficiency upgrades. Effective for property in service from January 1, 2006 through December 31, 2008, the deduction allows partial deductions for improvements in interior lighting. Though the statute does not specify required lamp types or efficacies, it does call for an overall reduction in lighting power density (to qualify the lighting power density must be below the minimum required by the ASHRAE/IES 90.1), and specifically, encourages the use of higher- performance
and reduced- wattage fluorescent lamps. The Emergency Economic Stabilization Act of 2008 (HR -1424), approved and signed on October 3, 2008, extends the benefits of EPACT 2005 through December 31, 2013.

3.2.4.6 Northeast Energy Efficiency Partnerships

NEEP is a regional nonprofit organization that promotes energy efficiency in the Northeast. NEEP runs a High Efficiency Commercial Lighting Initiative to “achieve cost

effective energy and demand by overcoming market barriers to the availability and widespread market adoption of advanced T8 fluorescent lighting systems.” 16 NEEP coordinates with multiple local and state governments, utilities, and other initiatives, such as Efficiency Vermont k
and the Long Island Power Authority, to promote efficient lighting products. 17

, 18

3.2.5 Historical Shipments

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

DOE used this data for three main purposes. First, the shipment data and market trend information contributed to the shipments analysis and base- case forecast for ballasts (chapter 10 of the NOPR TSD). By using historical shipment data and expert opinion on market trends and calibrating forecast assumptions with recent data, DOE believes it has based the shipments
model and base- case forecasts on a sound dataset. Second, DOE used the data to select the representative product classes and representative units for analysis. Generally, DOE selected product classes and units to reflect the highest volume, most common ballast types used in the
United Stat es today (chapter 5 of the NOPR TSD). Third, DOE used the data to develop the installed stock of ballasts for the national impact analysis (chapter 11 of the NOPR TSD). Based on its understanding of trends in the market, DOE estimated how the market would respond to various efficiency levels.

The historical shipment data for ballasts is broken down into many subcategories beginning with magnetic versus electronic type ballasts. Under each technology type, the

k Efficiency Vermont offers technical assistance and financial incentives to encoura ge energy efficiency in Vermont. This organization offers rebates of $10 for the upgrade to or installation of High Performance T8 systems.3-15 shipments are categorized by a variety of charac teristics. Commercial and residential ballasts are delineated by corrected versus uncorrected power factor (section 3.3.3.5 ). Ballasts are also defined by starting method (section 3.3.3.1 ), maximum number of lamps driven (one, two, three, or four), lamp wattage, lamp diameter, and a few additional specific characteristics. Based on interviews with ballast manufacturers, DOE learned that the U.S. Census data represents about 90 percent of T8 and T5 shipments and about 70 percent of T12 electronic shipments. DOE also learned that the U.S. Census does not include shipment data for major residential ballasts or dimming ballasts. The Census data also does not provide shipments for every permutation of
ball ast performance characteristics, but does provide data for establishing trends for the major categories. Ballasts that operate T8 lamps comprised the majority of shipments in 2005. These are followed (in order of 2005 unit sales) by T12 ballasts, compact fluorescent lamp ballasts, T5 ballasts, and other small subsets.

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

2005.

Figure 3.2.1 2005 B allast Market Share

In 2005, corrected power- factor (commercial) magnetic ballasts were not broken out into smaller categories for shipments reporting. DOE used subcategory unit shipment proportions from the 2000 corrected power- factor magnetic ballast cat egory to extrapolate the disaggregation of shipments for 2005. This estimation provided data points for 4- and 8-foot magnetic T12
ballasts as well as 8 -foot HO magnetic T12 ballasts. The 2005 U.S. Census Data also did not report magnetic residential and l inear dimming ballast shipments. To estimate magnetic residential ballast shipments, DOE extended the linear decline in magnetic residential ballasts from 2002-2004 to extrapolate a value for 2005. DOE used a similar approach to estimate linear dimming ballast shipments.3-16 Electronic ballasts have slowly replaced magnetic ballasts, as seen in Figure 3.2.2 . In 1990, magnetic ballasts represented about 96 percent of shipments, while the 2005 magnetic ballast market share dropped to 27 percent. This trend was in part due to energy conservation standards for T12 ballasts. The most recent energy conservation standards for fluorescent lamp ballasts effectively eliminated the sale of 4 -foot T12 medium bipin (MBP), 2-foot T12 U-shaped, and 8- foot T12 slimline magnetic ballasts. The standard began to go into effect for certain 4-foot T12 MBP, 8 -foot T12 slimline ballasts, and 8-foot HO ballasts in 2005. The final phase of the standard became effective in 2010, when replacement 4-foot T12 MBP, 8-foot T12 single pin (SP) slimline, and 8 -foot HO magnetic ballasts will no longer be sold. (10 CFR 430.32(m)(4)(ii) and 430.32(m)(5)- (6))

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

1989 1991 1993 1995 1997 1999 2001 2003 2005Market Share

Year Magnetic

Electronic

Figure 3.2.2 Magnetic and Electronic Ballast Market Share

The vast majority of 4 -foot T12 MBP and 2-foot T12 U- shaped ballasts are magnetic (about 77 percent of the T12 market in 2005), and the vast majority of 4-foot T8 MBP and 2-foot

T8 U -shaped ballasts are electronic (about 97 percent of T8 ballast shipments in 2005). Therefore, the decline in magnetic ballasts mirrors a decline in T12 ballast shipments. Similarly,
the increase in electronic ballasts mirrors an increase in 4 -foot T8 MBP and 2-foot T8 U- shaped ballast shipments. Figure 3.2.3 and Table 3.2.8 show these shipment trends. The trend in ballast shipments is followed by similar trends in 4 -foot T8 MBP and 2-foot T8 U-shaped lamp shipments and 4-foot T12 MBP and 2-foot T12 U-shaped lamp shipmen ts. DOE received general service fluorescent lamp historical shipments from NEMA from 2001 to 2005. 20 Based on conversations with manufacturers, DOE believes these trends continue beyond 2005.3-17 

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

1994 1996 1998 2000 2002 2004 2006Shipments



### Year T8s

T12s

Figure 3.2.3 Shipments of Ballasts that Operate Four

- Foot MBP Lamps

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

Uni t Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Four

- Foot

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

Four

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

F our

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

Four

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

(D) indicates data not made public

.

Table 3.2.9 shows similar trends for 8 -foot T12 and T8 SP slimline ballasts and lamps. In general, 8

- foot SP slimline T12 ballasts and lamps are experiencing a decrease in shipments,
whereas 8

- foot SP slimline T8 ballasts and lamps are experiencing an increase in shipments. The increase in shipments for 8- foot SP slimline T8 lamps is smaller than for 4 -foot T8 shipments. According to manufacturers and lighting experts, this is because a portion of the 8-foot T12 SP slimline ballast market is being transferred to the 4 -foot T8 ballas t market.3-18 Figure 3.2.4 Shipments of Eight -Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts

Table 3.2.9 Shipments of Eight

- Foot Slimline T8 and Eight -Foot SP Slimline T12 Ballasts and Lamps
Unit Sales by Year

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

- Foot
Slimline T12
Ballast 7,394 6,612 6,268 6,601 6,638 5,813 (D) (D) (D) (D) 2,599

Eight

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

Eight

- Foot
Slimline T12 Lamp (D) (D) (D) (D) (D) (D) 43,265 41,443 37,170 36,263 33,636

Eight

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

(D) indicates data not made public.

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

3.2.10 are rated for cold -temperature outdoor signage applications, which were excluded from previous energy conservation standards. The Census data for high output ballasts are no t exclusive to ballasts that operate 8 -foot RDC HO lamps, but information from manufacturers indicates these ballasts represent most of the high output market. Discussions with lighting experts and lamp manufacturers indicate that they expect any migration of the 8- foot RDC HO market to go toward T5 HO fluorescent systems and metal halide systems. High output ballast shipments likely follow a similar trend to the 8 -foot HO lamp shipments. Both ballast and lamp3-19 shipments show the high output market share is much smaller than for 8

- foot slimline T8 and T12 ballasts and lamps.

Table 3.2.10 T12 High- Output Ballast Market Share

Unit Sales by Year*

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

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

Eight

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

Eight

- Foot
T8 RDC HO Lamp 691 647 467 674 420

(D) indicates data not made public.

* Data from 1995 and 1996 include electronic and magnetic ballast shipments. Data from 1997

- 2005 include only magnetic shipments. Lamps shipments are available for 2001

- 2005 only.

Based on public data, Figure 3.2.5 shows magnetic residential ballast shipments have
decreased from 1995 to 2004. l Shipments data for this category were unavailable for 2005. Because the major manufacturers in the residential sector are not members of NEMA, shipments in the residential sector are likely larger than those rep orted in the U.S. Census data. Residential ballasts have been excluded from energy conservation standards until the expiration of the exemption imposed by EPACT 2005.

l U.S. Census data does not report shipments of electronic residential (low

- power

- factor) ballasts.3-20 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006Shipments

Year

Figure 3.2.5 Shipments of Residential Ballasts

T5 ballasts have been growing steadily since reported shipments began in 2002 ( Figure

3.2.6 ). T5 normal output ballast shipments were not reported in the U.S. Census data. Conversations with ballast manufacturers indicated some growth in normal output T5 ballasts due to replacements of 4-foot electronic T8 ballasts. In addition, manufacturers indicated that significant growth in T5 ballast shipments has been driven by 4-lamp T5 high output ballast systems replacing high -b ay metal halide systems in the industrial sector. Based on information from ballast manufacturers, DOE believes these trends continued beyond 2005.3-21 Figure 3.2.6 Shipments of T5 High

- Output Ballasts

3.3 TECHNOL OGY ASSESSMENT

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

3.3.1 Basic Structure of Fluorescent Lamps

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

Lamp types are designated by a series of letters and numbers. The letter “F” is used to designate a fluorescent lamp. It is followed by a two- digit number that identifies either the nominal lamp wattage for nomin ally 4 -foot lamps or the lamp length in inches for 8-foot lamps. These digits are followed by the letter “T,” for tubular, which is followed by the lamp diameter in eighths of an inch. Additional designations are sometimes used: for example, “HO” if the
la mp is high output or “/ES” if the lamp is an energy saver or reduced- wattage lamp. Table 3.3.1 shows the nomenclature that defines the diameter, lamp length, and lamp wattage for some common fluorescent lamps.3-22 Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature

Lamp Nomenclature Nominal Lamp Length feet Nominal Lamp Wattage

W Lamp Diameter

inches

F32T8 4 32 1

F40T12 4 40 1 1⁄2

F54T5 HO 4 54 5/8

F96T12 8 75 1 1⁄2

F96T12 HO 8 110 1 1⁄2

F96T12 HO/ES 8 95 1 1⁄2

The fluorescent lamp consists of a glass bulb or tube, filled with low pressure mercury vapor and inert gas, with electrodes sealed onto both ends of the tube. The fluorescent lamp has five major components: bulb, electrodes, base, gas fill, and phosphors. Two electrodes are hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled tungsten wires coated with a mixture of alkaline oxides. A base provides an electrical connection
to these e lectrodes and also supports the lamp. Depending on the start method and operational properties of the lamp ( e.g. , dimming, wattage, etc.), lamp designs may use different bases such

as single pin , medium bipin, and recessed double contact. Once voltage is applied to the electrodes, the tungsten coil and coatings emit large quantities of electrons when the coating is at the proper temperature (1,000–1,300 K). These electrons then collide with gaseous mercury atoms, exciting electrons within those atoms. As th e electrons decay to their stable or ground state, they emit UV radiation primarily at 254 nanometers (nm). In addition to the mercury vapor, an inert gas or a combination of gases is added to the lamp primarily to moderate the collisions of mercury ions and minimize evaporation of the electrode coating. The UV radiation is then absorbed by the phosphors and reemitted as light.

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp

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

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

i.e. , ignition and current limiting/control, are required in all fluorescent lamps, regardless of shape, size, or type. Both functions constitute the major function of a ballast. Figure 3.3.1 shows a graphical representation of this relationship from ignition (Townsend, glow, and abnormal glow) through arc discha rge.3-23Current (I)



### Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

RegionCurrent (I)



### Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

Region

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

A voltage pulse several times th at of the lamp operating voltage may be required to initiate the arc discharge. During this process, the lamp’s operating point must pass through the Townsend, glow, and abnormal-glow as quickly as possible. Rapid start (RS) and programmed start (PS) syste ms use tertiary cathode heating to catalyze this process, while instant start (IS) operation simply uses a higher starting voltage.

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

.

3.3.3 Fluorescent Lamp Ballast Overview

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

A ballast has four critical functions:

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

2. deliver high voltage to start and ignite the lamp,3-24 3. regulate (limit) electric current flowing through the lamp after ignition to avoid

current run

- away and self -destruction, and

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

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

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

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

3.3.3.1 Starting Method

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

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

ra

pid start ballasts can be similar. 23 In general, RS ballasts provide between 15,000 and 17,000 switching cycles. 22

, 23

A more recent and advanced version of the RS ballast is the PS ballast. Like the RS ballast, the PS ballast heats the lamp filaments to a certain temperature for a prescribed amount of time before applying a high- voltage pulse to ignite the lamp. Some programmed start ballasts remove all power to the electrodes after ignition (also known as cathod e cut -out), resulting in some energy savings over other PS systems. However, due to added internal circuitry, PS ballasts cannot be as efficient as IS ballasts. PS ballasts can provide between 50,000 to 100,000 switching cycles depending on ballast design. 22

, 24 A lamp operating on a PS ballast can last more than three times longer than it would on a RS or IS ballast. 22

Instant start ballasts rely on higher voltage t o initiate the discharge rather than applying a steady filament voltage. These ballasts apply a very high voltage pulse to the lamp to rapidly3-25 ionize the gas in the lamp and initiate the arc instantly, without the need for heating the
electrodes. Because I S electronic ballasts do not provide lamp electrode heating, these ballasts are inherently more efficient, saving approximately 2 watts of energy per lamp compared to RS ballasts. However, due to the high applied voltage necessary to start the lamp, the el ectrodes of a lamp operated by an IS ballast deteriorate more quickly than the heated electrodes of a lamp operated by a RS or PS ballast, resulting in decreased lamp life. IS ballasts can provide between 10,000 and 15,000 switching cycles depending on the ballast design. 22

, 23

3.3.3.2 Ballast Factor

The ballast factor is defined as the output of a ballast delivered to a reference lamp in terms of power or light divided by t he output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). To calculate the light output of a lamp- and

- ballast system, one would multiply the light output of the lamp by both the number of lamps operated by the ballast
and i ts ballast factor. Because ballast factor affects the light output of the system, manufacturers design ballasts with a range of ballast factors to allow consumers to vary the light output (and thus power consumed) of a fluorescent system. In general, balla sts that operate 4 -foot MBP lamps and designed with a ballast factor of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor of 0.78 or less; high ballast factor ballasts typically
have a ballast factor of 1.10 or higher.

In the ongoing active mode test procedure rulemaking, DOE has proposed to change the definition of ballast factor be total measured lamp arc power divided by the total reference lamp arc power. In this NOPR, DOE has used this method to calculate b allast factor.

3.3.3.3 Ballast Efficacy Factor

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

Power Input Output Light Relative

= BEF Equation 3.1

Where:

= BEF ballast efficacy factor;

= Output Light Re lative the light output delivered through the use of a ballast divided by the light output delivered through the use of a reference ball ast, expressed as a percent; and

= nputPowerI the power consumption in watts of a ballast and fluorescent lamp or lamps.

3.3.3.4 Ballast Luminous Efficiency

Ballast luminous efficiency means the total fluorescent lamp arc power divided by the
fluorescent lamp ballast input power multiplied by the appropriate frequency adjustment factor. BLE describes the percentage of ballast input power that is used in the lamp column to produce light. Power delivered to the lamp cathodes (filaments) is not included in the output measurement and is considered a ballast loss. This percentage is then multiplied by an3-26 adjustment factor depending on the frequency at which a ballast operates a lamp. Low

- frequency operation of a lamp produces fewer lumens per lamp arc watt than high -frequency operation, so

DOE uses a frequency adjustment factor to account for the decrease in system efficacy. In general, the BLE metric results in reduced measurement variation, reduced testing burden, and a more straightforward efficiency metric t han the existing BEF metric and test procedure. In this NOPR, DOE evaluated ballast performance in terms of the ballast luminous efficiency metric.

3.3.3.5 Power Factor

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

Current Input Ballast Voltage Input Ballast Input Power Factor Power

∗ = Equation 3.2

Where:



### = r PowerFacto power factor,

= PowerInput input power in watts to ballast,

= utVoltage BallastInp input voltage in volts to ballast, and

= utCurrent BallastInp input current in amps to ballast.

Power factors range between 0 and 1. A power factor of 1 indicates that the voltage and current wave forms are in phase and not disto rted. Fluorescent ballasts can be characterized by two classes of power factor: high power factor (HPF) of 0.9 or greater, and normal power factor (NPF) of 0.6 or greater. HPF ballasts use about one-half the current of NPF ballasts. The primary
cause of lo w power factor in magnetic ballasts is the inductance of the ballast transformers. It can be corrected with the addition of the proper capacitor. In electronic ballasts, the primary cause of low power factor is due to total harmonic distortion (defined bel ow) caused by a non

linear load. According to ANSI C82.77- 2002, commercial ballasts must have a HPF while residential fluorescent ballasts (with an input power below 120W) must have a power factor of 0.5 or greater.

3.3.3.6 Total Harmonic Distortion

Another important performance parameter is harmonic distortion. Line current harmonics are the components of the line current that oscillate at integer multiples of the fundamental frequency of the power supply, e.g. , 60 Hz, 120 Hz, 180 Hz, etc. Harmonics of a fundament al frequency are an undesirable byproduct of any non- linear system operation, generating noise and wasted power. Total harmonic distortion refers to the ratio of the root mean square (rms) values of the harmonic content to that of the fundamental current, expressed as a percentage. It may also
be called harmonic factor:3-27 2

1 2

4 2

3 2

2 ... )(
I III fund THD +++

= Equation 3.3

Where:

= THD total harmonic distortion; and

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

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

3.3.3.7 Electromagnetic Interference

Many devices found in office environments, such as computers, photocopiers, facsimile machines, and fluorescent lighting systems, can generate electromagnetic waves. The effects of these waves vary based on their strength and the susceptibility of nearby equipment. Alternating

current in electronic devices produces a magnetic field, which in turn induces an AC voltage in a nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or
radiated. Conducted EMI occurs when electronic devices induce currents in the local power network that in turn negatively affect other devices on that network. Radiated EMI is associated with the electric and magnetic field inherent in electronic devices. EMI can be minimized with proper grounding and wiring techniques. 25 EMI lim its for both consumer and non-consumer lighting products sold in the United States are listed in 47 CFR 18 subpart C. These regulations require that consumer/residential (Class B) ballasts have lower maximum EMI requirements than

non- consumer (Class A) pro ducts. The International Committee on Radio Interference has more stringent regulations concerning EMI. However, fluorescent lamp ballasts sold in the United States currently do not have to meet these regulations. More detail on electromagnetic
interferenc e can be found in appendix 5E.

3.3.3.8 Safety

A ballast will continue to drive or reignite a lamp when the lamp reaches the end of its life. Usually, the failure of the lamp will have no adverse consequences. Occasionally, the ballast will continue to try to drive a failed lamp repeatedly until the temperature in the region of the electrode increases rapidly and causes overheating of the lamp electrodes. This can be avoided through additional circuitry that provides end- of

- life (EOL) protection. Some ballasts in th e United States are required to have EOL protection ( e.g. , ballasts that operate T5 lamps). However, the most popular T8 ballasts are not. International standards (IEC 600797-1 Ed. 4) require all fluorescent lamp ballasts regardless of lamp diameter to hav e EOL protection.

Another safety issue arises when a lamp is not inserted properly into the lamp holder, which can cause arcing. This problem can either be addressed through better design of the lamp3-28 holders, or by adding circuitry to the ballast that detects arcing and reduces the output voltage so
that the arc cannot be sustained.

3.3.4 Fluorescent Lamp Ballast Technology Options

The following section discusses the two major technologies used in fluorescent lamp ballast design

— magnetic ballasts and electronic ballasts —and additional technology options (improved components and improved circuit design) that can incrementally improve the efficiencies of a magnetic or electronic ballast.

3.3.4.1 Magnetic Ballasts

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

The main core

- and

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

F igure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast

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

Because of their low frequency operation, magnetic ballasts are less energy efficient than electronic ballasts ( Figure 3.3.3 ). Magnetic ballasts fail to optimize lumen output for a given wattage. These ballasts also release the energy not used to operate the lamp as heat in the transformer windings. This heat is dissipated to the environment by the ballast potting material and its metal or plastic enclosures.3-29 3.3.4.2 Electronic Ballasts

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

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

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

Not only is the lamp more efficient at higher frequencies but the ballasting action (current

- limiting) at high frequency requires smaller components. This reduces ballast losses and makes the ballast more efficient. In addition, the ballast noise becomes inaudible at higher frequencies and there is no 60- cycle flicker like that associated with fluorescent lamps th at operate with magnetic ballasts.

Whereas typical magnetic ballasts generally have three components ( i.e. , core, coil, and capacitor), electronic ballasts have additional blocks of electronic components. Figure 3.3.4
shows the i nterior of an electronic ballast.3-30 Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

Figure 3.3.5 presents an example of a functional block diagram of a fixed -light output electronic ballast. Auxiliary functions performed by a typical electronic ballast include electromagnetic interference filtering to block ballast -generated noise, input rectification, PF correction for sinusoidal input curre nt, a direct

- current (DC) filter, a direct

- current to alternating

current (DC

- AC) inverter, a feedback/controller for high -frequency operation, and a final output stage to power the lamp.

Figure 3.3.5 Fixed

- Light Output Electronic Fluorescent Ballast Block Diagram
Source: T. Ribarich, A Systems Approach to Ballast IC Design

, El Segundo, CA

, 1999

, and Philips Semiconductor

, Power Semiconductor Applications , 1994.

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

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

Circuit Stage Function Efficiency Impact Waveform (not to scale)3-31 EMI Filter Impedes EMI by providing a high impedance path to EMI and a low impedance path to the
desire d input. The circuit also protects against high voltage pikes. Very Low

t V

Input Rectifier Begins to convert incoming AC to DC using
diodes. A full

- bridge rectifier, one type of input rectifier, is composed of four diodes, which “rectify” the full AC wa veform as shown in the waveform on the right. The current is not in phase with the voltage. Low

t V, I

Power Factor

Correction Corrects the current so it is in phase with the voltage. Power factor correction can be achieved through a buck or boost

- converter circuit topology. Low

- Medium

t V, I

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

t V

DC

- AC Inverter Converts incoming DC to high

- frequency AC.
The resonant half

- bridge self

- oscillating circuit is one type of circuit topology that can be used to accomplish this task. Medium

High

t V

When the lamp is not started, the circuit operates in resonance to increase output voltage to start the lamp. O nce the lamp is started, the circuit operates at a frequency off of resonance to continue operating the lamp. High Starting:3-32 Output Stage A resonant filter topology is one type of circuit topology used in the output stage.

t V

Operation:

t V

Feedback/Controller An integr ated circuit (IC) that controls the frequency output of the DC

- AC inverter. It can also protect against under voltage lockout and lamp faults. Low N/A

3.3.4.3 Improved Components

A common way to increase the efficiency of both magnetic and electronic ballasts is to improve the quality of their components. Magnetics (transformers and inductors), diodes, capacitors, and transistors are the main components that affect efficiency.

Magnetics (transformers and inductors) : In electronic ballasts, magnetics influence the efficiency of the EMI, power factor correction (PFC), and output stage of the ballast. In magnetic ballasts, magnetics influence the efficiency of the output stage and current

- limiting portion of the
ballast.

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

a t echnology option to improve a magnetic component’s winding losses.

One way to reduce magnetic component power loss at light loads is to select magnetics with higher quality core materials. There are two types of core materials that ballasts can use:
silico n steel (thinly laminated steel alloyed with silicon) and amorphous steel. Core performance of silicon steel can be enhanced by magnetically orienting the grain structure in the metal. Even larger gains in efficiency can be achieved using amorphous materials. To further increase the efficiency of the ballast using amorphous materials, one can create the core of the inductor from laminated sheets of amorphous steel, insulated from each other. However, this method can increase the size and weight of the balla st.3-33 Another way to reduce the magnetic component’s power loss is to select materials with lower winding losses. High- frequency operation (typical of electronic ballasts) can increase winding losses as two additional loss mechanisms, skin effect and proximi ty effect, become more prominent. One way to reduce both the skin effect and proximity effect is to use litz wire, which consists of a number of individually insulated magnet wires twisted or braided into a uniform pattern. Skin effect refers to the tendency of AC current to flow through a conductor’s
surface or “skin” rather than a conductor’s core. Because litz wire increases the amount of surface area current can flow through, overall winding losses can be reduced as the effective wire
resistance is decr eased. When conductors are close together, the magnetic field of one conductor will reduce the area that the current flows through in another conductor, increasing its winding losses. This effect, called the p roximity effect, can be also be improved by usi ng litz wire.

Diodes : In electronic ballasts, the input rectifier inverts the negative half of the AC sine wave and makes it positive. Several technology options can be used to improve the efficiency of this portion of the circuit. The power consumed by a diode is the product of the current flowing through the diode multiplied by the voltage drop across it. Conventional diodes have a voltage drop of about 0.6 V. Use of a Schottky diode m would reduce the voltage drop across the diodes by about 0.3 V to 0.4 V. However, as discussed in Appendix 5D, DOE was unable to identify a Schottky diode that could be used as a direct replacement for the conventional diodes typically
used in ballasts.

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

Transistors : In electronic ballasts, transistors are used in both the power factor correction and the DC-AC inverter port ion of the circuit. The transistor dissipates energy due to its drain

- to

source resistance (R DS_ON ) when the current flows through the transistor to the transformer. Using transistors with low R DS_ON can reduce this loss. For example, the efficiency of electronic ballast’s bipolar transistors can be improved by using metal-oxide- semiconductor field

- effect transistors (MOSFETs), a transistor with a lower drain

- to

- source resistance.

3.3.4.4 Improved Circuit Design

Another method of increasing the efficiency of both m agnetic and electronic ballasts is to improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout technology, integrated circuits, improved starting method, and synchronous rectification.

Cathode Cutout : Both rapid start and programmed start ballasts provide heat to the filament while starting a lamp. As discussed in section 3.3.3.1 , providing filament power while

m A Schottky dio de is a metal semiconductor diode with a smaller voltage drop than a conventional diode. Schottky diodes therefore consume less power.3-34 starting the lamp can increase its lifetime. Removing the power provided to the filament after the lamp has been started using an electronic circuit will increase the efficiency of both programmed start and rapid start ballasts. Removing this power can reduce the power the ballast consumes by as much as 2 watts per lamp.

Integrate d Circuits : In certain cases, a ballast’s efficiency can be improved by

s ubstituting integrated circuits for discrete components . For example, some ballasts use bipolar
transistors in a resonant half- bridge self

- oscillating circuit to convert incoming DC t o AC. The efficiency of this circuit can be improved by substituting the components in that circuit with an integrated circuit. 26

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

power.

DOE only considered starting method as a technology option in case of the migration from RS to IS ballasts. DOE’s research indicates that IS ballasts are common replacements for RS ballasts, and though the lamp lifetime is sometimes lower in IS ballasts than RS ballasts, it does not seem to be significant enough to affect consumer utility. As discussed in section 3.3.3.1

, lamp lifetime in IS ballasts is approximately 25 percent less compared to RS ballasts when operated on a 3-hour start. However, lamps operated on RS ballasts have the same lifetime as lamps operated on IS ballasts when operated on short start cycles. This is typical when ballasts are used with occupancy sensors to save energy. Conversely, the lifetime of a lamp that operates on a PS ballast with occupancy sensors can be as much as three times longer than the lifetime of a lamp that operates on an IS or RS ballasts. Because IS ballasts have more limited utility as replacements for PS ballasts, IS ballasts are not considered a technology option for improving the efficiency of PS ballasts.

3.4 PRODUCT CLASSES

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

In amending EPCA, NAECA 1988 established eight product classes for fluorescent lamp ballasts ( Table 3.4.1 ).3-35 Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp

Ballasts
Application for Operation of Ballast Inp ut Voltage Total Nominal Lamp Watts

One F40T12 Lamp 120 40

277 40

Two F40T12 Lamps 120 80

277 80

Two F96T12 Lamps 120 150

277 150

Two F96T12 HO Lamps 120 220

277 220

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

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

Ballasts
Application for Operation of Ballas t Input Voltage Total Nominal Lamp Watts

One F34T12 Lamp 120 34

277 34

Two F34T12 Lamps 120 68

277 68

Two F96T12/ES Lamps 120 120

277 120

Two F96T12 HO/ES Lamps 120 190

277 190

In addition to the lamps and lamp ballasts identified in Table 3.4.1 and Table 3.4.2 , the fluorescent lamp ballast market today includes ballasts that operate smaller diameter lamps such as T8 and T5 lamps (section 3.3.1 ). These fluorescent lamp

- and

- ballast systems are gaining in market share, whereas T12 systems are becoming less popular and losing market share. This market shift is expected to accelerate in 2010, when the exclusion from the standard levels established by the 2000 Ballast Ru le and EPACT 2005 for replacement ballasts will expire. The standard levels established by the 2000 Ballast Rule and EPACT 2005 for fluorescent lamp ballasts are difficult to meet using magnetic ballast technology. Because magnetic ballasts comprise the la rge majority of T12 ballast sales, DOE believes that when the standards take effect, there will be an increase in shipments of electronic ballasts that operate T8 and T5 lamps.

Because of these market changes and because DOE is anticipating expanding its scope of covered product for fluorescent lamp ballasts, DOE is proposing to amend the product classes for these ballasts. The following sections summarize all of the factors that DOE considered as potential determinants of product class. In general, when co nsidering the characteristics below, DOE considered three main factors as affecting consumer utility: (1) the lumen package of the lamp

- and

- ballast system; (2) the physical constraints of the lamp

- and

- ballast system; and (3) the use of the ballast in an ap plication for which other ballasts are not suitable. When referring to efficiency, DOE is referring to BLE.

3.4.1 Power versus Efficiency Relationship3-36 DOE believes that there are both fixed and variable losses in any fluorescent ballast. Fixed losses consist of switching losses, due to components such as transistors, and fixed voltage drops across certain components, such as diodes. These components are necessary for proper ballast operation but will always contribute some amount to overall ballast losses. In ballasts that operate low powers, fixed losses comprise a significant amount of the power lost. Variable losses consist primarily of resistive losses (also referred to as I 2 R losses) which increase as current increases. Ballasts that operate higher powers also operate at a higher current and therefore have greater resistive losses. At a certain power level, resistive losses will be greater than fixed losses, as these losses continue to increase as power increases.

Using test data, DOE empirically found a relat ionship between the BLE metric and the natural log of lamp arc power. In general, as lamp arc power increases, BLE increases as well. DOE believes this is because the fixed losses of a ballast become proportionally less significant at higher lamp arc powers. Because this power- efficiency relationship exists, DOE is able to set efficiency levels as a function of lamp arc power. Thus, several factors that affect the total wattage operated by a ballast (such as lamp length, ballast factor, and number of lamps operated) do not necessarily require separate product classes.

3.4.2 Starting Method

DOE found RS and PS ballasts to be inherently less efficient than IS ballasts because RS
and PS ballasts provide filament power to the lamp. Although some PS ballasts cut out th e filament power during normal operation (using the cathode cutout technology option discussed
above ), the extra circuit ry to remove this power still consumes some amount of power. In the BLE metric, cathode heating is counted as a loss because it does not directly contribute to the creation of light. Therefore, RS and PS ballasts will have lower BLEs than comparable IS
ballasts.

Whereas RS and IS ballasts are commonly used as substitutes for each other, PS ballasts are not. Programmed start ballasts are c ommonly used in conjunction with occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. The lifetime of a lamp operated on a PS ballast with occupancy sensors can be as much as three times longer than the
lifetime of a lamp operated on an IS or RS ballast in the same application. Thus, DOE’s research indicates that use of instant start ballasts with occupancy sensors can result in a significant reduction in lamp lifetime. Because the application in which they are used g reatly affects lamp lifetime, programmed start ballasts offer the user a distinct utility. In consideration of their affect on both BLE and utility, DOE established separate product classes for programmed start ballasts.

3.4.3 Lumen Package

Lumen package refers to the quantity of light that a lamp

- and

- ballast system provides to a consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts that run the lamps at high currents. For example, 8-foot HO lamps and 4- foot MiniBP HO lamps tend to operate at higher currents than 8- foot slimline lamps and 4

- foot MiniBP SO lamps, respectively. This difference in operating design increases the quantity of light per unit of lamp length. Consumers tend to use systems with different lumen packages for different applications. For example, high- lumen

- output systems may be installed in certain high -ceiling or outdoor3-37 applications where large quantities of light are needed. Alternatively, standard

- lumen -output systems might be installed in lower

- ceili ng applications such as offices or hospitals, where the distance between the light source and the illuminated surface is not as large. Notable differences in the application of ballasts designed to operate SO lamps versus HO lamps indicate a
difference in utility.

However, BLE is not dependent on system light output, but rather on the total power operated by the ballast. As HO lamps have higher rated powers than comparable (same length, diameter) SO lamps, DOE believed ballasts that operate HO lamps would b e more efficient than comparable ballasts that operate SO lamps. An analysis of test data generally confirme d this prediction. Therefore, because the power-efficiency equation accounts for HO versus SO lamp operation, DOE is not establishing separate produ ct classes for ballasts that operate HO lamps

, with one exception as explained in the following paragraph.

DOE found that b allasts that operate 8 -foot HO lamps did not follow the expected relationship. Compared to 8- foot slimline ballasts, DOE found that 8

- foot HO ballasts exhibited lower BLEs although they operated higher lamp powers. This may be because this ballast type
has a different topology, or circuit design, than other ballast types ( e.g. 4-foot MBP and 8-foot slimline ballasts). Because DOE has es tablished that lumen package offers a unique utility, and in this case a change in lumen package is accompanied by a change in BLE from what the efficiency equation would predict, DOE establish ed a separate product class for ballast s that operate 8 -foot HO lamps.

3.4.4 Sign Ballasts

Ballasts that are designed for use in cold temperature outdoor signs have slightly different characteristics than those ballasts that operate in the commercial sector. First, sign ballasts are designed to operate in cold temperature environments – as low as negative 20 degrees Fahrenheit. Second, sign ballasts are classified by the total length (in feet) of lamps they can operate as well as the total number of lamps. To operate in cold temperature environments and to be able to handle numerous lamp combinations, sign ballasts contain more robust components compared to regular 8- foot HO ballasts in the commercial sector. Thus, sign ballasts are inherently less efficient. For this reason, sign ballasts did not achieve the expected BLE pr edicted by the power-efficiency relationship.

Although regular 8-foot HO ballasts are also rated for operation in cold temperature environments, they cannot always serve as substitutes for sign ballasts due to their lack of
moisture seals and more limited load specifications . For these reason s, and the associated differences in BLE compared to ballasts of similar lamp arc power

, DOE established separate product classes for sign ballasts.

3.4.5 Product Classes

For all the reasons discussed above, DOE is consideri ng the ballast product classes listed
in Table 3.4.3

.3-38 Table 3.4.3 Product Classes for Fluorescent Lamp Ballasts Description Product Class Number** IS and RS ballasts that operate 4-foot MBP lamps*

8

- foot slimline lamps 1

PS ballasts that operate 4-foot MBP lamps*

4- foot MiniBP SO lamps

4

- foot MiniBP HO lamps 2

IS and RS ballasts that operate

8

- foot HO lamps 3

PS ballasts that operate

8

- foot HO l amps 4

Ballasts that operate 8-foot HO lamps in cold temperature outdoor signs 5

*Includes both commercial and residential ballasts **Efficiency levels for all product classes are based on an equation3-39 REFERENCES

1 Ron Runkles. NEMA Premium Efficiency Ele ctronic Ballast Program. NEMA Lighting Systems

Division . 2007. (Last accessed April 4, 2011). < http://www.cee1.org/cee/mtg/09

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

2 National Electrical Manufacturers Association. Lighting Systems Division . 2002. (Last accessed April 4, 2011). < http://www.nema.org/prod/lighting/upload/LightingSystemsDivision.pdf >.

3 U.S. Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes. 2008. (Last accessed April 4, 2011.)

< http://www.sba.gov/sites/default/files/Size_Standa rds_Table.pdf >.

4 California Energy Commission. 2007 Appliance Efficiency Regulations . 2007. (Last accessed April 4, 2011). < http://www.energy.ca.gov/2007pub lications/CEC -400-2007-016/CEC-400-

2007-016- REV1.PDF >.

5 Natural Resources Canada, Office of Energy Efficiency. Proposed Regulations for Fluorescent Lamp Ballasts . 2001. (Last accessed April 4, 2011). <http://oee.nrcan.gc.ca/regulations/Fluorescent.cfm?at tr=0>.

6 Natural Resources Canada, Office of Energy Efficiency. Recent Amendments . 2009. (Last accessed April 4, 2011). <http://oee.nrcan.gc.ca/regulations/amendment6_part2.cfm?attr=0>.

7 Natural Resources Canada, Office of Energy Efficiency. Regulations A mending the Canada's Energy Efficiency Regulations. 2009. (Last accessed April 4, 2011). <http://oee.nrcan.gc.ca/regulations/amendment9_part1.cfm?attr=0>.

8 Natural Resources Canada, Office of Energy Efficiency. Canadian Energy Efficiency Regulations for Fluorescent Lamp Ballasts. 2009. (Last accessed April 4, 2011). <http://oee.nrcan.gc.ca/regulations/product/fluorescent_lamp_ballasts.cfm?attr=0>.

9 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Federal Energy Management Program. How to Buy Energy- Efficient Fluorescent Ballasts . 2000. (Last accessed April 4, 2011). <http://www1.eere.energy.gov/femp/pdfs/ballast.pdf >

10 Consortium for Energy Efficiency. CEE High Performance T8 Specification . 2008. (Last accessed April 4, 2011). < http://www.cee1.org/com/com- lt/com

- lt -specs.pdf >.

11 Consortium for Energy Efficiency. CEE Reduced -Wattage T8 Specification . 2007. (Last accessed April 4, 2011). < http://www.cee1.org/com/com- lt/lw -spec.pdf >.

12 National Electrical Manufacturers Association. NEMA Premium Electronic Ballast Program

. (Last accessed April 4, 2011).3-40 < http://www.nema.org/gov/energy/efficiency/upload/nema_premium_electronic_ballast_progra m.pdf >.

13 Industrial Equipment News. NEMA Premium Motor Results Show Increase In Sales. November 4, 2004. (Last accessed April 4, 2011 .) < http://www.ien.com/article/nema -premiummotor/8468 >.

14 U.S. Environmental Protection Agency and U.S. Department of Energy. About ENERGY STAR. (Last accessed April 4, 2011 ). <http://www.energystar.gov/index.cfm?c=about.ab_index>.

15 U.S. Environmental Protection Agency and U.S. Department of Energy. Residential Light Fixtures Key Product Criteria. (Last accessed April 4, 2011 ). <http://www.energystar.gov/index.cfm?c=fixtures.pr_crit_light_fixtures>.

16 Northeast Energy Efficiency Partnership. Commercial Buildings and Technologies Initiative

. 2009 (Last accessed April 4, 2011 ) < http://neep.org/regional- initiatives/1/56/Commercial

Buildings- and -Technology- Initiative >

17 Efficiency Vermont. High Performance T8 Eligible Products & Fact Sheet . (Last accessed April 4, 2011 .) < http://www.efficiencyvermont.com/stella/filelib/2008_HPT8FactSheet_FINAL1207.pdf >.

18 Efficiency Vermont. 2010 Rebate Application. 2010. (Last accessed April 4, 2011 ). < http://www.efficiencyvermont.com/stella/fileli b/2010_LightingRebateApplication_FINAL.pdf >.

19 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics . Current Industrial Reports, Fluorescent Lamp Ballasts, MQ335C. 2008. (Last accessed April 4, 2011 ). <http://www.census.gov/mcd/>

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

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

22 Philips. Smart T Bay . (Last accessed April 4, 2011 ).

< http://ww w.smartlightingtechnology.com/pdf/SmarTBay_608.pdf

.

23 Osram Sylvania. Ballast-Lamp Technology Update . 2000. (Last accessed April 4, 2011 ).

< http://www.lighthouseconsultingllc.com/Osram_Sylvania/Sylvania%20Ballast%20update.pdf >.3-41 24 Osram Sylvania. Ballast Technology Applications and Specifications Guide . 2009. (Last
accessed April 4, 2011 .) < http://www.sylvania.com/onlinemedia/ihdp/BallastSpec Guide/#?page=4 >.

25 National Lighting Product Information Program. Lighting Answers: Electromagnetic Interference Involving Fluorescent Lighting Systems . 1995. (Last accessed April 4, 2011 ).

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

26 International Rectifier. International Rectifier Introduces Robust Self- Oscillating Electronic Ballast Lighting Control IC . 2009. (Last accessed April 4, 2011 .) < http://www.irf.com/whats

new/nr051122.html >.