Energy Conservation Standards Rulemaking Framework Document for Fluorescent Lamp Ballasts

Docket Number: EERE

- 2015

- BT

- STD

- 0006
RIN: 1904

- AD51

U.S. Department of Energy Office of Energy Efficiency and Renewable Energy Building Tech nologies Program

June 9, 2015i TABLE OF CONTENTS

SECTION 1 INTRODUCTION

................................ ................................ ............................... 1
1.1 Authority and Background

................................ ................................ ............................ 1
SECTION 2 OVERVIEW OF THE RULEMAKING PROCESS

................................ ........... 2
2.1 Energy Conservation Standard Rulemaking Process and Stakeholder Participation

... 2

2.1.1 Preliminary Analyses and Notice of Public Meeting

................................ ................ 4
2.1.2 Notice of Proposed Rulemaking

................................ ................................ ............... 5
2.1.3 Final Rule

................................ ................................ ................................ .................. 6
2.1.4 Overview of Analyses for Rulemaking

................................ ................................ ..... 7
2.2 Test Procedures

................................ ................................ ................................ ............. 9
2.3 Standby and Off Mode Standards

................................ ................................ ................. 9
2.4 Metric

................................ ................................ ................................ ......................... 10
SECTION 3 SCOPE OF COVERAGE

................................ ................................ .................. 11
3.1 Fluorescent Lamp Ballasts Currently Subject to Standards

................................ ........ 12
3.2 Additional Fluorescent Lamp Ballasts for Which DOE Might Consider Standards

.. 12

3.2.1 Additional Dimming Ballasts

................................ ................................ ................. 12
3.2.2 Four

- Foot MBP T8 Programmed Start Ballasts with an Average Current Less Than
140 mA

................................ ................................ ................................ ................................ . 13
3.2.3 Ballasts Operating at 480 Volts

................................ ................................ .............. 14
3.3 Additional Fluorescent Lamp Ballasts for Which DOE Does not Plan to Consider
Standards

................................ ................................ ................................ ......................... 14
SECTION 4 MARKET AND TECHNOLOGY ASSESSMEN T

................................ .......... 15
4.1 Market Assessment Overview

................................ ................................ .................... 15
4.2 Product Classes

................................ ................................ ................................ ........... 16
4.3 Technology Assessment

................................ ................................ .............................. 18
SECTION 5 SCREENING ANALYSIS

................................ ................................ ................ 20
SECTION 6 ENGINEERING ANALYSIS

................................ ................................ ............ 21
6.1 Overview

................................ ................................ ................................ ..................... 21
6.2 Representative Product Classes

................................ ................................ .................. 22
6.3 Baseline Ballasts

................................ ................................ ................................ ......... 22
6.4 Identify Higher

- Efficiency Ballast Replacements

................................ ...................... 22
6.5 Efficiency Levels

................................ ................................ ................................ ........ 23
6.6 Pricing Analysis

................................ ................................ ................................ .......... 23
6.7 Scaling to Product Classes Not Analyzed

................................ ................................ ... 24
6.8 Proprietary Designs

................................ ................................ ................................ ..... 24
6.9 Outside Regulatory Changes Affecting the Engineering Analysis

............................. 25
SECTION 7 ENERGY USE ANALYSIS

................................ ................................ .............. 25
7.1 Reduced Wattage Options

................................ ................................ ........................... 26
7.2 Lighting Controls

................................ ................................ ................................ ........ 27
7.3 New Data Sources

................................ ................................ ................................ ....... 28
SECTION 8 MARKUPS ANALYSIS

................................ ................................ ................... 28
SECTION 9 LIFE

- CYCLE COST AND PAYBA CK PERIOD ANALYSIS

....................... 30
9.1 Energy Prices

................................ ................................ ................................ .............. 32
9.2 Life

- Cycle Cost Discount Rates

................................ ................................ .................. 33
9.3 Installation, M aintenance, and Repair Costs

................................ ............................... 33ii 9.4 Fluorescent Lamp Ballast Lifetime

................................ ................................ ............. 34
SECTION 10 SHIPMENTS

................................ ................................ ................................ ..... 35
10.1 No

- New

- Standards Case Projections

................................ ................................ .......... 35
10.2 Accounting Methodology

................................ ................................ ........................... 36
10.3 Standards Effects on Ballast Shipments

................................ ................................ ..... 36
SECTION 11 NATIONAL IMPACT ANAL YSIS

................................ ................................ .. 37
11.1 Inputs to Projections

................................ ................................ ................................ ... 37
11.2 Calculation of National Energy Savings

................................ ................................ ..... 38
11.3 Net Present Value

................................ ................................ ................................ ....... 39
SECTION 12 CONSUMER SUBGROUP AN ALYSIS

................................ .......................... 39
SECTION 13 MANUFACTURER IMPACT ANALYSIS

................................ ...................... 40
13.1 Sources of Information

................................ ................................ ............................... 40
13.2 Industry Cash

- Flow A nalysis

................................ ................................ ...................... 41
13.3 Manufacturer Subgroup Analysis

................................ ................................ ............... 41
SECTION 14 UTILITY IMPACT ANALY SIS

................................ ................................ ....... 42
SECTION 15 EMPLOYMENT IMPACT AN ALYSIS

................................ ........................... 42
SECTION 16 EMIS SIONS ANALYSIS

................................ ................................ .................. 44
SECTION 17 MONETIZING CARBON DI OXIDE AND OTHER EMIS SIONS

................. 46
SECTION 18 REGULATORY IMPACT AN ALYSIS

................................ ............................ 47

LIST OF TABLES

Table 2.1 Preliminary Rulemaking Schedule for Fluorescent Lamp Ballast Energy Conservation
Standards

................................ ................................ ................................ ................................ ......... 4 Table 4.1 2011 Ballast Rule Technology Options

................................ ................................ ........ 19 Table 7.1 Average Annual Lamp

- and

- Ballast System Operating Hours by Sector

..................... 26 Table 7.2 2011 Ballast Rule

– Adjusted Average Annual Operati ng Hours for Commercial Sector

................................ ................................ ................................ ................................ ....................... 27 Table 9.1 Inputs to the Life

- Cycle Cost and Payback Period Analysis

................................ ........ 32 Table 11.1 Inputs to the National Impact Analysis

................................ ................................ ....... 38

LIST OF FIGURES

Figure 2.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Energy Conservation Standard Rulemaking Process

................................ ................................ ................................ ......... 8 Figure 8.1 Ballast Rule Distribution Channels for Commercial and Industrial Ballasts

.............. 29iii LIST OF ABBREVIATIONS

AEO Annual Energy Outlook
BF Ballast factor
BLE Ballast luminous efficiency
BLS Bureau of Labor Statistics
BOM Bill of materials
CAIR Clean Air Interstate Rule
CBEC S Commercial Building Energy Consumption Survey
CFR Code of Federal Regulations
CSAPR Cross

- State Air Pollution Rule
CSL Candidate standard levels
DALI Digitally addressable lighting interface
DOE Department of Energy
DOJ Department of Justice
EGU El ectric generating units
EIA Energy Information Administration
EL Efficiency level
EMI Electromagnetic interference
EPA U.S. Environmental Protection Agency
EPCA Energy Policy and Conservation Act
FFC Full

- fuel

- cycle
GHG Greenhouse gas
GRIM Governme nt Regulatory Impact Model
GSFL General service fluorescent lamp
HAP Hazardous air pollutants
HVAC H eating, ventilating, and air conditioning
LCC Life

- cycle cost
LMC Lighting Market Characterization
LED light

- emitting diode
MATS Mercury and Air Toxi cs Standards
MECS Manufacturer Energy Consumption Survey
MIA Manufacturing impact analysis
MPC Manufacturer production costs
MSP Manufacturers’ selling prices
NAECA N ational Appliance Energy Conservation Amendments
NEMS National Energy Modeling System
NES National energy savings
NIA National impact analysis
NPV Net present value
OEM Original equipment manufacturer
OMB Office of Management and Budget
PBP Payback period
PM Particulate matter
PS Program m ed

- start RECS Residential Energy Consumptio n Surveyiv SCC Social cost of carbon
TLED tubular light

- emitting diode
TSD Technical support document
TSL Trial standard levels
UL Underwriters Laboratories1 RULEMAKING FRAMEWORK DOCUMENT FOR
FLUORESCENT LAMP BAL LASTS

SECTION 1 INTRODUCTION
The U.S. Department of Energy (DOE) develops and promulgates test procedures and energy conservation standards for certain consumer appliances and commercial equipment. The process for developing standards involves analysis, public notice and comment, and consultation
with i nterested parties. Interested parties , also referred to as stakeholders, include manufacturers,

consumers , energy conservation and environmental advocates, s tate and f ederal agencies, and any other groups or individuals with an interest in these standards and test procedures.

The purpose of this document is to describe the procedural and analytical approaches DOE anticipates using to evaluate energy conservation standards for fluorescent lamp ballasts . It is intended to inform interested parties a nd to en courage and facilitate their input during the rulemaking. This document is the starting point for developing standards and not a definitive statement with respect to any issue to be determined in the rulemaking.

Section 2 discuss es the rulemaking process. DOE will maintain documents and
i nformation regarding this rulemaking on the DOE website at: http://www1.eere .energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=110

.

While DOE invites stakeholder comment on all aspects of the material presented in this document, specific issues on which DOE seeks comment are highlighted by comment boxes.
These com ment boxes include questions on the approaches DOE is proposing for the analyses required for the rulemaking. Appendix A lists t he items from all such boxes

.

1.1 Authority and Background
Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA) , Public Law (Pub. L.) 94

- 163 (42 U.S.C. 6291

- 6309, as codified) established the “Energy Conservation Program for Consumer Products Other Than Automobiles,” 1 a program covering most major household appliances. Additional ame ndments to EPCA have given DOE the authority to regulate the energy efficiency of several products, including certain fluorescent lamp ballasts

— the products that are the subject of this document. Amendments to EPCA in the National Appliance Energy Conserva tion Amendments of 1988 (NAECA 1988), Pub. L. 100

- 357, established energy conservation standards for fluorescent lamp ballasts. (42 U.S.C. 6295(g)(5)) These same amendments also required that DOE: (1) conduct two rulemaking cycles to
determine whether thes e 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))

DOE completed the first cycle of amendments by publishing a final rule in September 2000 (hereafter the “2000 Ballast Rule”). 65 FR 567 40 (Sept. 19, 2000). This first rulemaking

1 For editorial reasons, upon codification i n the U.S. Code (U.S.C.), Part B was redesignated as Part A.2 cycle established a consensus standard, representing an agreement betwee n the fluorescent lamp ballast industry and energy

- efficiency advocacy organizations. The standard levels adopted replaced the ballast efficacy factors that were promulgated in NAECA 1988 for certain fluorescent lamp ballasts. The standard level adopted wa s intended to eliminate certain so

- called “magnetic” ballasts that operate lamps at line frequency (60 hertz) and are less efficient than “electronic” ballasts, which operate at high frequency. 2

It was later realized that due to the structure of the lang uage in the consensus standard adopted by DOE in the 2000 Ballast Rule, it would still be possible for manufacturers to produce and sell magnetic ballasts for certain types of fluorescent lamps. Aware of this problem, Congress took action on this issue, an d promulgated new energy conservation standards for certain fluorescent lamp ballasts under the Energy Policy Act of 2005 (EPACT 2005), Pub. L.
109

- 58. (EPACT section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)) On October 18, 2005, DOE published a fina l rule in the Federal Register codifying those new fluorescent lamp ballast standards into the Code of Federal Regulations (CFR) at 10 CFR 430.32(m). 70 FR 60407. These
standards established minimum ballast efficiency requirements for “energy saver” versio ns of
full

- wattage ballasts, such as the F34T12 ballast.

Following the amendments from EPACT 2005, the second rulemaking cycle required by 42 U.S.C. 6295(g)(7) was completed with the publishing of a final rule in November 2011 (hereafter the “2011 Ballas t Rule”). 76 FR 70548 (Nov. 14, 2011). The 2011 Ballast Rule changed the metric required of tested fluorescent ballasts from ballast efficacy factor to ballast
luminous efficiency (BLE) and set minimum requirements.

Within six years of the publication of a final rule, EPCA mandates that DOE is to publish either a notice of determination that standards do not need to be amended or a notice of proposed rulemaking including new proposed standards. (42 U.S.C. 6295(m)) This F ramework document
and the associate d public meeting represent the first step in that six year review process to consider whether energy conservation standards for fluorescent ballasts should be amended

.

SECTION 2 OVERVIEW O F T HE RULEMAKING PROCES S

2.1 Energy Conservation Standard Rulemaking Process and Stakeholder Participation
When DOE evaluates any new or amended energy conservation standard for “covered products,” EPCA, as amended, specifies that any standard DOE prescribes for consumer products must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Moreover, the Secretary of Energy (Secretary) may not establish a new or amended standard if such standard would not result in a significant conservati on of energy. (42 U.S.C. 6295(o)(3)(B)) In determining whether a standard is economically justified, DOE must consider, to the greatest extent practicable, the following seven factors:

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

- foot T12 single pin slimline lamps (F96T12).3 (1) T he economic impact of the standard on the manufacturers and on the co nsumers of the products subject to such standard;

(2) T he savings in operating costs throughout the estimated average life of the covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance exp enses of, the covered products which are likely to result from the imposition of the standard;

(3) T he total projected amount of energy, or as applicable, water, savings likely to result directly from the imposition of the standard;

(4) A ny lessening of the utilit y or the performance of the covered products likely to result from the imposition of the standard;

(5) T he impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard;

(6) T he need for national energy and water conservation; and

(7) O ther factors the Secretary considers relevant.

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

- (VII) )

The process of developing energy conservation standards involves analysis, public notice,
and consultation with interested parties. Such interested parties generally include manufacturers, consumers, energy conservation and environmental advocates, state and federal agencies, and any other groups or individuals with an interest in energy conservation standards and test procedures. DOE considers participation of interested parties to be a very important part of the rulemaking process. Accordingly, DOE actively encourages the participation and interaction of all interested parties during the comment period provided at each stage of the rulemaking. The broad array of interested parties who routinely provide comments promotes a balanced discussion of critical information required to conduct the standards rulemaking, beginning with public comment on the framework document

.

In conducting energy conservation standards rulemakings, DOE involves interested parties through a variety of means. As discussed in further detail below, the standards rulemaking process typically involves three public notices in addition to the notic e of availability of the framework document. All of these notices are published in the Federal Register

. Publication of the framework document, preliminary analysis, and notice of proposed rulemaking (NOPR) are typically accompanied by public meetings and comment periods to solicit comment from interested parties to enhance the rulemaking process.

• Preliminary Analysis and Notice of Public Meeting (section 2.1.1 ). The preliminary analysis is designed to publicly vet the models and tools that DOE will use in the rulemaking, and to facilitate public participation before the proposed rule stage. Candidate standard levels (CSLs), which are levels that span the range of efficiencies4 from baseline products to the most efficient technology, are the basis for demonstrating the functionality of the models and tools.

• Notice of Proposed Rulemaking (section 2.1.2 ). The NOPR presents a discussion of comments received in response to the preliminary analysis; DOE’s analysis of the impacts of potential standards on consumers, manufacturers, and the nation; DOE’s weighing of these impacts; and the proposed standard levels for public comment.

• Final Rule (section 2.1.3 ). The final rule presents a discussion of comments received in response to the NOPR; the revised analysis of the impacts of standards; DOE’s weighing of the impacts; and the standard levels DOE is adopting. The final rule also estab lishes
the date for compliance with any standards.

DOE has prepared a p reliminary schedule for the fluorescent lamp ballast rulemaking in
Table 2.1

.

Ta ble 2.1 Preliminary Rulemaking Schedule for Fluorescent Lamp Ballast Energy
Conservation Standards

Deliverable Publication Date

Framework Document Ju ne 2015
Preliminary Analysis September 2016

NOPR October 2017

Final Rule October 2019

2.1.1 Preliminary Analyses and Notice of Public Mee ting
During the preliminary analysis phase of this rulemaking, DOE presents the models and tools it will use to conduct the four principal analyses that the preliminary analysis comprises

— the engineering analysis, life -cycle cost (LCC) and payback period (PBP) analysis , national impact analysis (NIA), and preliminary manufacturing impact analysis (MIA). Before conducting the engineering analysis, DOE typically identifies technology options to increase efficiency and then preliminarily determines whether to retain that option for detailed analysis or to eliminate it from further consideration. The process for consideration of technology options includes a market and technology assessment (see Section 4 ) and a screening analysis ( see Section 5 ). DOE applies four screening criteria in the screening analysis to determine which technology options to eliminate from further consideration: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety. DOE refers to the t echnology options that remain after the screening analysis as design options in the engineering analysis. DOE consults with interested parties and independent technical experts to identify the design options, efficiency levels, or key issues that DOE will consider in the rulemaking.

N ext, DOE considers design options or efficiency levels for each product class. DOE
coll ects manufacturer cost data, historical shipment data, shipment

- weighted average efficiency data, and preliminary manufacturer impact data ( e.g. , capital conversion expenditures, marketing5 costs, and research and development costs) based on these design op tions or efficiency levels. DOE then conducts the principal analyses, including: (1 ) the engineering analysis (see Section
6 ); (2 ) the LCC and PBP analysis (see Section 9 ); (3 ) the NIA, which consid ers national energy savings (NES) and consumer net present value (NPV) (see Section 11 ); and (4 ) a preliminary MIA (see Section 13 ). DOE will present the results of t hese analyses in the preliminary technical support document (TSD).

Based on the results of the preliminary analysis described previously, DOE selects CSLs from among the energy

- efficiency levels considered in the preliminary analysis. DOE uses analytical models and tools to assess the different product classes at each CSL analyzed. Many of these analytical models and tools are in the form of spreadsheets, which are also used to conduct the LCC and PBP analysis and to determine the NES and NPV of CSLs. DOE will make the spreadsheet tools used in the preliminary analysis and the results of the preliminary analysis
available on its website for review. The p ublication of DOE ’s analysis of various CSLs in the preliminary analysis will enable interested parties to review the spreadsheet models (also posted on DOE’s website) that underpin the analyses and provide DOE with comments so that the
models can be refined.

DOE will also make a TSD available containing the details of all the analyses performed
to date whe n it publishes the preliminary analysis. After publication of the preliminary analysis, DOE will provide a public comment period and hold a public meeting. In addition, DOE encourages interested parties to make joint recommendations for CSLs and to submit them to
DOE for consideration.

2.1.2 Notice of Proposed Rulemaking
In the next stage of the rulemaking, the NOPR, DOE generally considers energy

efficiency levels or design options that span technologically achievable efficiencies. The range of levels DOE typi cally analyzes includes the following:

• The baseline efficiency level (the minimum level) set by the product with the lowest

energy

- efficiency level currently sold on the market for a given category; for product categories where minimum federal energy cons ervation standards already exist, this is typically defined by the existing energy conservation standard;

• The efficiency levels (ELs) with the greatest NPV and different LCC effects on

consumers ;

• The highest, most efficient EL or lowest energy consumption EL that is technologically feasible (maximum technologically feasible [max tech] level); and

• ELs that incorporate technologies of significance or fill in large gaps between other ELs
considered.

For the NOPR, DOE reviews and considers all the comments re ceived after the publication of the preliminary analysis. This process may result in revisions or refinements to the6 preliminary analyses, including the engineering analysis, and LCC and PBP analysis. DOE also
will conduct additional economic and environme ntal impact analyses at this stage of the rulemaking. These analyses generally include a consumer subgroup analysis (see Section 12 ), a complete manufacturer impact analysis (see Section 13 ), a utility impact analysis (see Section
14 ), an employment impact analysis (see Section 15 ), an emissions analysis (see Section 16 ), a monetized emissions analysis (see Section 17 ), and a regulatory impact analysis (see Section 18 ).

DOE describes the methodolo gy used and posts the results of all the analyses on its website for review and comments. Based on comments by stakeholders, further revisions to the analysis may be undertaken. This analytical process ends with the proposal of standard levels in
the NOPR. DOE proposes standard levels based on the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking. The NOPR, published in the Federal Register

, documents the evaluation and selection of the proposed standard level(s), along with a di scussion of other TSLs considered but not selected (and the reasons for not selecting them).

The selection process for proposed efficiency standards generally runs as follows. For each product class, DOE will identify the max tech EL. If DOE proposes a l evel lower than the max tech level, it will sequentially explain the reasons for eliminating higher levels beginning with the highest level considered. DOE will present the analytical results in the NOPR and the analysis details in an accompanying TSD.

D OE considers many factors in selecting proposed standards, as described in section 2.1

. These factors and criteria are prescribed by EPCA and take into consideration the impacts of energy conservation standards. In addition, as stated previously, DOE encourages stakeholders to make joint recommendations for standard levels. DOE carefully considers such recommendations in its decision process.

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

c opy of the NOPR and TSD to solicit DOJ review of the impact of the proposed standard levels on competition in the lighting industry. Publication of the NOPR is followed by a public comment period typically lasting 60 days.

2.1.3 Final Rule
After the publicatio n of the NOPR, DOE will consider public comments it receives on the proposal and supporting analyses. Based on the public comments, DOE will review the supporting analyses and proposed standards and consider modifications where necessary. Before issuing th e final rule, DOE will also consider DOJ comments on the NOPR relating to the impacts of the proposed standard levels on competition to determine whether changes to these
standard levels are needed.

The standards rulemaking will conclude with the publica tion of the final rule. DOE will select the final standard level based on the complete record of the standards rulemaking. The final rule will promulgate the final standard level and the compliance date and explain the basis
for its selection. The final ru le will be accompanied by a final TSD.7 2.1.4 Overview of Analyses for Rulemaking
The purpose of the analyses conducted in support of the standards rulemaking is to ensure that DOE selects energy conservation standards that achieve the maximum improvement in

en ergy efficiency that is technologically feasible and economically justified, and will result in significant energy savings. Economic justification includes the consideration of economic impacts on domestic manufacturers and consumers, national benefits inc luding environmental impacts, issues of consumer utility, and impacts from any lessening of competition. DOE expects the selection of such standards to achieve the maximum energy savings that are economically justified without imposing excessive financial burden on any particular party.

Figure 2

. 1 summarizes the analytical components of the standards

- setting process. The “analyses” are presented in the center column. Each analysis has a set of “key inputs,” which are data and information required for the analysis. “Approaches” are the methods that DOE will use to obtain key inputs, which may vary depending on the information in question. For example, some key inputs exist in public databases; DOE will collect other information from stakeholders or experts with special knowledge, and DOE will g ather other information in support of this rulemaking. The results of each analysis are “key outputs,” which feed directly into the rulemaking. Arrows indicate the flow of info rmation between the various analyses. DOE ensures a consistent approach to its analyses throughout the rulemaking by considering each analysis as a part of the overall standards

- setting framework.8 Figure 2

. 1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Energy Conservation Standard Rulemaking Process9 2.2 Test Procedures
EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and amendment of test procedures. (42 U.S.C. 6293 ) Manufacturers of covered products must use these test procedures to certify to DOE that their products comply with EPCA energy conservation standards and to quantify the efficiency of their product.

DOE published a test procedure final rule on May 4, 2 011, (hereafter the “2011 Test Procedure Final Rule”) establishing revised active mode test procedures for fluorescent lamp ballasts. 76 FR 25211. The 2011 test procedure final rule established appendix Q to subpart B of Title 10 of the CFR part 430. 3

O n February 4, 2015, DOE published a final rule amending the test procedures for fluorescent lamp ballasts (hereafter the “2015 Ballast Correction final rule ”). 80 FR 5896. The adopted corrections followed the intent of the 2011 Test Procedure Final Rule to support any new or revised energy conservation standards at the time those standards require compliance. The compliance date for these revisions is August 3, 2015.

On June 5

, 2015 , DOE published a final rule clarification to the test procedure and energ y conservation standard for fluorescent lamp ballasts (hereafter the “2015 Ballast Clarification final rule”). The intent of this final rule was to clarify definitions and test setup, to modify organization of requirements, and to delete obsolete requireme nts. 80 FR 31971 . The compliance
date for these revisions is December 2, 2015

.

Item 2

- 1 DOE welcomes comment on the current test procedures and whether or not
amendments are needed.

2.3 Standby and Off Mode Standards

EPCA defines active mode as the condition in whic h an energy

- using piece of equipment is connected to a main power source, has been activated, and provides one or more main functions (42 U.S.C. 6295)(gg)(1)(A)). Standby mode is defined as the condition in which an

energy

- using piece of equipment is conne cted to a main power source and offers one or more of the following user

- oriented or protective functions: facilitating the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal

sensor, or timer; or providing continuous functions, including information or status displays (including clocks) or sensor

- based functions. Id

. Off mode is defined as the condition in which

an energy

- using piece of equipment is connected to a main power source, an d is not providing any standby or active mode function. Id

.

3 The 2011 Test Procedure Final Rule originally established appendix Q 1 to subpart B of Title 10 of the CFR part
430 , which was subsequently redesignated as appendix Q to subpart B of Title 10 of the CFR part 430 by the 2015 Ballast Clarification final rule. 80 FR 31971 (June 5, 2015)

.10 EPCA requires DOE to amend test procedures to include standby mode and off mode energy consumption in the overall energy efficiency, energy consumption, or other energy descriptor for each cover ed product for which DOE’s current test procedures do not fully account for standby mode and off mode energy consumption. If an integrated test procedure is not feasible, DOE must prescribe a separate standby mode and off mode energy use test procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) In October 2009, DOE prescribed a separate standby mode test procedure and determined that fluorescent lamp ballasts do not exhibit off mode energy use. In addition, DOE stated that the only ballasts subjec t to standby mode power measurements would be those that incorporate some electronic circuit enabling the ballast to communicate with and be part of a lighting control system ( e.g. , a digitally addressable lighting interface (DALI)). 74 FR 54445 (Oct. 22, 2009).

EPCA also requires any final rule establishing or revising a standard for a covered product adopted after July 1, 2010 incorporate standby mode and off mode energy use into a single amended or new standard if feasible or separate standard if not f easible. (EPCA section 325(gg)(3); 42 U.S.C. 6295(gg)(3)) In addition, the single amended new or separate standard
must achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)( A))

As discussed in section 3.2.1 , DOE is considering standards for additional dimming
ballasts

, which could include DALI

- enabled fluorescent lamp ballasts. Pursuant to EPCA, DOE would consider standby mode e nergy consumption if standby mode capable dimming ballasts

we re considered for standards.

Item 2

- 2 DOE welcomes comment on which ballasts are capabl e of operating in standby mode and any other information relating to standby mode energy use

.

2.4 Metric

Current energ y conservation standards for fluorescent lamp ballasts are applicable to active mode energy use and are based on BLE. This metric is a ratio of the power provided by the ballast to the lamp divided by the input power to the ballast. The metric also include s an adjustment factor to account for the reduced system efficacy associated with operation at low

frequency ( i.e. , 60 Hertz). DOE plans to continue using the BLE metric in this energy conservation standard rulemaking to regulate active mode energy use.

As discussed in section 2.3 , DOE may consider standards for standby mode energy consumption. The standby mode test procedure at appendix Q to subpart B of Title 10 of the CFR part 430 measures the input power to the ballast whe n operating in standby mode and also the control signal power. DOE would consider using a combination of input power and control signal measurements to establish a metric for regulation of standby mode energy consumption.11 Item 2

- 3 DOE welcomes comment on the metri cs used for establishing energy conservation standards for active mode and standby mode energy use.

SECTION 3 SCOPE O F COVERAGE
The definition of fluorescent lamp ballast and fluorescent lamp establish the scope of coverage of this rulemaking. These terms are defi ned below. Any product meeting the definition of fluorescent lamp ballast is included in DOE’s scope of coverage, though all products within the scope of coverage may not be subject to standards.

Fluorescent lamp ballast means a device which is used to st art and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation. 10 CFR 430.2

Fluorescent lamp means a low pressure mercury electric

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

(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 rat ed 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 hig h output lamps) with recessed double contact 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 49 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 25 or more; and

(6) Any straight

- shaped lamp (commonly referred t o 4

- foot miniature bipin high output lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches and rated wattage of 44 or more.

10 CFR 430.212 3.1 Fluorescent Lamp Ballasts Currently Subject to Standards
As directed by 42 U.S.C. 629 5(m), in this rulemaking DOE must review the current standards for fluorescent lamp ballasts and determine whether amended standards would result in significant conservation of energy, be technologically feasible, and be economically justified. (42
U.S.C. 6295(n)(2)) Fluorescent lamp ballasts that are currently required under EPCA, as amended, to comply with energy conservation standards include fluorescent lamp ballasts

m anufactured on or after November 14, 2014 , that are designed to operate at an input vo ltage at or between 120 volts (V) and 277 V and with an input current frequency of 60 h ertz , and are designed to operate the following lamps:

• 4

- foot medium bipin (MBP) lamps with a rated wattage of 25 W or more;

• 2

- foot MBP U

- shaped lamps with a rated watt age of 25 W or more;

• 8

- foot high output (HO) lamps;

• 8

- foot slimline lamps with a rated wattage of 49 W or more;

• 4

- foot miniature bipin (miniBP) standard output (SO) lamps with a rated wattage of 26 W

or more;

• 4

- foot miniBP HO lamps with a rated wattage of 44 W or more;

• 4

- foot MBP lamps with a rated wattage of 25 W or more with a power factor of less than 0.90 and are designed and labeled for use in residential applications; and

• 8

- foot HO lamps that have an Underwriters Laboratories (UL) Type 2 rating and ar e designed, labeled, and marketed for use in outdoor signs.

Additionally, there are standards for fluorescent lamp ballasts m anufactured on or after November 14, 2014 , that are designed to operate at an input voltage at or between 120 and 277 V
and with a n input current frequency of 60 h ertz , for dimming to 50 percent or less of the maximum output of the ballast , and to operate one or two F34T12 lamp s, two F96T12 Energy Saver ( ES ) lamps , or t wo F96T12 HO ES lamps . 10 CFR 430.32(m)

3.2 Additional Fluorescent L amp Ballasts for Which DOE Might Consider Standards

3.2.1 Additional Dimming Ballasts
At the time of the 2011 Ballast Rule, DOE determined that dimming ballasts of all types represented less than 1 percent of shipments and were primarily installed in energy

- sav ing applications. DOE believed there was little risk of dimming ballasts becoming a substitute for
other ballasts subject to standards , as the analyzed dimming ballasts were more expensive than comparable fixed

- light

- output ballasts and required specialize d control systems, resulting in additional up

- front cost. For these reasons, DOE did not consider standards for dimming ballasts beyond the ballasts that operate the four reduced

- wattage lamp combinations already subject to13 energy conservation standards. 7 6 FR 20090, 20098 (April 11, 2011); 76 FR 70548, 70557 (Nov. 14, 2011).

Over time, dimming ballast shipments have increased and are now available for use with several lamp types. 4 The recent general service fluorescent lamp (GSFL) and incandescent
reflec tor lamp energy conservation standards rulemaking determined that about 8 percent of GSFLs are now operated by dimming ballasts. 80 FR 4042 (Jan. 26, 2015). Furthermore, state and local regulations and building codes, such as California’s new continuous or multiple light levels dimming requirements for most spaces under CA Title 24 5 and the increased lighting control requirements in ASHRAE 90.1

- 2013, 6 will continue to support an increase in the installation of dimming ballasts in the near future.

DOE find s the increased prevalence of these ballasts warrants an analysis of the technological feasibility, economic justification, and potential for significant energy savings of energy conservation standards for dimming ballasts. DOE plans to carry out this anal ysis for additional dimming ballasts in this rulemaking

.

Item 3

- 1 DOE welcomes comment on the feasibility and justification for setting standards for additional dimming fluorescent lamp ballasts

. In particular

, DOE requests market and shipment information as well as information regarding the potential for efficiency improvements and energy savings

.

3.2.2 Four

- Foot MBP T8 Programmed Start Ballasts with an Average Current Less Than
140 mA
During the 2011 Ballast Rule, DOE found that some low ballast factor (BF) programme d start ( PS ) ballasts operate at currents below minimum American National Standards Institute ( ANSI ) C78.81

- 2010 7 levels, requiring cathode heating to maintain lamp life. Such ballasts have lower efficiencies, but would offer energy savings from their low power levels (relative to normal or high BF ballasts) and use with occupancy sensors. DOE determined that ballasts designed to operate 4

- foot MBP T8 lamps are required to use some level of cathode heating when operating lamps at currents less than 155 mA. Through testing, DOE learned the BF of
the se ballasts was similar to or less than 0.7, a unique utility that might be removed from the
market if these ballasts were held to the established standard level. DOE concluded that

, because
BLE decreases as curren t is dec reased, none of the PS ballasts tested with an average current of
less than 1 40 mA were able to meet the max tech ELs analyzed in the PS product class

.

4 4

- foot MBP lamps, 2

- foot U

- shaped lamps, 4

- foot miniBP SO lamps, and 4

- foot miniBP HO lamps

5 California Energy Commission. 2013 Building Energy Efficiency Standards for Residential and N onresidential Buildings . CEC

‐ 400

‐ 2012

‐ 004

- CMF

- REV2. Sacramento, CA: CEC, 2012. Accessed May 11, 2015: http://www.energy.ca.gov/2012publications/CEC

- 400

- 2012

- 004/CEC

- 400

- 2012

- 004

- CMF

- REV2.pdf

. 6 American Society of Heating, Refrigerating, and Air

- Conditioning Engineers. ANSI/ASHRAE/IES Standard 90.1

- 2013

-- Energy Standard for Buildings Except Low

- Rise Residential Buildings . Atlanta, GA: ASHRAE, 2013.

7 A merican National Standard for Electric Lamps

– Double

- Capped Fluorescent Lamps

– Dimensional and Electrical Characteristics, Approved January 14, 2010.14 Therefore, DOE exempted these low

- current PS ballasts from standards. 76 FR 70548, 70558 (Nov. 1 4, 2011).

DOE plans to reevaluate the justification for excluding from standards T8 MBP PS fluorescent lamp ballasts with an output less than 140 mA per lamp. Specifically , DOE plans to

reassess shipments and the range of efficiency possible and availabl e.

Item 3

- 2 DOE welcomes comment on the current exclusion from standards for T8 MBP PS fluorescent lamp ballasts with an output less than 140 mA per lamp and welcomes any relevant shipment information for these products.

3.2.3 Ballasts Operating at 480 Volts

While exi sting standards apply only fluorescent lamp ballasts that operate at an input voltage at or between 120 and 277 V, the industrial sector also uses 480 V ballasts. Fluorescent lamp ballasts with an input voltage at 480 V that operate 4

- foot MBP T8 and 4

- foo t SO and HO T5 lamps are commercially available. However, the shipment market share for 480 V fluorescent lamp ballasts likely to be small based on the limited availability of 480 V ballasts in catalogs.
DOE may evaluate energy conservation standards for f luorescent lamp ballasts that operate at 480 V in this rulemaking.

Item 3

- 3 DOE welcomes comment on whether standards for fluorescent lamp ballasts that operate at input voltages other than at or between 120 and 277 V would save significant energy and be technolog ically feasible and economically justified . In particular, DOE requests market and shipment information as
well as information regarding the potential for efficiency improvements and energy savings

.

Item 3

- 4 DOE welcomes comment on any additional fluorescent lamp b allasts that should be considered for standards. In particular, DOE requests market and shipment information as well as information regarding the potential for efficiency improvements and energy savings.

3.3 Additional Fluorescent Lamp Ballast s for Which DOE Does not Plan to Consider
Standards

F or applications in which EMI has been or is expected to be an issue, magnetic ballasts are typically recommended. Ap plications potentially sensitive to EMI include : medical operating room telemetry or life support syste ms; airport control systems; electronic test equipment; radio communication devices; radio recording studios; correctional facilities; clean rooms; facilities15 with low signal

- to

- noise ratios; and aircraft hangars or other buildings with predominantly metal
construction. 8 As, in some environments, EMI could pose a serious safety concern that is best mitigated with magnetic ballast technology

, DOE exempted T8 magnetic ballasts designed, labeled, and marketed for use in EMI

- sensitive applications and shipped b y the manufacturer in packages containing 10 or fewer ballasts. 76 FR 70548, 70557 (Nov. 14, 2011).

Because these EMI

- related safety concerns still exist, DOE plans to continue excluding these low frequency T8 fluorescent lamp ballasts from consideration for standards in this rulemaking.

Item 3

- 5 DOE welcomes comment, including shipment information, on the plan to not
amend the current exclusion from standards for low frequency T8 fluorescent lamp ballasts for EMI

- sensitive locations

.

SECTION 4 MARKET A ND TECHNOLOGY ASSES SMENT
The market and technology assessment will provide information about the manufacturers of fluorescent lamp ballasts, and specifics about the performance attributes of these ballasts. This assessment is used to develop product classes and identify tec hnology options to improve BLE for each of the ballast types. The CFR defines “ballast luminous efficiency” as the total fluorescent lamp arc power divided by the fluorescent lamp ballast input power multiplied by the appropriate frequency adjustment facto r.

4.1 Market Assessment Overview
As a part of the market assessment, DOE will qualitatively and quantitatively characterize the structure of the fluorescent lamp ballast market. DOE will identify and characterize the manufacturers, estimate market shares an d trends, address regulatory and non

regulatory initiatives intended to improve the energy efficiency or reduce the energy consumption of ballasts subject to or under consideration for standards , and explore the potential for technological improvements in the design and manufacturing of such products.

This market assessment will serve as a resource to guide the analyses that follow. For example, DOE may use historical shipments and prices as an indicator of future shipments and prices. Similarly, DOE plan s to use market structure data for the manufacturer impact analysis, data that will be particularly useful for assessing competitive impacts. This phase also allows
DOE to start determining design options by reviewing product literature and industry public ations.

DOE has already gathered a large amount of information in support of the 2011 Ballast Rule. DOE recognizes, however, that additional data has become available since the publication

8 This list is not all

- inclusive.16 of that rule. In addition, DOE recognizes that there may be limit ed public information regarding recent trends in national shipments, manufacturing costs, channels of distribution, and manufacturers’ market shares of fluorescent lamp ballasts. This type of data is an important input for analyses that determine if energy conservation standards are economically justified and will result in significant energy savings. Therefore, DOE encourages stakeholders to submit data that pertains to these issues and would aid DOE’s understanding of trends in the fluorescent lamp
ballas t market. These data may be provided under a confidentiality agreement with DOE’s contractor responsible for this part of the rulemaking analysis. DOE’s contractors will then

prepare aggregated results for DOE’s analyses. These aggregated results do not di vulge the sensitive, individual raw data, but enable other interested parties to comment on the aggregated
dataset.

Stakeholders may also submit confidential data to DOE, indicating in writing which data should remain confidential. To prevent public disc losure of the data due to actions taken by a third party, stakeholders providing confidential information to DOE must submit that data according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting information that
he or she believes to be confid ential and exempt by law from public disclosure should submit two copies. One copy of the document shall include all the information believed to be confidential, and the other copy of the document shall have the information believed to be
confidential dele ted. DOE will make its own determination about the confidential status of the information and treat it according to its determination. 9 DOE prepares aggregated results from the data submitted for use in DOE’s analyses. These aggregated results do not divul ge the sensitive nature of the individual raw data, but enable other stakeholders to review and comment on the aggregated dataset.

Item 4

- 1 DOE welcomes information on shipments, product

- feature and efficiency trends, distribution channels, and estimates of market shares for ballasts considered in this rulemaking. For the data to be used to conduct energy savings calculations, please provide appropriate groupings (e.g., by existing product class, technology, and/or other relevant performance characteristics ).

4.2 Prod uct Classes

DOE divides products subject to standards into classes by: (a) the type of energy used; (b) the capacity of the product; or (c) any other performance

- related feature that justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then conducts its analysis and considers establishing or amending standards so as to provide

9 Factors that DOE considers when evaluating requests to treat submitt ed information as confidential include: (1) a description of the items; (2) whether and why such items are customarily treated as confidential within the industry; (3) whether the information is generally known by or available from other public sources; (4 ) whether the information has previously been made available to others without obligation concerning its confidentiality; (5) an explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date
after whic h such information might lose its confidential character; and (7) why disclosure of the information would be contrary to the public interest.17 separate standard levels for each product class. DOE is considering maintaining the current product classes for ballasts currentl y subject to standards. The following list shows the current product classes for fluorescent lamp ballasts.

1. Instant start (IS) and rapid start (RS) ballasts (not classified as residential) that operate

• 4

- foot MBP lamps

• 2

- foot U

- shaped lamps

• 8

- foot slimlin e lamps

2. PS ballasts (not classified as residential) that operate

• 4

- foot MBP lamps

• 2

- foot U

- shaped lamps

• 4

- foot miniBP SO lamps

• 4

- foot miniBP HO lamps

3. IS and RS ballasts (not classified as sign ballasts) that operate

• 8

- foot HO lamps

4. PS ballasts (not classif ied as sign ballasts) that operate

• 8

- foot HO lamps

5. Sign ballasts that operate

• 8

- foot HO lamps

6. IS and RS residential ballasts that operate

• 4

- foot MBP lamps

• 2

- foot U

- shaped lamps

• 8

- foot slimline lamps

7. PS residential ballasts that operate

• 4

- foot MBP lamps

• 2

- f oot U

- shaped lamps

8. Dimming ballasts that operate

• One F34T12 lamp

• Two F34T12 lamps

• Two F96T12 ES lamps

• Two F96T12 HO ES lamps18 As mentioned in section 3.2.1 , DOE is considering analyzing standards for additional dimming fluores cent lamp ballasts in this rulemaking as their annual shipments ha ve increased
since the 2011 Ballast Rule and the market growth is expected to continue with the inclusion of dimming ballasts in many building code requirements. If standards are considered for additional dimming fluorescent lamp ballasts, DOE may consider establishing separate product classes
based on factors such as:

• R esidential versus commercial end use,

• L amp type operated by the ballast,

• C ontinuous dimming,

• S tep dimming,

• 0

- 10V dimming co ntrol,

• P ower line dimming control, or

• S tandardized control interfaces such as digitally addressable lighting interface ( DALI).

Should DOE also analyze low ballast factor PS ballasts and/or 480 V fluorescent lamp ballasts, as discussed in section 3.2.3 , DOE may also consider a separate product class for such ballasts, based on factors such as lamp type operated by the ballast , starting method, and ballast input voltage.

Item 4

- 2 DOE welcomes comment on the product class divisions it is considering for fluorescent lamp ballasts. In particular, DOE welcomes comment on appropriate class

- setting factors for dimming ballasts , low ballast factor PS ballasts, and 480 V fluorescent lamp ballasts

.

Item 4

- 3 DOE welcomes comment on any other class

- setting factors that should be considered in the analysis

.

4.3 Technology Assessment
The technology assessment centers on understanding how energy is used by the product, and what changes are possible that would reduce energy consumption. Measures tha t improve the energy efficiency of the products are called technology options, and they are based on existing technologies, as well as working prototypes. DOE develops a list of technology options, which are then considered against four screening criteria discussed in the following section. Those technology options that pass the four screening criteria are called design options and will be considered as ways to improve the efficiency of the products in the engineering analysis and
will assist DOE in determi ning the max tech designs.19 In the 2011 Ballast Rule, DOE reviewed manufacturer catalogs, recent trade publications, technical journals, and patent filings; and consulted with technical experts to determine technology options. Table 4

. 1 lists the technology options identified to improve the efficiency of fluorescent lamp ballasts in the 2011 Ballast Rule. See chapter 3 of the TSD for the 2011 Ballast Rule for a more complete discussion of the technology options. 10

DOE does not expect electronic ballasts or starting method will continue to be technology options for this rulemaking. Due to market trends and DOE energy conservation standards, magnetic ballasts and rapid start ballasts are no longer sold for the catego ries of ballasts under
consideration for standards.

Table 4

. 1 2011 Ballast Rule Technology Options

Technology Option Description 2011 Ballast Rule TSD
Reference

Electronic Ballast Use an electronic ballast d esign. Chapter 3, Section 3.3.4.2

Improved Components Transformers Use grain

- oriented silicon steel or amorphous
steel to reduce core losses. Chapter 3, Section 3.3.4.3

Use litz wire to reduce winding losses. Chapter 3, Section 3.3.4.3

Use laminated sheets of amorphous steel to
create the core of the inductor. Chapter 3, Section 3.3.4.3

Diodes Use diodes with lower losses. Chapter 3, Section 3.3.4.3

Capacitors Use capacitors with a lower effective series
resistance. Chapter 3, Section 3.3.4.3

T ransistors Use transistors with low drain

- to

- source resistance. Chapter 3, Section 3.3.4.3

Improved

Circuit Design Cathode Cutout Remove filament heating after lamp has started. Chapter 3, Section 3.3.4.4
Integrated

Circuits Substitute discrete componen ts with an integrated circuit. Chapter 3, Section 3.3.4.4

Starting Method Use instant start instead of rapid start as a starting method for lamp operation. Chapter 3, Section 3.3.4.4

In addition to the technology options analyzed in the 2011 Ballast R ule, DOE is considering the following improved components in this fluorescent lamp ballast rulemaking:

• Increasing the number of steel laminations to lower core losses

,

• Using optimized

- gauge copper or increasing the conductor cross section to reduce
windin g losses

,

10 The 2011 Ballast Rule technical support document is available on regulations.gov in docket number EERE

- 2007

- BT

- S TD

- 0016

.20 • Using wire with multiple smaller coils instead of one larger coil to incre ase the number of
turns of wire

, and

• Using shape

- optimized winding to reduce the proximity effect losses

.

Item 4

- 4 DOE welcomes comment on the preliminary technology options identi fied in
this section. DOE welcomes comment on whether there are additional technology options that it should consider.

SECTION 5 SCREENING ANALYSIS
The purpose of the screening analysis is to screen out technologies that will not be considered further in the analy sis. After making an initial list of technologies (during the market and technology assessment), DOE will review and evaluate each technology based on the following four criteria, as specified by 10 CFR part 430, subpart C, Appendix A, sections 4(a)(4)
and 5(b):

1. Technological F easibility. DOE will consider technologies incorporated in commercial products or in working prototypes to be technologically feasible.

2. Practicability to M anufacture, Install, and S ervice. If mass production and reliable
installation and servicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard requires compliance, then DOE will consider that technology practicable to manufacture, install,
and servic e.

3. Adverse I mpacts on P roduct or E quipment U tility to C onsumers or A vailability. If DOE determines a technology would have a significant adverse impact on the utility of the product to significant subgroups of consumers, or would result in the unavailabili ty of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not consider that te chnology
further.

4. Adverse I mpacts on H ealth or S afety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider that technology
further.

DOE will fully document its reasons for eliminating any tec hnology options during the screening analysis, and will publish this documentation for stakeholder review and comment as part of the preliminary analysis. Those technology options not screened out by these four criteria are called “design options” and are considered as possible methods of improving efficiency in the engineering analysis.21 In the 2011 Ballast Rule, the only technology option DOE screened out was the use of laminated sheets of amorphous steel to create the core of the inductor. DOE screened out this technology because this method increases the size and weight of the ballast, which results in the
bal lasts failing to be practical to manufacture, install, and service, and have adverse impacts on product utility. See chapter 4 of the TSD for the 2011 Ballast Rule for more details on the screening analysis.

Item 5

- 1 DOE welcomes comment on the applicability of the four screening criteria to the technology options described in this section , including whether it is still appropriate to screen out the use of laminated sheets of amorphous steel to create the core of the inductor

.

Item 5

- 2 DOE welcomes comment on how the four screening criteria would apply to any additional technology option(s) that an interested party recommends to
DOE

.

SECTION 6 ENGINEERING ANALYSIS

After cond ucting the screening analysis described above, DOE will perform an engineering analysis based on the remaining design options that are available to improve product efficiency. The engineering analysis consists of estimating the energy consumption and cost of equipment at various levels of increased efficiency. As in the 2011 Ballast Rule, to ensure that ELs analyzed are technologically feasible, DOE plans to concentrate its efforts on developing product ELs associated with ballasts designs that incorporate a range of design options based upon commercially available ballasts or working prototypes.

6.1 Overview
The purpose of the engineering analysis is to determine the relationship between the manufacturer selling prices (MSPs) and efficiency of the products un der consideration for
standards . This relationship between price and efficiency serves as the basis for cost/benefit calculations to individual consumers in the LCC and PBP analysis and to the Nation in the NIA.

The engineering analysis will focus on sel ecting commercially available ballasts that incorporate design options that improve BLE . The engineering analysis will also identify the highest efficiency that is technologically feasible within each product class ( i.e. , the max tech model). DOE may deter mine the max tech model by investigating the existence of any fluorescent lamp ballast prototypes with higher efficiency than those commercially available.22 6.2 Representative Product Classes
As discussed previously in this F ramework document, DOE is consider ing establishing eight or more product classes for fluorescent lamp ballasts. DOE is not planning to directly analyze every product class. Instead, DOE will select certain product classes to analyze, and then scale its analytical findings for those represe ntative product classes to other product classes that are not analyzed. DOE typically chooses representative product classes based on high shipment
volumes.

6.3 Baseline Ballasts
Once DOE identifies the representative product classes for analysis, DOE select s representative units (baseline ballasts) from within the representative product classes. These baseline ballasts are generally what DOE believes to be the most

- common, least

- efficient ballasts in their respective product classes.

DOE plans to establish baseline ballasts by analyzing efficiency data in manufacturer catalogs and compliance and certification data submitted to DOE

. For ballasts already subject to energy conservation standards, DOE will select the ballasts that just meet minimum standards.
F or products that do not have existing energy conservation standards, DOE will select the most

common, least

- efficient ballast sold in a given product class.

Item 6

- 1 DOE welcomes comment on the appropriate baseline for ballasts already subject to energy conservati on standards.

Item 6

- 2 If DOE analyze s standards for new categories of ballasts, including additional dimming , low ballast factor PS, or 480 V fluorescent lamp ballasts,
DOE welcomes comment on the appropriate baseline ballast types and efficiency value in those ca tegories

.

6.4 Identify Higher

- Efficiency Ballast Replacements

DOE selects more efficient ballasts for each baseline ballast by considering technologies not eliminated in the screening analysis. DOE considers these technologies in the engineering analysis, ei ther by modeling potential efficiency improvements due to the design options or by analyzing commercially available ballasts in which the design options are incorporated. In identifying more efficient ballast designs, DOE recognizes that a lighting system’ s lumen package and performance characteristics are important design criteria for consumers. DOE chooses substitute ballasts with performance characteristics similar to those of the baseline
ballasts.

DOE plans to account for lumen output when it establi shes ballast designs for its analyses because consumers take lumen package into consideration when purchasing lighting systems. Selections of higher

- efficiency ballasts will be made such that the potential substitutions23 maintain light output within 10 perc ent of the baseline system’s light output, and that the substitute lamp

- and

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

Item 6

- 3 DOE welcomes comment on the methodology it is considering to select higher

- efficiency ball ast designs

.

6.5 Effic ien cy Levels
The efficiency level is an energy conservation standard requirement under consideration for a given product class. After identifying the more efficient substitutes for each baseline ballast, DOE is considering developing EL s based on three factors: (1) the design options associated with specific ballasts being studied; (2) the ability of ballasts across multiple wattages to comply with the standard level of a given product class; and (3) the maximum technologically
feasible level. DOE anticipates developing efficiency levels using an equation that relates the total lamp arc power operated by a ballast to BLE. In the 2011 Ballast Rule, DOE used a power law equation which takes the form:

BBBBBB = AA

1 + BB ∗ pppppppppp − CC

Whe re: power = average total lamp arc power. 11

Item 6

- 4 DOE welcomes comment on its proposed methodology of establishing efficiency levels , including the form of an equation that relates average total lamp arc power to BLE.

Item 6

- 5 DOE welcomes comment on the use of complianc e data and verification testing data when establishing efficiency levels.

6.6 Pricing Analysis
The engineering analysis primarily involves estimating the energy consumption and cost of equipment at various levels of increased efficiency. These estimates are then used to identify
the cost

- efficiency relationship for the equipment. DOE typically structures its estimation of the

cost

- efficiency relationship around one of three methods: (1) the design

- option approach, which
calculates the incremental cost of addi ng specific design options to the baseline model; (2) the efficiency

- level approach, which calculates the incremental costs of achieving increases in energy efficiency, without regard to the particular design options used to achieve such increases;

11 Average total lamp arc power is the aver age of the total lamp arc power of the ballast units tested

.24 and (3) the reverse engineering cost

- assessment approach, which involves a “bottom

- up” manufacturing cost

- assessment based on a detailed bill of materials (BOM) derived from teardowns of equipment being analyzed. Deciding which methodology to use for the engineer ing analysis depends on the product, the technologies under study, and any historical data DOE can draw upon. DOE tentatively plans to use the efficiency

- level approach to identify incremental improvements in efficiency for each piece of equipment. DOE may use a bottom

- up cost

assessment approach to develop a cost if feasible

.

In the 2011 Ballast Rule, DOE used a combination of (1) bottom

- up pricing ( i.e. , product teardowns to generate a BOM) and (2) manufacturer suggested price lists (blue books) and ret ail
data to carry out an efficiency

- level approach . One challenge with completing the bottom

- up approach to pricing for ballasts is the presence of potting (a sticky tar

- like substance that blocks visual inspection of components) on the circuit board. DOE may find that the bottom

- up approach is impractical if ballasts without potting material are unavailable

– and instead use blue books and retail data to develop ballast pricing.

Item 6

- 6 DOE welcomes comment on the pricing methodology, and in particular the feasib ility of using product teardowns to develop pricing

.

6.7 Scaling to Product Classes Not Analyzed
As mentioned previously, DOE plans to select certain product classes as representative and concentrate its analytical effort on those classes. Standards for non

- representative product classes are determined by scaling standards from product classes that were directly analyzed. DOE will develop scaling factors for fluorescent lamp ballasts by comparing the efficiency of
ballasts in the representative product classe s to efficiencies of commercially available ballasts
from non

- representative product classes.

In the 2011 Ballast Rule, DOE did not analyze 8

- foot HO PS ballasts or 4

- foot MBP PS residential ballasts directly. Thus, it was necessary to develop a scaling relationship for these product classes by comparing the efficiency of ballasts that differed only by the characteristic used to establish the scaled product class ( e.g. , starting method). DOE anticipates using a similar method in this rulemaking.

Item 6

- 7 DOE welc omes comments on the methodology to scale energy conservation standards to product classes not directly analyzed.

6.8 Proprietary Designs
DOE will consider in its engineering and economic analyses all design options that are commercially available or present in a working prototype, including proprietary designs, that25 meet the screening criteria discussed in Section 5 . However, DOE will consider a proprietary design in the subsequent analysis only if it does not represent a unique path to a given efficiency level. If the proprietary design is the only approach available to achieve a given efficiency level, then DOE will eliminate the efficiency level from further analysis. DOE will reject a standard level that can be met only with a proprietary technology because it could result in an anti

competitive market, a principal consistently applied in past DOE rulemakings as economically unjustifiable. However, if a given energy

- efficiency level can be achieved by a number of design

approac hes, including a proprietary design, DOE will continue to examine the given efficiency
level.

DOE is aware of the manufacturer concerns about proprietary designs and will take steps to maintain the confidentiality of any proprietary data provided by the manufacturers. This information will provide input to the competitive impacts assessment and other economic analyses.

Item 6

- 8 DOE welcomes comments on proprietary designs it should be aware of for the fluorescent lamp ballasts that are the subject of this rulemak ing

.

6.9 Outside Regulatory Changes Affecting the Engineering Analysis
In conducting an engineering analysis, DOE considers the effects of regulations outside DOE’s statutory energy conservation standards rulemaking process that can affect manufacturers
of t he products under consideration for standards . Some regulatory requirements can also affect
the efficiency or energy consumption of the ballasts subject to standards . DOE will attempt to identify other regulatory requirements that could affect the engineer ing analysis. The consideration of these requirements is closely related to the cumulative regulatory burden assessment that DOE will conduct as part of the manufacturer impact analysis. Based on consideration of the comments received on the engineering an alysis, DOE will make any necessary changes to its analysis

.

Item 6

- 9 DOE welcomes comments on regulatory burdens or changes that should be considered in the engineering analysis

.

Item 6

- 10 DOE welcomes comments on other issues that could affect the engineering analysis

.

SECTION 7 E NERGY USE ANALYSIS
For fluorescent lamp ballasts, DOE will establish the annual energy use of the products and assess the energy savings potential of various product efficiencies. As part of the energy use26 analysis, certain engineering assumptions may be required regarding product application, including how the product is installed and operated. DOE uses the annual energy use and energy savings potential in the LCC and PBP analysis to establish the savings in consumer operating

costs.

To characterize the average use of fluorescent lamp ballasts for a typical year, DOE plans

to develop annual operating hours by sector (commercial, industrial, and residential ). For the
LCC and PBP analysis , DOE will account for variability in operating hours by developing a distribution of operating hours for the LCC

- PBP spreadsheet. The operating hour distributions
will capture variation across building types, lighting applications, and fluorescent lamp

- and

ballast systems for the sectors.

The 2000 Ballast R ule used a dif ferent data set than the 2011 Ballast R ule, but both had similar operating hours for the different sectors. The 2011 Ballast R ule used a combination of data sources including the 2002 U.S. Lighting Market Characterization (LMC) , the Energy
Information Admi nistration’s (EIA) 2003 Commercial Building Energy Consumption Survey (CBECS), the 2005 Residential Energy Consumption Survey (RECS), and the 2006 Manufacturer Energy Consumption Survey (MECS) to develop a distribution of operating hours
for fluorescent la mps by sector and Census Division. See chapter 6 of the TSD for the 2011 Ballast Rule for a more complete discussion of the operating hours. Table 7

. 1 compares the operating hours of two most recent final rules for fluorescent lam p ballasts.

Table 7

. 1 Average Annual Lamp

- and

- Ballast System Operating Hours by Sector

Sector Average Annual Operating Hours hr/yr

2000 Ballast Rule 2011 Ballast Rule

Residential N.R.* 789

Commercial 3,30 0

– 3,700 3,886

Industrial 4,600 4,747

* N.R.

– Not reported

Item 7

- 1 DOE welcomes comment on the approach DOE is taking to determine the operating hours profile for fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment on whether the end

- us e operating profiles are different for the various types of fluorescent lamp ballasts under consideration for standards in this rulemaking, and if so, how

.

7.1 Reduced Wattage Options
Although the subject of this rulemaking is a fluorescent lamp ballast, the energy usage is directly affected by the lamps operating on the fluorescent ballasts. Reduced

- wattage ( e.g. , 30 W,27 28 W, or 25 W lamps for 4

- foot T8 ) fluorescent lamps affect the baseline energy usage of fluorescent lamp ballasts.

DOE is researching the prevalence of tubular light

- emitting diodes (also known as TLEDs)

— LED lamps in the form factor of a fluorescent lamp. DOE is researching the potential effects on baseline energy usage of the use of TLEDs that operate on fluorescent ballasts.

Item 7

- 2 DOE welcomes comment on the wattage of reduced

- wattage fluorescent lamps typically installed as well as what proportion of reduced

- wattage lamps are installed. DOE also welcomes comments on the prevalence of tubular LEDs operating on fluorescent lamp ballasts

.

7.2 Lighti ng Controls

In the 2011 Ballast R ule, DOE accounted for occupancy sensors in the energy use analysis by determin ing an average savings value associated with occupancy sensors. DOE then translated the energy savings into reduced operating hours for the pro ducts operated by

occupancy sensors. Table 7

. 2 includes the operating hours that DOE used in the 2011 Ballast
R

ule related to occupancy sensors.

Table 7

. 2 2011 Ballast Rule

– Adjuste d Average Annual Operating Hours for Commercial
Sector

Sector Average Annual Operating Hours hr/yr

Commercial 2, 721

One product class that DOE is considering is dimming fluorescent lamp ballasts. DOE plans to review data sets, reports, case studies, an d any available documents to determine the portion of time and the output setting to which fluorescent ballasts are dimm ed for task tuning, daylight harvesting, and other applications. DOE also plans to research the common applications and prevalence of di mming ballasts.

Item 7

- 3 DOE welcomes comment on the typical space types operated by occupancy sensors. DOE also welcomes any data on the energy savings related to the use of occupancy sensors. DOE welcomes data on the portion of fluorescent
ballasts used with occ upancy sensors. DOE welcomes any data on the effects of occupancy sensor use o n the operating hours profile for fluorescent lamp
ballasts in this rule.28 Item 7

- 4 DOE welcomes comment on the use of the dimming ballasts: types of ballasts and lamps typically dim m ed; a pplications in which dim m ing occurs; output setting of the dimmed ballasts when in use; typical energy savings for dimming ballasts; and market share of dimming ballasts in use

.

7.3 New Data Sources

DOE plans to use the updated 2010 U.S. Lighting Market Char acterization to develop operating hours by sector. 12 DOE plans to review the current versions of CBECS, RECS 13 , and MECS, but if lighting applicable data is not available in the current versions, DOE plans to revert to early versions of those documents as DO E did previously in the 2011 Ballast R ule.

For the commercial sector, DOE would use LMC commercial sector operating hour data by facility type to develop a distribution of annual operating hours for fluorescent lamp

- and

ballast systems. To develop a dist ribution of annual operating hours in the industrial sector, DOE
would use an approach similar to that used for the commercial sector

, aggregat ing LMC annual operating hour data by industry to develop weighted average annual operating hours. T o develop
a d istribution of annual operating hours for the residential sector, DOE would use LMC data by housing room type

.

Item 7

- 5 DOE welcomes comment on the use of the operating hours profile for fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment

on whether the end

- use operating profiles are different for the various types of fluorescent lamp ballasts under consideration for standards in this rulemaking, and if so, how

.

Item 7

- 6 DOE welcomes comment on any data sources to use to calculate the operating
hours o f fluorescent ballasts and energy savings related to the use of dimming fluorescent ballasts

.

SECTION 8 MARKUPS ANALYSIS

DOE uses consumer price estimates in the NIA and LCC and PBP analys e s. DOE typically uses manufacturer

- to

- consumer markups to convert estimates of the manufacturer selling price derived from the engineering analysis ( see Section 6 ) to consumer prices. The
manufacturer

- to

- consumer markups are in addition to the manufacturer markups on production
costs that DOE uses in estimating manufacturer selling price in the engineering analysis.

12 2010 U.S. Lighting Market Characterization. January, 2012. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010

- lmc

- final

- jan

- 2012.pdf

13 RECS was updated in 2009, but these updates did not address lighting usage; therefore, DOE used RECS 2005
data for th e 2011 Ballast R ule.29 The end

- user product price depends on how the end user purchases the ballast . For commercial and industrial ballast designs, two types of distribution channels describe how most
fluoresce nt lamp ballasts pass from the manufacturer to the end user. The first distribution channel applies to ballasts installed in fixtures. In this distribution channel, the manufacturer sells the ballast to an original equipment manufacturer (OEM)

— in this case , the fixture
manufacturer

— who in turn sells the fixture to an electrical wholesaler ( i.e. , distributor), who sells it to a contractor, who passes it on to the end user. The second distribution channel applies to ballasts not installed in fixtures ( e.g. , r eplacement ballasts ). In this distribution channel , the manufacturer sells the ballast to an electrical wholesaler, who sells it to a contractor, who passes
it on to the end user. Figur e 8

. 1 illustrates the two main distribution c hannels for commercial and industrial ballasts. For residential ballast designs, DOE assumed that the manufacturer sells the ballast to an OEM who in turn sells it in a fixture to a home improvement retailer, where it is purchased by the end user

.

Figur e 8

. 1 Ballast Rule Distribution Channels for Commercial and Industrial Ballasts

For commercial and industrial ballast designs, DOE has assumed in previous rulemakings
that ballasts in fixtures represent 63 percent of the market and replacement ballasts represent 37 percent. These percentages were originally included in the 2000 Ballast Rule, and validated in
the 2011 Ballast Rule

. In previous rulemakings, DOE could not obtain retailer sales data detailing th e breakdown between residential fixture ballasts and replacement ballasts, and therefore assumed that ballasts in fixtures represented 100 percent of the residential market. DOE will consider retaining these assumptions for the current standards rulemaking , based on comment from interested parties.

Consistent with the approach followed for other products and equipment, DOE will determine average baseline and incremental markups by examining the annual Securities and BALLAST MANUFACTURER

OEM FIXTURE
MANUFACTURER

ELECTRICAL WHOLESALER

CONTRACTOR

END

- USER OF LIGHTING SYSTEM FIXTURE BALLASTS REPLACEMENT
BALLASTS30 Exchange Commission (SEC) 10

- K reports filed by publicly traded OEM fixture manufacturers, electrical wholesalers, and home improvement retailers. The baseline markup relates the MSP of baseline products to the distributor sales price. Incremental markups are coefficients that relate the change in the MSP of higher

- efficiency models to the change in the distributor sales price. The incremental markup reflects a situation in which the distributor faces an increase in cost of goods sold for particular products because of manufacturing changes nece ssitated by new or
amended standards.

In addition to developing markups, DOE will develop and include sales taxes to calculate final prices to consumer s. DOE will use an annually updated Internet source, the Sales Tax Clearinghouse, to calculate applicab le sales taxes. 14

Item 8

- 1 DOE seeks comment on the distribution channels and the share of industry shipments for each distribution channel described in this document as it applies to the fluorescent lamp ballasts under consideration for standards in
this rule makin g

.

SECTION 9 LIFE

- CYCLE COST A ND PAYBACK PERIOD AN ALYSIS
The effects of increased energy conservation standards on consumers include a change in operating expense (usually decreased) and a change in purchase price (usually increased). The LCC of a product is the c ost a product incurs over its lifetime, taking into account both purchase price and operating expenses. The PBP represents the time it takes to recover the additional
installed cost of the more efficient device through annual operating cost savings. DOE wi ll analyze the net effect on consumers by calculating the LCC and PBP using the engineering performance data ( Section 6 ), the energy use analysis data ( Section 7 ), and the markups analysis ( Section 8 ). Inputs to the LCC calculation include the installed cost to the consumer (purchase price plus installation cost), operating expenses (energy expenses, and, if applicable, repair costs and maintenance costs), the lifetime of the product or other defined period of analysis, and a discount rate. Inputs to the PBP calculation include the installed cost to the consumer and annual operating costs.

In addition to the LCC and PBP calculations, for certain products DOE also conduct s a rebuttable presumption analysis. Under 42 U.S.C. 6295(o)(2)(B)(iii), the statute establishes a rebuttable presumption that a standard is economically justified “[i]f the Secretary finds that the additional cost to the consumer of purchasing a product c omplying with an energy conservation standard level will be less than three times the value of the energy ... savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure....” For f luorescent lamp ballasts, because the DOE test procedure does not include an input for operating hours, DOE plans to use the average annual operating hours of the

most

- common end

- use application. Although the rebuttable presumption calculation is helpful i n

14 Sou rce: www .thes tc.com/31 understanding that certain standard levels have short payback periods, often DOE has found that

some ELs higher that the rebuttable presumption level are cost

- justified. Therefore, DOE does not make a determination of economic justification based on this calculation alone . Economic justification is based on a weighing of the seven EPCA factors described in section 2.1 . The LCC and PBP analysis described in the following section reflects field conditions and is therefore a more accurate depiction of consumer impacts.

For the p reliminary a nalysis, DOE will conduct the LCC and PBP analysis using typical
values to reflect conditions in the field for product retail price and life, energy costs, energy usage, and di scount rates. If DOE determines that there is significant variability in any of the above inputs, it will conduct sensitivity analyses to determine how the LCC and PBP are impacted by high and low estimates for each of the inputs. For any sensitivity analy ses that it conducts, DOE will account for correlations that may exist between inputs ( e.g. , energy usage may be correlated to energy prices). The detailed impact calculation, which DOE will conduct
after the p reliminary a nalysis, may include an assessment of effects on subgroups of consumers,
as described in Section 12

.

For the NOPR, DOE will carefully review all of the comments it receives on the LCC analysis, make any necessary revisions to the analysis, and evaluate additional parameters not
included in the p reliminary a nalysis, if necessary.

For fluorescent lamp ballasts, DOE will need to determine input values for several variables. The following sections discuss the methodologies DOE plans to use to dev elop energy prices, discount rates, maintenance/repair/installation costs, and ballast lifetimes. Some of the major inputs DOE is anticipating it will develop for the fluorescent lamp ballast LCC and PBP analysis are listed in Table 9

. 1

.32 Table 9

. 1 Inputs to the Life

- Cycle Cost and Payback Period Analysis

Input Description

Product Price The price of certain fluorescent lamp ballasts established in Section 8 , Markups Analysis

.

Sales T ax Sales tax is applied to convert the product price to a final consumer price including
sales tax. Sales tax mark

- ups will be developed in Section 8

, Markups Analysi s

. Maintenance, R epair, and I nstallation C ost This input represents the cost to consumers of installing the ballast as well as the c ost of maintaining that ballast

.

Annual O perating H ours The annual operating hours are the estimated hours that a fluoresc ent lamp ballast is in use during the time span of one year. Operatin g hours are developed in Section 7

, Energy Use Analysis

. Product E nergy C onsumption R ate The product energy consumption is the site

- energy us age rate associated with operati ng the lamp system developed in Secti on 7 , Energy Use Analysis

.

Electricity P rices Electricity prices used in the analysis are the average price per kilowatt

- hour ( i.e.

, $/kWh) p aid by consumer s

. Electricity Price T rends Electricity price trends estimate the future cost of electricity

.

Lifetime The total hours in operation after which the consumer retires the ballast or components o f a ballast system from service

.

Discount R ate The discount rate is the rate at which DOE discounts future expenditures t o establish their present value

. Analysis Period Analysis period is the time span ov er which DOE calculates the LCC

.

9.1 Energy Prices
For consumers of fluorescent lamp ballasts, DO E will survey residential, commercial, and industrial energy tariffs 15 as a means for establishing marginal electricity prices. DOE will
also use data from CBECS 16 conducted by EIA to estimate building energy use characteristics that affect electricity price s. If the tariff survey and EIA data demonstrate a large variability in electricity prices, DOE will conduct a sensitivity analysis to determine how high and low electricity price estimates might affect the economic feasibility of any amended energy

conser vation standards. DOE will use projections of national average energy prices for residential, commercial, and industrial consumers

— principally from EIA’s Annual Energy Outlook (AEO) from the most recent year available

— as input for future energy prices in i ts LCC analysis

.

Item 9

- 1 DOE welcomes input on the electricity prices to be used in this analysis

.

15 “Energy tariffs” are the rules for calculating energy bills. DOE contractors maintain a database of hundreds of tariffs that can be used to calculate incremental energy bill impacts from energy savings. See: http://tariffs.lbl.gov/

16 See: http://www.eia.doe.gov/emeu/cbecs/.33 9.2 Life

- Cycle Cost Discount Rates
The calculation of consumer LCC requires the use of an appropriate discount rate. DOE uses the discount rate to determine the prese nt value of lifetime operating expenses. For consumers of fluorescent lamp ballasts, DOE will derive the discount rates for commercial and industrial consumers by estimating the cost of capital of companies that purchase commercial equipment. The cost of c apital is commonly used to estimate the present value of cash flows to be derived from a typical company project or investment. Most companies use both debt and equity capital to fund investments, so the cost of capital is the weighted

- average cost of equi ty and debt financing. This corporate finance approach is referred to as the “weighted

- average cost of capital.” However, because the set of commercial or industrial companies purchasing fluorescent lamp ballasts may differ from those who purchase another product, such as distribution transformers, each rulemaking requires development of its own targeted discount

rates

.

Because a portion of fluorescent lamp ballasts are used in residential applications, DOE plans to derive the discount rates from estimate s of the “finance cost” to purchase residential products. The finance cost can be interpreted as: (1) the financial cost of any debt incurred to purchase products (principally interest charges on debt), or (2) the opportunity cost of any equity used to pur chase products (principally interest earnings on household equity). Much of the data DOE proposes to determine the cost of debt and equity comes from the Federal Reserve Board’s
triennial Survey of Consumer Finances

. 17

Item 9

- 2 DOE welcomes input on the planned app roaches for estimating discount rates for consumers of fluorescent lamp ballasts under consideration for standards

in this rulemaking

.

9.3 Installation, Maintenance, and Repair Costs
Typically, DOE takes into consideration any expected changes to installatio n, maintenance, and repair costs for products under consideration for standards in a rulemaking. Often, small incremental changes in product efficiency would incur little or no change in installation, maintenance, and repair costs over baseline products

. H owever, f or products with significant energy efficiency improvements over the baseline, there may be increased installation, maintenance, and repair costs, because such products are more likely to incorporate technologies that are not widely available or u tilized.

For fluorescent lamp ballasts, DOE intends to handle each of these costs in its LCC analysis as follows:

• Installation Costs. DOE does not expect that installation costs for fluorescent lamp ballasts will change with more energy

- efficient ballas t designs, as new regulations are not

17 Available at http://www.federalreserve.gov/pubs/oss/oss2/scfindex.htm34 expected to change either the ballast lifetime or the labor costs for installing a
standards

- compliant ballast.

• Maintenance Costs

. DOE expects that maintenance costs for fluorescent lamp ballasts could change with more energy

- efficient ballast designs. Because maintenance costs
include both the installation labor and product cost of replacement lamps that operate on any given ballast, it is possible that maintenance costs may change. DOE does not believe
that the labor costs of installing a fluorescent lamp will change with more

- efficient ballasts. Furthermore, DOE understands that more energy

- efficient ballasts would not significantly affect the useful lifetime ( i.e ., shorter or longer) of the lamps operated by
those ba llasts.

• Repair Costs

. DOE does not believe that fluorescent lamp ballasts are subject to being “repaired,” as ballasts are generally just replaced at the end of their useful life. For this reason, repair costs will not be part of the LCC analysis.

Item 9

- 3 DOE wel comes comment on how to develop installation, maintenance, and (if applicable) repair costs for fluorescent lamp ballasts. In particular, will fluorescent ballast energy conservation standards affect the useful lifetime of the ballasts and/or the fluoresce nt lamps operated by those ballasts? If the lamps operated by the more

- efficient ballasts would be affected, then DOE invites comments from interested parties on whether re

- lamping practices (i.e., group re

- lamping and spot re

- lamping) would change as a re sult of the
standard

.

9.4 Fluorescent Lamp Ballast Lifetime
Typically, DOE will use information from manufacturer product catalog s , various literature sources such as technical reports a nd conference proceedings, the 2000 Ballast Rule
and the 2011 Ballast Ru le, as well as input from manufacturers and other interested parties, to establish fluorescent lamp ballast lifetimes for use in the LCC and PBP subsequent analyses.

Based on consideration of the comments received for the p reliminary a nalysis, DOE will

m ake necessary changes to the analysis. These changes will be reflected in the documentation of
the NOPR.

Item 9

- 4 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for
the ballasts under consideration for standards in this rulemaking

.35 SECTION 10 SHIPMEN TS
DOE develops shipment projections of products in order to calculate the national impacts of standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments projections based on an analysis of key market drivers for fluorescent lamp
ballasts.

10.1 No

- New

- Standards Case Projections

To evaluate the various effects of standards, DOE will develop a no

- new

- standards case shipments projection against which to compare standards case shipment projections at higher
ELs (based on the CSLs). DOE will design the no

- new

- standards case projection to depict what would be anticipated to happen to energy consumption and energy costs over time if energy
conservation standards for the ballasts under consideration in this rulemaking are not adopted (i.e., the absence of any new or amended fluorescent lamp ballast standards) . In determining the

no

- new

- standards case projection, DOE will consider historical shipments, the mix of ballast efficiencies currently sold in the absence of regulati on, and how that mix might change over time. For these purposes, DOE requires data on historical product shipments and the market
shares of the different ELs offered in each product class.

DOE seeks data on historical shipments of fluorescent lamp ballas ts, from manufacturers or industry associations. DOE could base its shipments analysis on an extrapolation of historical sales data from the U.S. Census Bureau. The Census Bureau publishes limited information on the quantity and dollar value of fluorescent lamp ballast shipments; however, those shipments are not broken down by ballast type or product class. Also the Census data appears last collected
circa 2006. Alternatively, DOE could base its shipments analysis on an extrapolation of the shipments analys e s from the 2000 Ballast Rule and the 2011 Ballast Rule . The 2011 Ballast R ule projected in 2011 roughly 100 million total fluorescent lamp ballast s shipped and increased to 120 million ballasts shipped in 2014. The shipment model in the 2011 Ballast R ule had shipments of virtually all product classes increasing to the end of the 2011 Ballast R ule’s analysis period of 2045. DOE is also interested in comments from interested parties on efficiency
trends in the no

- new

- standards case ( i.e ., the trends of consu mers purchasing ballasts that use less energy or other purchasing behavior ) that would enable DOE to represent these market trends in its analysis.

DOE hopes to develop shipment data within each fluorescent lamp ballast product class,
as well as to under stand the breakdown of ELs within each product class ( i.e ., data on the
distribution of products ). However, DOE recognizes that this information may be difficult to collect, so DOE may ultimately need to consider other approaches, such as interviewing expe rts who work in the fluorescent lamp ballast market.36 Item 10

- 1 DOE welcomes recommendations on sources of data that would provide information on shipments of fluorescent lamp ballasts by product class. In addition, DOE welcomes comment or recommendations on how it might characterize long

- term trends in efficiency of fluorescent lamp ballasts for the

no

- new

- standards case shipments projection

.

10.2 Accounting Methodology
DOE plans to determine annual shipments in the no

- new

- standards case by accounting
for new ballast i nstallation, ballast replacements due to failure, and ballast retrofits. Each of these affect the accounting methodology as discussed below :

• New construction means the new ballasts that are installed each year due to product growth in a particular sector. DOE plans to determine a value for this input by using the National Energy Modeling System (NEMS) growth projections for the commercial and industrial equipment sectors.

• Replacements refer to the new ballasts that are installed each year to replace ballas ts that
have failed. DOE plans to base this calculation on product sales and retirement rates.

• Retrofits means the ballasts replacing existing ballasts during renovation. This retrofit

r eplacement may occur before the original ballast has failed.

DOE int ends to use an accounting model method to prepare shipment scenarios for the

no

- new

- standards case and the standards case. The model will keep track of the aging and replacement of fluorescent lamp ballasts given a projection of future ballast sales growth

.

Item 10

- 2 DOE welcomes comment on the accounting methodology described above for each of the fluorescent lamp ballasts under consideration for standards in this rulemaking

.

10.3 Standards Effects on Ballast Shipments
For each ballast type, DOE will develop a set of shipment projections for the ballasts
under consideration for standards for each set of efficiency st andards analyzed. It will use these
standards case projections to evaluate the effects of standards on ballast shipments. DOE derives
standards case projec tions using the same data sets as it used for the no

- new

- standards case projections. However, because the standards case projections take into account the increase in purchase price and the decrease in operating costs caused by standards, projected shipmen ts typically deviate from the no

- new

- standards case. The magnitude of the difference between the
standards case and no

- new

- standards case shipment projections depends on the estimated37 purchase price increase, as well as the operating cost savings from the standard. Because the purchase price tends to have a larger effect than operating cost on product purchase decisions,
standards case projections typically do show an elasticity of demand, manifested as a drop in shipments relative to the no

- new

- standards c ase.

Market

- pull programs, such as consumer rebate programs that encourage the purchase of

more efficient fluorescent lamp ballasts and manufacturer tax credits that encourage the production of more efficient fluorescent lamp ballasts, also affect standa rds case shipment projections. To the extent that such programs exist, DOE will consider their effect on the projection of both standards case and no

- new

- standards case shipments

.

Item 10

- 3 DOE welcomes comment on how any potential new or amended energy

conservatio n standards for fluorescent lamp ballasts might affect shipments of these ballasts. DOE also invites information about market

- pull programs that currently exist to promote the adoption of more

- efficient ballasts

.

SECTION 11 NATIONAL IMPACT ANAL YSIS

The NIA discusse s DOE’s assessment of the aggregate impacts of potential efficiency standards at the national level. DOE will report include future NES from CSLs ( i.e. , the cumulative incremental energy savings from a new or increased energy conservation standard
relative to a no

- new

- standards case of no change in the energy conservation national standard over a specified period) and the NPV from CSLs ( i.e.

, the cumulative incremental LCC from a new or increased energy conservation state relative to the no

- new

- standards ca se over a specified projection period).

11.1 Inputs to Projection s Analyzing effects of f ederal energy conservation standards for fluorescent lamp ballasts requires a comparison of projected energy consumption in the United States with, and without,

new energ y conservation standards. The projections contain estimates of unit energy consumption of new ballasts, annual product shipments, the price of purchased products , and
base and standards case efficiencies. The derivations of the base shipments projections a re discussed in Section 10 . Approaches to determine retail prices for products are described in
Section 8 , while approaches to determine unit energy consumption are described in Section 7

.

The rebound effect, another input to the NIA, is discussed in this section. C onsumers that encounter lower operating costs associated with a more energy

- efficient product may use that product more often than a less eff icient product. The rebound effect analysis accounts for this increase in consumer use. Some of the major inputs DOE is anticipating it will develop for the
NIA are described in Table 11

. 1

.38 Table 11

. 1 Inputs to the National Impact Analysis

Input Data Description of Data Sources

Shipments Annual shipments developed in Section 10

Stock of Fluorescent Lamp Ballasts This stock is calculated f rom the service life of ballasts developed in
Section 9 and annual shipments from ballasts developed in Section 10

Effective Date of Potential Standard 20 22
Analysis Period 20 22 to 20 51 (30 years)

No

- New

- Standards Case Project ed Efficiency Distribution of base shipments by efficiency level o ver time developed
in Section 9

Standards Case Projected Efficiency Distribution of shipments by efficiency level fo r each standards case
over time

Unit Energy Consumption (kWh/yr) This is the average energy consumption of a fluorescent lamp ballast established in the energy

- use and end

- use load analysis

, Section 7

Total Installed Cost Established in the Markups Analysis

, Section 8 and the LCC analysis,
Section 9
Electricity Price Projection Established in the Life

- Cycle Cost Analysis, Section 9

Elec tricity Site

- to

- Source Conversion Conversion varies yearly and is generated by EIA A EO projection s of electricity generation and electricity related losses
Heating, Ventilating, and Air

Conditioning (HVAC) Interaction Savings Accounts for the additional energy saved through HVAC interactions. The methodology will be similar to that used in the 2000 Ballast Rule
and the 2011 Ballast Rule

Discount Rate The discount rate is the rate at which DOE discounts future expenditures to establish their present value

. 3 and 7 perc ent discount
rates will be used

Present Year Future costs and savings will be discounted to the year 2015

Rebound Effect The difference between the projected and actual savi ngs due to increased efficiency

Item 11

- 1 DOE welcomes comment on the data sources it anticipates using to develop inputs for the national impact analysis

.

11.2 Calculation of National Energy Savings
DOE intends to calculate national energy consumption for each year beginning with the expected effective date of the potential standar ds. It will calculate national electricity consumption for the no

- new

- standards case and each standard level analyzed. DOE plans to perform this calculation through the use of a spreadsheet model that effectively multiplies annual shipment projections by u nit energy savings, thereby accounting for the stock of products affected by standards.

In response to comments by interested parties who asked for a simple, transparent model, DOE developed NES spreadsheet models for its standards rulemakings starting i n 1996, to39 project energy savings and to demonstrate how the growth in efficiency can be accounted for over time. Although these models are specific to each product, their general framework is applicable to the entire fluorescent lamp ballast market. It is DOE’s expectation that the NES spreadsheet model will provide a stand

- alone forecast of national energy savings and NPV for fluorescent lamp ballasts. Based on consideration of comments DOE may receive on the

p reliminary a nalysis, DOE will make any necess ary changes to the analysis. It will reflect those changes in the documentation for the NOPR

.

Item 11

- 2 DOE welcomes comment on the NES spreadsheet models it plans to use for estimating national impacts of energy conservation standards for fluorescent lamp ballasts

.

11.3 Net Present Value
DOE calculates the national NPV of energy conservation standards in conjunction with the NES. It calculates annual energy expenditures from annual energy consumption by incorporating projected energy prices, using the shipment and ave rage energy

- efficiency projection s described in Section 10 . DOE calculates annual product expenditures by multiplying the price per unit by the projected shipments. The difference between a no

- new

- standards case and a standards case scenario gives the national energy bill savings and increased product expenditure in dollars, and for the fluorescent lamp ballasts rulemaking, this differential will likely result in an NES offset against increased expenditures on ba llasts. The difference each year between energy bill savings and increased product expenditures is the net savings (if positive) or net costs (if negative). DOE will discount these annual values to the present time and sum them to provide a NPV . Because th e national cost of capital may differ from the consumer cost of capital, the discount rate used in the NIA can be different from that used in the LCC. According to U.S. Office of Management and Budget (OMB) guidance, DOE will conduct two NPV calculations, one using a real discount rate of 3 percent and another using a real discount
rate of 7 percent

. 18 The 7

- percent and 3

- percent real discount rates are considered to be representative of the present value of costs and benefits associated with projects in the marketplace facing an average degree of risk. Specifically, the 7

- percent real value is an estimate of the average before

- tax rate of return to private capital in the U.S. economy. The 3

- percent real value represents the “societal rate of time preference, ” which is the rate at which society discounts future consumption flows to their present value. Based on consideration of the
comments received on the p reliminary a nalysis, DOE will make any necessary changes to the analysis and the CSLs

.

SECTION 12 CONSUMER SUBGROU P ANALYSIS
At the NOPR stage of this rulemaking, DOE will conduct a consumer subgroup analysis. In this analysis, DOE analyzes consumer effects by dividing consumers into subgroups and

18 OMB, Circ ular A

- 4: Regulatory Analysis, September 17, 200340 accounting for variations in key inputs to the LCC analysis. The LCC a nd PBP analysis
described in Section 9 investigates the effects of energy conservation standards on all users of fluorescent lamp ballasts. For the consumer subgroup analysis, DOE divides users into subgroups, which comprise a subset of the population that is likely to be affected disproportionately by new or revised energy conservation standards ( e.g ., small businesses, ethnic minorities, low

- income populations, or senior consumers). In comparing potential effects
on the differ ent consumer subgroups, DOE will evaluate variations in regional electricity prices, variations in usage profiles, and variations in installation costs that might affect the consumer subgroups.

The purpose of a subgroup analysis is to determine the exten t of any such disproportional
effect

. In the 2011 Ballast R ule, DOE analyzed low

- income consumers, institutions of religious worship, and institutions that serve low

- income populations. DOE will work with interested parties early in the rulemaking process to identify any subgroups for this consideration.

Item 12

- 1 DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fluorescent lamp ballasts

.

SECTION 13 MANUFACTURER IMPACT ANALYSIS
The manufacturer impact analysis will assess the potential impacts of energy conservation standards on manufacturers of fluorescent lamp b a llasts. A wide range of quantitative and qualitative effects may occur following the adoption of standards that may require changes to manufacturing practices. DO E will identify these potential effects through interviews with manufacturers and other experts.

For the NOPR, DOE will conduct an industry

- wide cash

- flow analysis using the Government Regulatory Impact Model (GRIM), identify and analyze subgroups of

man ufacturers whose businesses vary significantly from the industry as a whole, perform a competitive impacts assessment, and review the cumulative regulatory burden for the industry.

13.1 Sources of Information
Many of the analyses described earlier provide imp ortant information that DOE uses as inputs for the MIA. Such information includes financial parameters developed in the market assessment (see section 4.1 ), cost data developed in the e ngineering analysis (see Section 6 ), and shipment projections (see Section 10 ). DOE supplements this data with information gathered during manufacturer interviews. The interview process will play a key role i n the MIA, as it provides an opportunity for interested parties to express their views on important issues.

DOE will conduct detailed interviews with manufacturers to gain insight into the range of potential impacts of standards. During the interviews, D OE will solicit information on the possible impacts of standards on manufacturing costs, product prices, sales, direct employment,41 capital assets, and industry competitiveness. Both qualitative and quantitative information are
valuable. DOE will schedule i nterviews well in advance to provide every opportunity for key individuals to be available. Although a written response to the questionnaire is acceptable, DOE prefers an interactive interview process because it helps clarify responses and provides the

opp ortunity for additional issues to be identified.

DOE will ask that interview participants identify all confidential information provided, both in writing and orally. While it will consider information gathered, as appropriate, in its
decision

- making proc ess, DOE will protect confidential information from disclosure consistent with applicable law.

DOE will collate the information from interviews and prepare a summary of the major issues and outcomes. This summary will become part of the TSD produced for this rulemaking.

13.2 Industry Cash

- Flow Analysis
The industry cash

- flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of more

- stringent energy conservation standards on the industry that manufacturers the products under consideration for standards

.

The GRIM analysis uses a number of factors

— annual expected revenues; costs of goods sold; selling, general, and administrative costs; taxes; and capital expenditures

— to arrive at a series of annual cash flows beginning from the announcement of the standard and continuing through the end of the analysis period. DOE compares the results against no

- new

- standards case projections that involve no amended standards. The financial impact of amended standards is
then the differe nce between the two sets of discounted annual cash flows. Other performance metrics, such as return on invested capital, also are available from the GRIM.

DOE will gather inputs needed for the GRIM from three primary sources: (1) relevant
information for publicly available sources, such as the financial reports of publicly traded companies, (2) the analyses conducted to this point; and (3) interviews with manufacturers and
other stakeholders. Information gathered from previous analyses will include financ ial parameters, manufacturing costs, price projections, and shipments projections. Interviews with manufacturers and other stakeholders will supplement this information

.

13.3 Manufacturer Subgroup Analysis
Average industry cost values may not reveal different ial impacts among fluorescent lamp ballast manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs significantly from the industry average may be affected differently by amended standards. Id eally, DOE would consider the impact on every firm individually. In highly concentrated industries, this may be possible. However, for industries that have numerous participants, DOE will use the results of the market and technology assessment to

group man ufacturers into subgroups, as appropriate. For fluorescent lamp ballasts, DOE is interested in feedback about potential subgroups, including small businesses. DOE will conduct a Regulatory Flexibility Act analysis, as part of the NOPR, to determine impacts of any amended standards on small businesses consistent with the Regulatory Flexibility Act

.42 Item 13

- 1 DOE seeks comments on any potential subgroups of fluorescent lamp ballast manufacturers that it should consider in a manufacturer subgroup analysis

.

Item 13

- 2 DOE seeks co mment on the number of small businesses and any specific small businesses that could be impacted by energy conservation standards for fluorescent lamp ballasts, and what those impacts might entail

.

SECTION 14 UTILITY IMPACT ANALY SIS
To estimate the effects of energ y conservation standards for fluorescent lamp ballasts on the electric utility industry, DOE plans to use a variant of EIA’s NEMS, called NEMS

- BT. 19 NEMS is a large, multi

- sectoral partial equilibrium model of the U.S. energy sector, used primarily for the purpose of preparing EIA’s AEO . NEMS produces a widely recognized reference case projection for the United States through 2040 and is available in the public
domain.

The effect of reducing site energy use is modeled by making NEMS runs that deviate
from the most recent AEO r eference case. Each year, DOE develops response coefficients using
NEMS

- BT that give changes in capacity and generation by fuel type for a given quantity of site energy use reduction to a particular energy end use. DOE develops respons e coefficients for several different energy end uses. To model the effect of this potential standard on the electric utilities industries, the response coefficients will be weighted by end use, and then they will be applied to the site energy savings for f luorescent lamp ballasts that are generated from the NIA analysis.

Item 14

- 1 DOE welcomes input from interested parties on its plans to use NEMS

- BT to conduct the utility impact analysis

.

SECTION 15 EMPLOYMENT IMPACT AN ALYSIS
The employment impact analysis examines indirect employment impacts from standards, which consist of the net jobs created or eliminated in the national economy, other than in the

19 For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information Administration documentation. EIA approves of the name NEMS to describe only an official version of the mode l without any modifications to code or data. Because this analysis entails some minor code modifications and the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model by the
name NEMS

- BT (“BT” refers to DOE’s Building Technologies Office, under whose aegis this work has been performed).43 manufacturing se ctor being regulated, caused by (1) reduced spending by end users on energy

, (2) reduced spending on new ener gy supply by the utility industry, (3) increased spending on

new products t o which the potential standards apply, and (4) the effects of those three factors throughout the economy. 20

During the NOPR stage of the fluorescent lamp ballast rulemaking, DOE wi ll estimate the effects of standards on employment for product manufacturers, relevant service industries, energy suppliers, and the economy in general. Its analysis covers both direct and indirect employment impacts. Direct employment effects would result if standards led to a change in the number of employees at manufacturing plants and related supply and service firms. Direct impact estimates are covered in the manufacturer impact analysis.

DOE defines indirect employment effects from standards as net jobs eliminated or created in the general economy as a result of increased spending driven by the increased product prices and reduced spending on energy. Indirect employment effects focus on the national economy other than in the manufacturing sector bein g regulated. Indirect effects may result both from expenditures shifting among goods (the substitution effect) and from changes in income that lead to a change in overall expenditure levels (the income effect).

One method for assessing the possible effec ts on the demand for labor of such shifts in economic activity is to compare sector empl oyment statistics developed by the Labor Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the number of jobs per million doll ars of economic activity in different sectors of the economy, as well as the jobs created elsewhere in the economy by this same economic activity. Data from BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and indirectly) than expenditures in other sectors of the economy. 21 There are many reasons for these differences, including wage differences and the fact that the utility sector is more capital

intensive and less labor

- intensive than other sectors. Energy con servation standards have the effect of reducing consumer utility bills. Because reduced consumer expenditures for energy likely lead to increased expenditures in other sectors of the economy, the general effect of efficiency standards is to shift economic activity from a less labor

- intensive sector ( i.e. , the utility sector) to more labor

- intensive sectors ( e.g. , the retail and service sectors).

As part of its NOPR analyses , DOE plans to estimate indirect national employment
effects using an input/output model of the U.S. economy called Impact of Sector Energy Technologies version 3.1.1 (ImSET). 22 ImSET is a special

- purpose version of the “U.S. Benchmark National Input

- Output” (I

– O) model, which was designed to estimate the national employment and income ef fects of energy

- saving technologies. The ImSET software includes a

20 Direct employment impacts are any changes in the number of employees of manufacturers of the equipment subject to standards, their suppliers, and related service firms. The MIA will address effects on the number of employees working for the manufacturers.

21 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input

- Output Modeling System (RIMS II) . 1992. Washington, DC. U.S. Department of Commerce.

22 Scott MJ, OV Livingston, JM Roop, RW Schultz, and PJ Balducci. 2009. Imset 3.1: Impact of Sector Energy Technologies Model Description and User’s Guide. PNNL

- 18412, Pacific Northwest National Laboratory, Richland, W A

. Available at: www.pnl.gov/main/publications/external/technical_reports/PNNL

- 18412.pdf44 computer

- based I

– O model having structural coefficients that characterize economic flows among 187 sectors most relevant to industrial, commercial, and residential building energy use.

DO E notes that ImSET is not a general equilibrium forecasting model and understands the uncertainties involved in projecting employment impacts, especially changes in the later years of the analysis. Because ImSET does not incorporate price changes, the empl oyment effects predicted by ImSET may over

- estimate actual job effec ts over the long run. DOE may consider the use of other modeling approaches for examining long

- run employment impacts

.

Item 15

- 1 DOE welcomes feedback on its planned approach for assessing national employment impacts, both direct and indirect

.

SECTION 16 EMISSIONS ANALYSIS
In the emissions analysis, DOE will estimate the reduction in power sector emissions of carbon dioxide (CO 2 ), nitrogen oxides (NO X ), sulfur dioxide (SO 2 )

, and mercury (Hg) from potential e nergy conservation standards for the considered product . In addition, DOE will
estimate emissions effects in production activities (extracting, processing, and transporting fuels) that provide the energy inputs to power plants. These are referred to as “up stream” emissions. Together, these emissions account for the full

- fuel

- cycle (FFC). In accordance with DOE’s FFC Statement of Policy (76 FR 51281), the FFC analysis includes impacts on emissions of methane and nitrous oxide, both of which are recognized as greenhouse gases (GHGs)

.

DOE conducts the emissions analysis using emissions factors derived from data in the
latest version of EIA’s AEO , supplemented by data from other sources. EIA pr epares the AEO using NEMS. Each annual version of NEMS incorporates the projected impacts of existing air quality regulations on emissions. The text below refers to AEO2014

, which generally represents current legislation and environmental regulations, including recent government actions, for which implementing regulations were available as of December 31, 201 3

. DOE intends to perform the emissions analysis using the most current AEO (at the time of the analysis).

Because the on

- site operation of fluorescent lamp ballasts may require the use of fossil
fuels and may result in emissions of CO 2 , NO X , and SO 2 at the sites where these product s are used, DOE will also account for the reduction in these site emissions and the associated upstream
emissions because of potential standards.

SO 2 emissions from affected electric gene rating units (EGUs) are subject to nationwide and regional emissions cap and trading programs. Title IV of the Clean Air Act sets an annual emissions cap on SO 2 for affected EGUs in the 48 contiguous states and the District of Columbia

. SO 2 emissions from 28 eastern states and D.C. were also limited under the Clean Air Interstate Rule (CAIR), which created an allowance

- based trading program that operates along with the Title IV program in those s tates and D.C. 70 FR 25162 (May 12, 2005). CAIR was remanded t o EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), but it45 remained in effect. See North Carolina v. EPA , 550 F.3d 1176 (D.C. Cir. 2008); North Carolina
v. EPA , 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2011

, EPA issued a replacement for CAIR,
the Cross

- State Air Pollution R ule (CSAPR). 76 FR 48208 (Aug. 8, 2011). On August 21, 2012,
the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City Generation, LP v.
EPA

, 696 F.3d 7, 38 (D.C. Cir. 2012). The court ord ered EPA to continue administering CAIR.
AEO2014 assumes that CAIR remains a binding regulation through 2040

. 23

The attainment of emissions caps is typically flexible among EGUs and is enforced through the use of emissions allowances and tradable permits. Under existing EPA regulations, any excess SO 2 emissions allowances resulting from the lower electricity demand caused by the adoption of an efficiency standard could be used to permit offsetting increases in SO 2 emissions by any regulated EGU. In past ru lemaking efforts, DOE recognized that there was uncertainty about the effects of efficiency standards on SO 2 emissions covered by the existing cap

- and

- trade system, but it concluded that no reductions in power sector emissions would occur for SO 2 as a

resu lt of standards.

Beginning in 201 6 , however, SO 2 emissions will fall as a result of the Mercury and Air Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 2011. 77 FR 9304 (Feb

. 16, 2012). In the final MATS rule, EPA es tablished a standard for hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAP s ), and also
established a standard for SO 2 (a non

- HAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP s . The same controls are us ed to reduce HAP s and non

- HAP acid gas; thus, SO 2 emissions will be reduced as a result of the control technologies installed on coal

- fired power plants to comply with the MATS requirements for acid gas. AEO2014 assumes that, in order to continue operating , coal plants must have either flue gas desulfurization or dry sorbent injection systems installed by 201 6 . Both technologies, which are used to reduce acid gas emissions, also reduce SO 2 emissions. Under the MATS, e missions will be far below the cap that would be established by CSAPR, so it is unlikely that excess SO 2 emissions allowances resulting from the lower electricity demand would be needed or used to permit offsetting increases in SO 2 emissions by any regulated EGU. Therefore, DOE believes that eff iciency standards will reduce
SO 2 emissions in 2015 and beyond.

CAIR established a cap on NO X emissions in eastern s tates and the District of Columbia.
S tandards are expected to have little or no physical effe ct on these emissions in those s tates covered by CAIR because excess NO X emissions allowances resulting from the lower electricity demand could be used to permit offsetting increases in NO X emissions. However, standards would be expected to reduce NO X emissions in the s tates not affected by the caps, so DOE

23 On April 29, 2014, the U.S. Supreme Court reversed the judgment of the D.C. Circuit. The case wi ll now return to the D.C. Circuit for further proceedings consistent with the Supreme Court's opinion. The Supreme Court held in part that EPA's methodology for quantifying emissions that must be eliminated in certain states due to their impacts
in other d ownwind states was based on a permissible, workable, and equitable interpretation of the Clean Air Act provision that provides statutory authority for CSAPR. See EPA v. EME Homer City Generation, Slip. Op. No 12

- 1182, *32 s lip o p. at 32 ( U.S. April 29, 201 4). B ecause DOE would be using emissions factors based on AEO201 4 for the NOPR phase of this rulemaking, this document assumes that CAIR, not CSAPR, is the regulation in force. The difference between CAIR and CSAPR is not relevant for the purpose of DOE's analysis of SO 2 emissions.46 estimates NO X emissions reductions f rom potential standards in the s tates where emissions are not capped.

The MATS limit mercury emissions from power plants, but they do not include emissions caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. DOE
will estimate merc ury emissions reduction using em issions factors based on AEO2014 , which incorporates the MATS.

Power plants may emit particulates from the smoke stack, which are known as direct particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power plants. DOE is investigating the possibility of using other methods to estimate reduction in PM emissions due to standards. The great majority of ambient PM associated with power plan ts is in the form of secondary sulfates and nitrates, which are produced at a significant distance from power plants by complex atmospheric chemical reactions that often involve the gaseous emissions of power plants, mainly SO 2 and NO X . The monetary benefi ts that DOE estimates for
reductions in SO 2 and NO X emissions resulting from standards are in fact primarily related to the
health benefits of reduced ambient PM

.

Item 16

- 1 DOE seeks comment about its approach to conduct the emissions analysis for the products that would be under consideration for standards in this rulemaking

.

SECTION 17 MONETIZING CARBON DI OXIDE AND OTHER EMIS SIONS
DOE plans to consider the estimated monetary benefits likely to result from the reduced
emissions of CO 2 and NO X that are expected to result fro m each of the standard levels
considered.

To estimate the monetary value of benefits resulting from reduced emissions of CO 2 , DOE plans to use the most current social cost of carbon (SCC) values developed and/or agreed to by an interagency process. The S CC is intended to be a monetary measure of the incremental damage resulting from GHG emissions, including , but not limited to, net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of sc ience, economics, and ethics. However, with full regard for the limits of both quantification and monetization, the SCC can be used to provid e estimates
of the social benefits of reductions in GHG emissions.47 The Interagency Working Group on Social Cost of Carbon released an update of its previous report in 2013. 24 The most recent estimates of the SCC in 2015, expressed in 201 4 $, are $ 12.2 , $ 41 .2 , $ 63.4 , and $ 121 per metric ton of CO 2 avoided. For emissions reductions that occur in later years, these values grow in real terms over time. Additionally, the interagency group
determine d that a range of values from 7 percent to 23 percent should be u sed to adjust the global SCC to calculate domestic effects, although DOE will give preference to consideration of the global benefits of reducing CO 2 emissions.

DOE multiplies the CO 2 emissions reduction estimated for each year by the SCC value
for that year in each of the four cases. To calculate a present value of the stream of monetary values, DOE discounts the values in each of the four cases using the discount rates that had been
used to obtain the SCC values in each case.

DOE recognizes that scien tific and economic knowledge continues to evolve rapidly as to
the contribution of CO 2 and other GHG to changes in the future global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.

DOE also esti mates the potential monetary benefit of reduced NO
x emissions resulting
from the standard levels it considers. For NO
x emissions, DOE used estimates developed by EPA
for 2016, 2020, 2025, and 2030. 25 The values reflect estimated mortality and morbidity per ton of directly emitted NO X reduced by e lectricity generating u nits . The values in 2016 are $5,562/ton using a 3

- percent discount rate and $4,920/ton using a 7

- percent discount rate (2014$). DOE is evaluating the appropriate valuation of avoided SO 2 and Hg emissions. Whether
monetization of reduced SO 2 and Hg emissions will occur as part of any proposed rule that DOE
issues for fluorescent lamp ballasts is yet to be determined.

Item 17

- 1 DOE requests comment about the approach it plans to use for estimating
monetary benefits associated with emissions reductions

.

SECTION 18 REGULATORY IMPACT AN ALYSIS
If DOE issues a proposal to amend standards for fluorescent lamp ballasts, it will prepare a regulat ory impact analysis to address the potential for non

- regulatory approaches to s upplant or augment energy conservation standards to improve the efficiency of fluorescent lamp ballasts. DOE recognizes that voluntary or other non

- regulatory efforts by manufacturers, utilities, and other interested parties can result in substantial impro vements in efficiency. DOE intends to analyze the likely effects of non

- regulatory initiatives on product energy use, consumer utility, and LCC. DOE will attempt to base its assessments on the effects of any such initiatives to date,

24 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866

. Interagency Working Group on Social Cost of Carbon, United States Government, May 2013; revised November
2013. www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf

25 http://www2.epa.gov/benmap/sector

- based

- pm25

- benefit

- ton

- estimates48 but will also consider information presented regarding the effects that an initiative might have in
the future.

The regulatory impact analysis will consider the likely effects of non

- regulatory initiatives on ballast energy use, consumer utility, and life

- cycle costs. DOE wil l take into account the actual impacts of any existing initiatives to date, but also will consider historical information presented that may reasonably estimate the effects that any such initiative might have in the future. DOE will use the NES spreadsheet model (as discussed in Section 11

, “Calculation of National Energy Savings”) to calculate the NES and NPV for the alternatives to the potential conservation standards under consideration.

If DOE proposes ener gy conservation standards for fluorescent lamp ballasts, and the
NOPR constitutes a significant regulatory action as defined under section 3(f) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993), DOE will prepare
and sub mit to OMB for review the assessment of costs and benefits required under section 6(a)(3) of the order

.49 APPENDIX A

– LIST O F ITEMS F OR COMMENT
This appendix lists all the items for comment contained in this Fluorescent Lamp Ballast
Framework d ocument, and the page numbers on which those items for comment can be found

.

Item 2

- 1 DOE welcomes comment on the current test procedures and whether or not
amendments are needed.

................................ ................................ ................................ ................. 9

Item 2

- 2 DOE welcomes comment on which ballasts are capable of operating in standby mode and any other information relating to standby mode energy use.

................................ ................. 10

Item 2

- 3 DOE welcomes comment on the metrics used for establishing energy conservation standards for active mode and standby mode energy use.

................................ ............................ 11

Item 3

- 1 DOE welcomes comment on the feasibility and justification for setting standards for additional dimming fluorescent lamp ballasts. In particular, DOE requests market and shipm ent information as well as information regarding the potential for efficiency improvements and energy savings.

................................ ................................ ................................ .............................. 13

Item 3

- 2 DOE we lcomes comment on the current exclusion from standards for T8 MBP PS fluorescent lamp ballasts with an output less than 140 mA per lamp and welcomes any relevant shipment information for these products.

................................ ................................ ..................... 14

Item 3

- 3 DOE welcomes comment on whether standards for fluorescent lamp ballasts that operate at input voltages other than at or between 120 and 277 V would save significant energ y and be technologically feasible and economically justified. In particular, DOE requests market and shipment information as well as information regarding the potential for efficiency improvements and energy savings.

................................ ................................ ............................... 14

Item 3

- 4 DOE welcomes comment on any additional fluorescent lamp ballasts that should be considered for standards. In particular, DOE requests market and shipment in formation as well as information regarding the potential for efficiency improvements and energy savings.

........... 14

Item 3

- 5 DOE welcomes comment, including shipment information, on the plan to not amend the current exclusion from standards for low frequency T8 fluorescent lamp ballasts for EMI

sensitive locations.

................................ ................................ ................................ ........................ 15

Item 4

- 1 DOE welcomes information on shipments, product

- feature and efficiency trends, distribution channels, and estimates of market shares for ballasts considered in this rulemaking.
For th e data to be used to conduct energy savings calculations, please provide appropriate groupings (e.g., by existing product class, technology, and/or other relevant performance characteristics).

................................ ................................ ................................ ............................. 16

Item 4

- 2 DOE welcomes comment on the product class divisions it is considering for fluorescent lamp ballasts. In particular, DOE welcomes comment on appropriate class

- setting
factors for di mming ballasts, low ballast factor PS ballasts, and 480 V fluorescent lamp ballasts.

.

................................ ................................ ................................ ................................ .... 18

Item 4

- 3 DOE welcomes comment on any other class

- setting factors that should be considered in the analysis.

................................ ................................ ................................ ............................... 18

Item 4

- 4 DOE welcomes comme nt on the preliminary technology options identified in this section. DOE welcomes comment on whether there are additional technology options that it
should consider.

................................ ................................ ................................ ............................ 2050 Item 5

- 1 DOE welcomes comment on the applicability of the four screening criteria to the technology options described in this section, including whether it is still appropriate to scr een out the use of laminated sheets of amorphous steel to create the core of the inductor.

...................... 21

Item 5

- 2 DOE welcomes comment on ho w the four screening criteria would apply to any additional technology option(s) that an interested party recommends to DOE.

........................... 21

Item 6

- 1 DOE welcomes comment on the appropriate baseline for ballasts already subject to energy conservation standards.

................................ ................................ ................................ ..... 22

Item 6

- 2 If DOE analyzes standards for new categories of ballasts, including additional dimming, low ballast factor PS, or 480 V fluorescent lamp ballasts, DOE welcomes comment on the appropriate baseline ballast types and efficiency value in those categories.

.......................... 22

Item 6

- 3 DOE welcomes comment on the methodology it is considering to select higher

efficiency ballast designs.

................................ ................................ ................................ ............. 23

Item 6

- 4 DOE welcomes comment on its proposed methodology of establishing efficiency levels, including the form of an equation that relates average total lamp arc power to BLE.

...... 23

Item 6

- 5 DOE welcomes comment on the use of compliance data and verification test ing data when establishing efficiency levels.

................................ ................................ ............................. 23

Item 6

- 6 DOE welcomes comment on the pricing methodology, and in particular the f easibility of using product teardowns to develop pricing.

................................ ................................ ............ 24

Item 6

- 7 DOE welcomes comments on the methodology to scale energy con servation standards to product classes not directly analyzed.

................................ ................................ ...... 24

Item 6

- 8 DOE welcomes comments on proprietary designs it should be aware of for the fluorescent lamp ballasts that are the subject of this rulemaking.

................................ ................ 25

Item 6

- 9 DOE welcomes comments on regulatory burdens or changes that should be considered in the engineering analysis.

................................ ................................ ........................ 25

Item 6

- 10 DOE welcomes comments on other issues that could affect the engineering analysis.

.

................................ ................................ ................................ ................................ .... 25

Item 7

- 1 DOE welcomes comment on the approach DOE is taking to determine the operating hours profile for fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment on
whether the end

- use operating profiles are different for the various types of fluorescent lamp ballasts under consideration for standards in this rulemaking, and if so, how.

............................ 26

Item 7

- 2 DOE welcomes comment on the wattage of reduced

- wattage fluorescent lamps typically installed as well as what proportion of reduced

- wattage lamps are installed. DOE also welcomes comments on the prevalence of tubular LEDs operating on fluorescent lamp ballasts.

..

................................ ................................ ................................ ................................ .... 27

Item 7

- 3 DOE welcomes comment on the typical space types operated by occupancy sensors. DOE also welcomes any data on the energy savi ngs related to the use of occupancy sensors. DOE welcomes data on the portion of fluorescent ballasts used with occupancy sensors. DOE welcomes any data on the effects of occupancy sensor use on the operating hours profile for fluorescent lamp ballasts in this rule.

................................ ................................ ............................ 27

Item 7

- 4 DOE welcomes comment on the use of the dimming ballasts: types of ballasts and lamps typically dimmed; app lications in which dimming occurs; output setting of the dimmed51 ballasts when in use; typical energy savings for dimming ballasts; and market share of dimming
ballasts in use.

................................ ................................ ................................ ............................... 28

Item 7

- 5 DOE welcomes comment on the use of the operating hours profile for fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment on whether the end

- use operating profiles are different f or the various types of fluorescent lamp ballasts under consideration for standards in this rulemaking, and if so, how.

................................ ................... 28

Item 7

- 6 DOE welcomes comment on any data sources to use to calculate the operating hours of fluorescent ballasts and energy savings related to the use of dimming fluorescent ballasts.

... 28

Item 8

- 1 DOE seeks comment on the distribution channels and the share of industry shipments for each distribution channel described in this document as it applies to the fluorescent l amp ballasts under consideration for standards in this rulemaking.

................................ ..................... 30

Item 9

- 1 DOE welcomes input on the electricity prices to be used in this analysis.

................ 32

Item 9

- 2 DOE welcomes input on the planned approaches for estimating discount rates for
consumers of fl uorescent lamp ballasts under consideration for standards in this rulemaking.

... 33

Item 9

- 3 DOE welcomes comment on how to develop i nstallation, maintenance, and (if applicable) repair costs for fluorescent lamp ballasts. In particular, will fluorescent ballast energy conservation standards affect the useful lifetime of the ballasts and/or the fluorescent lamps operated by those ballas ts? If the lamps operated by the more

- efficient ballasts would be affected, then DOE invites comments from interested parties on whether re

- lamping practices (i.e., group re

- lamping and spot re

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

.............. 34

Item 9

- 4 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for the
ballasts under consideration for standards in this rulemaking.

................................ ..................... 34

Item 10

- 1 DOE welcomes recommendations on sources of data that would provide information on shipments of fl uorescent lamp ballasts by product class. In addition, DOE welcomes comment or recommendations on how it might characterize long

- term trends in efficiency of fluorescent lamp ballasts for the no

- new

- standards case shipments projection.

................................ ............. 36

Item 10

- 2 DOE welcomes comment on the accounting methodology described above for each of the fluorescent lamp ballasts under consideration for stan dards in this rulemaking.

............... 36

Item 10

- 3 DOE welcomes comment on how any potential new or amended energy conservation
standards for fluorescent lamp ballasts might affect shipments of these ballasts. DOE also invites
information about market

- pull programs that currently exist to promote the adoption of more

efficient ballasts.

................................ ................................ ................................ ........................... 37

Item 11

- 1 DOE welcomes comment on the data sources it anticipates using to develop inputs for the national impact analysis.

................................ ................................ ................................ ... 38

Item 11

- 2 DOE welcomes comment on the NES spreadsheet models it plans to use for estimating national impacts of energy conservation standards for fluorescent lamp ballasts.

..... 39

Item 12

- 1 DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fluorescent lamp ba llasts.

................................ ................................ .... 40

Item 13

- 1 DOE seeks comments on any potential subgroups of fluorescent lamp ballast
manufacturers that it should consid er in a manufacturer subgroup analysis.

............................... 4252 Item 13

- 2 DOE seeks comment on the number of small businesses and any specific small
bu sinesses that could be impacted by energy conservation standards for fluorescent lamp ballasts, and what those impacts might entail.

................................ ................................ .............. 42

Item 14

- 1 DOE welcomes input from interested parties on its plans to use NEMS

- BT to conduct the utility impact analysis.

................................ ................................ ................................ ............ 42

Item 15

- 1 DOE welcomes feedback on its planned approach for assessing national employment impacts, both direct and indirect.

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Item 16

- 1 DOE seeks comment about its approach to conduct the emissions analysis for the products that would be under consideration for standards in this rulemaking.

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Item 17

- 1 DOE requests comment about the approach it plans to use for estimating monetary
benefits associated with emissions reductions.

................................ ................................ ............. 47