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 Technologies Program

June 9, 2015
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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 ASSESSMENT.......................................... 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 PAYBACK PERIOD ANALYSIS ....................... 30

9.1 Energy Prices.............................................................................................................. 32

9.2 Life-Cycle Cost Discount Rates.................................................................................. 33

9.3 Installation, Maintenance, and Repair Costs............................................................... 33
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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 ANALYSIS.................................................................. 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 ANALYSIS .......................................................... 39

SECTION 13 MANUFACTURER IMPACT ANALYSIS...................................................... 40

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

13.2 Industry Cash-Flow Analysis...................................................................................... 41

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

SECTION 14 UTILITY IMPACT ANALYSIS....................................................................... 42

SECTION 15 EMPLOYMENT IMPACT ANALYSIS........................................................... 42

SECTION 16 EMISSIONS ANALYSIS.................................................................................. 44

SECTION 17 MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS................. 46

SECTION 18 REGULATORY IMPACT ANALYSIS............................................................ 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 Operating 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.............. 29
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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

CBECS 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 Electric 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 Government Regulatory Impact Model

GSFL General service fluorescent lamp

HAP Hazardous air pollutants

HVAC Heating, ventilating, and air conditioning

LCC Life-cycle cost

LMC Lighting Market Characterization

LED light-emitting diode

MATS Mercury and Air Toxics Standards

MECS Manufacturer Energy Consumption Survey

MIA Manufacturing impact analysis

MPC Manufacturer production costs

MSP Manufacturers’ selling prices

NAECA National 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 Programmed-start

RECS Residential Energy Consumption Survey
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SCC Social cost of carbon

TLED tubular light-emitting diode

TSD Technical support document

TSL Trial standard levels

UL Underwriters Laboratories
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RULEMAKING FRAMEWORK DOCUMENT FOR

FLUORESCENT LAMP BALLASTS

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 interested parties. Interested parties, also referred to as stakeholders, include manufacturers, 

consumers, energy conservation and environmental advocates, state and federal agencies, and 

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

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 and to encourage 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 discusses the rulemaking process. DOE will maintain documents and 

information 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 comment boxes include questions on the approaches DOE is proposing for the analyses 

required for the rulemaking. Appendix A lists the 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 amendments to EPCA have given DOE the authority to 

regulate the energy efficiency of several products, including certain fluorescent lamp ballasts—

the products that are the subject of this document. Amendments to EPCA in the National 

Appliance Energy Conservation 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 these standards should be amended; and (2) for each rulemaking cycle, 

determine whether the standards in effect for fluorescent lamp ballasts should be amended so that 

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

DOE completed the first cycle of amendments by publishing a final rule in September 

2000 (hereafter the “2000 Ballast Rule”). 65 FR 56740 (Sept. 19, 2000). This first rulemaking 

 1 For editorial reasons, upon codification in the U.S. Code (U.S.C.), Part B was redesignated as Part A.
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cycle established a consensus standard, representing an agreement between 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 was 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 language in the consensus standard 

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

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

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

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

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

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

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

standards established minimum ballast efficiency requirements for “energy saver” versions 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 Ballast 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 Framework document 

and the associated 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 OF THE RULEMAKING PROCESS

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

the products subject to such standard;

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

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

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

result from the imposition of the standard;

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

directly from the imposition of the standard;

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

from the imposition of the standard;

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

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

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

(7) Other factors the Secretary considers relevant.

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

the date for compliance with any standards.

DOE has prepared a preliminary schedule for the fluorescent lamp ballast rulemaking in

Table 2.1. 

Table 2.1 Preliminary Rulemaking Schedule for Fluorescent Lamp Ballast Energy 

Conservation Standards

Deliverable Publication Date

Framework Document June 2015 

Preliminary Analysis September 2016

NOPR October 2017

Final Rule October 2019

2.1.1 Preliminary Analyses and Notice of Public Meeting

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 technology 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.

Next, DOE considers design options or efficiency levels for each product class. DOE 

collects manufacturer cost data, historical shipment data, shipment-weighted average efficiency 

data, and preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing 
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costs, and research and development costs) based on these design options 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 considers 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 these 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 publication 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 when 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 energyefficiency levels or design options that span technologically achievable efficiencies. The range of 

levels DOE typically 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 conservation 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 received after the 

publication of the preliminary analysis. This process may result in revisions or refinements to the 
6

preliminary analyses, including the engineering analysis, and LCC and PBP analysis. DOE also 

will conduct additional economic and environmental 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 methodology 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 discussion 

of other TSLs considered but not selected (and the reasons for not selecting them).

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

each product class, DOE will identify the max tech EL. If DOE proposes a level 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.

DOE 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 

copy 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 publication 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 the 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 publication of the final rule. DOE will 

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

final rule will promulgate the final standard level and the compliance date and explain the basis 

for its selection. The final rule will be accompanied by a final TSD.
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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 

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

significant energy savings. Economic justification includes the consideration of economic 

impacts on domestic manufacturers and consumers, national benefits including environmental 

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

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

justified without imposing excessive financial burden on any particular party.

Figure 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 gather 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 information between the various analyses. DOE ensures 

a consistent approach to its analyses throughout the rulemaking by considering each analysis as a 

part of the overall standards-setting framework.
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Figure 2.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Energy 

Conservation Standard Rulemaking Process
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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, 2011, (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

On 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 energy 

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 requirements. 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 which 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 connected 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, and is not providing 

any standby or active mode function. Id.

 3 The 2011 Test Procedure Final Rule originally established appendix Q1 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 covered 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 subject 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 feasible. (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 energy consumption if standby mode capable dimming ballasts 

were considered for standards.

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.

2.4 Metric

Current energy 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 includes an 

adjustment factor to account for the reduced system efficacy associated with operation at lowfrequency (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 when 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 metrics used for establishing energy 

conservation standards for active mode and standby mode energy use.

SECTION 3 SCOPE OF COVERAGE

The definition of fluorescent lamp ballast and fluorescent lamp establish the scope of 

coverage of this rulemaking. These terms are defined 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 start 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 rated wattage of 25 or 

more;

(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium 

bipin bases of nominal overall length between 22 and 25 inches and rated wattage of 

25 or more;

(3) Any rapid start lamp (commonly referred to as 8-foot high output lamps) with 

recessed double contact 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 to 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 430.2
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3.1 Fluorescent Lamp Ballasts Currently Subject to Standards

As directed by 42 U.S.C. 6295(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 

manufactured on or after November 14, 2014, that are designed to operate at an input voltage at 

or between 120 volts (V) and 277 V and with an input current frequency of 60 hertz, 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 wattage 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 are 

designed, labeled, and marketed for use in outdoor signs.

Additionally, there are standards for fluorescent lamp ballasts manufactured on or after 

November 14, 2014, that are designed to operate at an input voltage at or between 120 and 277 V 

and with an input current frequency of 60 hertz, for dimming to 50 percent or less of the 

maximum output of the ballast, and to operate one or two F34T12 lamps, two F96T12 Energy 

Saver (ES) lamps, or two F96T12 HO ES lamps. 10 CFR 430.32(m)

3.2 Additional Fluorescent Lamp 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-saving 

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 specialized 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 to
13

energy conservation standards. 76 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 

reflector 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 245 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 finds 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 analysis 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) programmed 

start (PS) ballasts operate at currents below minimum American National Standards Institute 

(ANSI) C78.81-20107 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 

these 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 current is decreased, none of the PS ballasts tested with an average current of 

less than 140 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 Nonresidential 

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 American 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. 14, 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 available.

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 existing 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-foot 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 fluorescent 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 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.

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 information as well as information regarding the potential for 

efficiency improvements and energy savings.

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

Standards

For applications in which EMI has been or is expected to be an issue, magnetic ballasts 

are typically recommended. Applications potentially sensitive to EMI include: medical operating 

room telemetry or life support systems; airport control systems; electronic test equipment; radio 

communication devices; radio recording studios; correctional facilities; clean rooms; facilities 
15

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 by 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 AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the manufacturers 

of fluorescent lamp ballasts, and specifics about the performance attributes of these ballasts. This 

assessment is used to develop product classes and identify technology 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 factor.

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 and trends, address regulatory and nonregulatory 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 plans 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 

publications.

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 limited 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 

ballast 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 divulge 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 disclosure of the data due to actions taken by a 

third party, stakeholders providing confidential information to DOE must submit that data 

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

he or she believes to be confidential and exempt by law from public disclosure should submit 

two copies. One copy of the document shall include all the information believed to be 

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

confidential deleted. 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 divulge 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 Product 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 submitted information as confidential include: (1) a 

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

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

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

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

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

be contrary to the public interest.
17

separate standard levels for each product class. DOE is considering maintaining the current 

product classes for ballasts currently 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 slimline 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 classified 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-foot U-shaped lamps

8. Dimming ballasts that operate

• One F34T12 lamp

• Two F34T12 lamps

• Two F96T12 ES lamps

• Two F96T12 HO ES lamps
18

As mentioned in section 3.2.1, DOE is considering analyzing standards for additional 

dimming fluorescent lamp ballasts in this rulemaking as their annual shipments have 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:

• Residential versus commercial end use,

• Lamp type operated by the ballast,

• Continuous dimming,

• Step dimming,

• 0-10V dimming control,

• Power line dimming control, or

• Standardized 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 that 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 determining 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 categories 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 design. 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

Transistors 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 components 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 Rule, 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 

winding losses,

 10 The 2011 Ballast Rule technical support document is available on regulations.gov in docket number EERE-2007-

BT-STD-0016.
20

• Using wire with multiple smaller coils instead of one larger coil to increase 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 identified 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 analysis. 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 Feasibility. DOE will consider technologies incorporated in commercial 

products or in working prototypes to be technologically feasible.

2. Practicability to Manufacture, Install, and Service. 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 service.

3. Adverse Impacts on Product or Equipment Utility to Consumers or Availability. 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 unavailability 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 technology 

further.

4. Adverse Impacts on Health or Safety. If DOE determines that a technology will have 

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

further.

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

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

part of the 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 

ballasts 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 conducting 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 under 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 selecting 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 determine 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 Framework document, DOE is considering 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 representative 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 selects 

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.

For products that do not have existing energy conservation standards, DOE will select the mostcommon, 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 conservation standards.

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.

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, either 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 establishes 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 substitutions 
23

maintain light output within 10 percent 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 ballast designs.

6.5 Efficiency 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 ELs 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

Where: 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 compliance 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 adding 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 average 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 engineering 

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 costassessment 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 retail 

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 

feasibility 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 classes 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 welcomes 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, that 
25

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 anticompetitive 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 

approaches, 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 rulemaking.

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 the 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 engineering 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 analysis, 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 ENERGY 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 use 
26

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-andballast systems for the sectors.

The 2000 Ballast Rule used a different data set than the 2011 Ballast Rule, but both had 

similar operating hours for the different sectors. The 2011 Ballast Rule used a combination of 

data sources including the 2002 U.S. Lighting Market Characterization (LMC), the Energy 

Information Administration’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 lamps 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 lamp 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 3,300 – 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-use 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 Lighting Controls

In the 2011 Ballast Rule, DOE accounted for occupancy sensors in the energy use 

analysis by determining an average savings value associated with occupancy sensors. DOE then 

translated the energy savings into reduced operating hours for the products operated by 

occupancy sensors. Table 7.2 includes the operating hours that DOE used in the 2011 Ballast 

Rule related to occupancy sensors.

Table 7.2 2011 Ballast Rule – Adjusted 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, and any available documents to determine the 

portion of time and the output setting to which fluorescent ballasts are dimmed for task tuning, 

daylight harvesting, and other applications. DOE also plans to research the common applications 

and prevalence of dimming 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 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.
28

Item 7-4 DOE welcomes comment on the use of the dimming ballasts: types of ballasts 

and lamps typically dimmed; applications in which dimming 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 Characterization to develop 

operating hours by sector.12 DOE plans to review the current versions of CBECS, RECS13, 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 DOE did previously in the 2011 Ballast Rule.

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-andballast systems. To develop a distribution of annual operating hours in the industrial sector, DOE 

would use an approach similar to that used for the commercial sector, aggregating LMC annual 

operating hour data by industry to develop weighted average annual operating hours. To develop 

a distribution 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 of 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 analyses. 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 the 2011 Ballast Rule.
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 

fluorescent 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., replacement 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. Figure 8.1 illustrates the two main distribution channels 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.

Figure 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 the 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

BALLASTS
30

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 necessitated by new or 

amended standards.

In addition to developing markups, DOE will develop and include sales taxes to calculate 

final prices to consumers. DOE will use an annually updated Internet source, the Sales Tax 

Clearinghouse, to calculate applicable 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 rulemaking.

SECTION 9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

The effects of increased energy conservation standards on consumers include a change in

operating expense (usually decreased) and a change in purchase price (usually increased). The 

LCC of a product is the cost a product incurs over its lifetime, taking into account both purchase 

price and operating expenses. The PBP represents the time it takes to recover the additional 

installed cost of the more efficient device through annual operating cost savings. DOE will 

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 conducts a 

rebuttable presumption analysis. Under 42 U.S.C. 6295(o)(2)(B)(iii), the statute establishes a 

rebuttable presumption that a standard is economically justified “[i]f the Secretary finds that the 

additional cost to the consumer of purchasing a product complying with an energy conservation 

standard level will be less than three times the value of the energy ... savings during the first 

year that the consumer will receive as a result of the standard, as calculated under the applicable 

test procedure....” For fluorescent lamp ballasts, because the DOE test procedure does not

include an input for operating hours, DOE plans to use the average annual operating hours of the 

most-common end-use application. Although the rebuttable presumption calculation is helpful in 

 14 Source: www.thestc.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 preliminary analysis, 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 discount rates. If DOE determines that there is significant variability in any of the 

above inputs, it will conduct sensitivity analyses to determine how the LCC and PBP are 

impacted by high and low estimates for each of the inputs. For any sensitivity analyses that it 

conducts, DOE will account for correlations that may exist between inputs (e.g., energy usage 

may be correlated to energy prices). The detailed impact calculation, which DOE will conduct 

after the preliminary analysis, 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 preliminary analysis, if necessary.

For fluorescent lamp ballasts, DOE will need to determine input values for several 

variables. The following sections discuss the methodologies DOE plans to use to develop energy 

prices, discount rates, maintenance/repair/installation costs, and ballast lifetimes. Some of the 

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 Tax 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 Analysis.

Maintenance, Repair, 

and Installation Cost

This input represents the cost to consumers of installing the ballast as well as the cost 

of maintaining that ballast.

Annual Operating Hours

The annual operating hours are the estimated hours that a fluorescent lamp ballast is 

in use during the time span of one year. Operating hours are developed in Section 7, 

Energy Use Analysis.

Product Energy

Consumption Rate

The product energy consumption is the site-energy usage rate associated with 

operating the lamp system developed in Section 7, Energy Use Analysis.

Electricity Prices Electricity prices used in the analysis are the average price per kilowatt-hour (i.e., 

$/kWh) paid by consumers.

Electricity Price Trends Electricity price trends estimate the future cost of electricity.

Lifetime The total hours in operation after which the consumer retires the ballast or 

components of a ballast system from service.

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

their present value.

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

9.1 Energy Prices

For consumers of fluorescent lamp ballasts, DOE will survey residential, commercial,

and industrial energy tariffs15 as a means for establishing marginal electricity prices. DOE will 

also use data from CBECS16 conducted by EIA to estimate building energy use characteristics 

that affect electricity prices. If the tariff survey and EIA data demonstrate a large variability in 

electricity prices, DOE will conduct a sensitivity analysis to determine how high and low 

electricity price estimates might affect the economic feasibility of any amended energy 

conservation standards. DOE will use projections of national average energy prices for 

residential, commercial, and industrial consumers—principally from EIA’s Annual Energy 

Outlook (AEO) from the most recent year available—as input for future energy prices in its LCC 

analysis.

Item 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 present value of lifetime operating expenses. For 

consumers of fluorescent lamp ballasts, DOE will derive the discount rates for commercial and 

industrial consumers by estimating the cost of capital of companies that purchase commercial 

equipment. The cost of capital is commonly used to estimate the present value of cash flows to 

be derived from a typical company project or investment. Most companies use both debt and 

equity capital to fund investments, so the cost of capital is the weighted-average cost of equity 

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 estimates 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 purchase 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 approaches 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 installation, 

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. However, for 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 utilized.

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

analysis as follows:

• Installation Costs. DOE does not expect that installation costs for fluorescent lamp 

ballasts will change with more energy-efficient ballast designs, as new regulations are not 

 17 Available at http://www.federalreserve.gov/pubs/oss/oss2/scfindex.htm
34

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 ballasts.

• 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 welcomes 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 fluorescent 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 result of the 

standard.

9.4 Fluorescent Lamp Ballast Lifetime

Typically, DOE will use information from manufacturer product catalogs, various 

literature sources such as technical reports and conference proceedings, the 2000 Ballast Rule 

and the 2011 Ballast Rule, 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 preliminary analysis, DOE will 

make 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 SHIPMENTS

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 regulation, 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 ballasts, 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 analyses from the 2000 Ballast Rule and the 2011 Ballast Rule. The 2011 Ballast Rule 

projected in 2011 roughly 100 million total fluorescent lamp ballasts shipped and increased to 

120 million ballasts shipped in 2014. The shipment model in the 2011 Ballast Rule had 

shipments of virtually all product classes increasing to the end of the 2011 Ballast Rule’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 consumers 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 understand 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 experts 

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 installation, 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 ballasts 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 

replacement may occur before the original ballast has failed.

DOE intends 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 standards analyzed. It will use these 

standards case projections to evaluate the effects of standards on ballast shipments. DOE derives 

standards case projections 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 shipments 

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 estimated 
37

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 case.

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 standards 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 

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.

SECTION 11 NATIONAL IMPACT ANALYSIS

The NIA discusses 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 case over a specified 

projection period).

11.1 Inputs to Projections

Analyzing effects of federal energy conservation standards for fluorescent lamp ballasts

requires a comparison of projected energy consumption in the United States with, and without, 

new energy conservation standards. The 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 are 

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. Consumers that 

encounter lower operating costs associated with a more energy-efficient product may use that 

product more often than a less efficient 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 from the service life of ballasts developed in 

Section 9 and annual shipments from ballasts developed in Section 10

Effective Date of Potential Standard 2022

Analysis Period 2022 to 2051 (30 years)

No-New-Standards Case Projected 

Efficiency

Distribution of base shipments by efficiency level over time developed 

in Section 9

Standards Case Projected Efficiency Distribution of shipments by efficiency level for each standards case

over time

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

established in the 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

Electricity Site-to-Source Conversion Conversion varies yearly and is generated by EIA AEO projections of 

electricity generation and electricity related losses

Heating, Ventilating, and AirConditioning (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 percent 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 savings 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 standards. 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 unit 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 in 1996, to 
39

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 

preliminary analysis, DOE will make any necessary 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 average energy-efficiency 

projections 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 ballasts. 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 the national cost of capital may differ from the consumer 

cost of capital, the discount rate used in the NIA can be different from that used in the LCC. 

According to U.S. Office of Management and Budget (OMB) guidance, DOE will conduct two 

NPV calculations, one using a real discount rate of 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 preliminary analysis, DOE will make any necessary changes to the 

analysis and the CSLs.

SECTION 12 CONSUMER SUBGROUP 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, Circular A-4: Regulatory Analysis, September 17, 2003
40

accounting for variations in key inputs to the LCC analysis. The LCC and 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 different 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 extent of any such disproportional 

effect. In the 2011 Ballast Rule, 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 ballasts. A wide range of 

quantitative and qualitative effects may occur following the adoption of standards that may 

require changes to manufacturing practices. DOE 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 

manufacturers 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 important 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 engineering 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 in 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, DOE 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 interviews 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 

opportunity 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 process, 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 difference 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 financial 

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 differential 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. Ideally, 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 manufacturers 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 comment 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 ANALYSIS

To estimate the effects of energy 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 reference 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 response 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 fluorescent 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 ANALYSIS

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 model 

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 sector being regulated, caused by (1) reduced spending by end users on energy, 

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

new products to 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 will 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 being 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 effects on the demand for labor of such shifts in 

economic activity is to compare sector employment 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 dollars 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 capitalintensive and less labor-intensive than other sectors. Energy conservation 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 effects 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, WA. Available at: www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf
44

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.

DOE 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 employment 

effects predicted by ImSET may over-estimate actual job effects 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 (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), and mercury (Hg) from 

potential energy 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 “upstream” 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 prepares 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, 2013. 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 CO2, NOX, and SO2 at the sites where these products are 

used, DOE will also account for the reduction in these site emissions and the associated upstream 

emissions because of potential standards.

SO2 emissions from affected electric generating 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 SO2 for affected EGUs in the 48 contiguous states and the District of Columbia. 

SO2 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 states and D.C. 70 FR 25162 (May 12, 2005). CAIR was remanded to 

EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), but it 
45

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 Rule (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 ordered 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 SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemaking efforts, DOE recognized that there was uncertainty 

about the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that no reductions in power sector emissions would occur for SO2 as a 

result of standards.

Beginning in 2016, however, SO2 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 established a standard for 

hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAPs), and also 

established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent surrogate 

standard for acid gas HAPs. The same controls are used to reduce HAPs and non-HAP acid gas; 

thus, SO2 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 2016. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, emissions will be far below the cap that 

would be established by CSAPR, so it is unlikely that excess SO2 emissions allowances resulting 

from the lower electricity demand would be needed or used to permit offsetting increases in SO2 

emissions by any regulated EGU. Therefore, DOE believes that efficiency standards will reduce 

SO2 emissions in 2015 and beyond.

CAIR established a cap on NOX emissions in eastern states and the District of Columbia. 

Standards are expected to have little or no physical effect on these emissions in those states 

covered by CAIR because excess NOX emissions allowances resulting from the lower electricity 

demand could be used to permit offsetting increases in NOX emissions. However, standards 

would be expected to reduce NOX emissions in the states 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 will 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 downwind 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 slip op. at 32 (U.S. April 29, 2014). Because DOE would be using emissions factors based on AEO2014

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 SO2 emissions.
46

estimates NOX emissions reductions from potential standards in the states 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 mercury emissions reduction using emissions 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 plants 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 SO2 and NOX. The monetary benefits that DOE estimates for 

reductions in SO2 and NOX 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 DIOXIDE AND OTHER EMISSIONS

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered.

To estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current social cost of carbon (SCC) values developed and/or agreed to 

by an interagency process. The SCC 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 science, economics, and ethics. However, with full regard 

for the limits of both quantification and monetization, the SCC can be used to provide 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 2014$, are 

$12.2, $41.2, $63.4, and $121 per metric ton of CO2 avoided. For emissions reductions that occur 

in later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7 percent to 23 percent should be used to adjust the global 

SCC to calculate domestic effects, although DOE will give preference to consideration of the 

global benefits of reducing CO2 emissions.

DOE multiplies the CO2 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 scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 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 estimates the potential monetary benefit of reduced NOx emissions resulting 

from the standard levels it considers. For NOx 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 NOX reduced by electricity generating units. 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 SO2 and Hg emissions. Whether 

monetization of reduced SO2 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 ANALYSIS

If DOE issues a proposal to amend standards for fluorescent lamp ballasts, it will prepare 

a regulatory impact analysis to address the potential for non-regulatory approaches to supplant 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 improvements 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-estimates
48

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 will take into 

account the actual impacts of any existing initiatives to date, but also will consider historical 

information presented that may reasonably estimate the 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 energy 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 submit to OMB for review the assessment of costs and benefits required under section 

6(a)(3) of the order.
49

APPENDIX A – LIST OF ITEMS FOR COMMENT

This appendix lists all the items for comment contained in this Fluorescent Lamp Ballast 

Framework document, and the page numbers on which those items for comment can be found.

Item 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 shipment 

information as well as information regarding the potential for efficiency improvements and 

energy savings............................................................................................................................... 13

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. ..................................................................................... 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 energy 

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 information 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 EMIsensitive 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 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). ............................................................................................................................. 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 dimming 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 comment on the preliminary technology options identified in this 

section. DOE welcomes comment on whether there are additional technology options that it 

should consider. ............................................................................................................................ 20
50

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

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............................ 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 higherefficiency 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 testing data 

when establishing efficiency levels. ............................................................................................. 23

Item 6-6 DOE welcomes comment on the pricing methodology, and in particular the feasibility 

of using product teardowns to develop pricing............................................................................. 24

Item 6-7 DOE welcomes comments on the methodology to scale energy conservation 

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 savings 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; applications in which dimming occurs; output setting of the dimmed 
51

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 for 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 lamp 

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 fluorescent lamp ballasts under consideration for standards in this rulemaking.... 33

Item 9-3 DOE welcomes 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 fluorescent 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 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 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. ............................................. 36

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. ............... 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 moreefficient 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 ballasts. .................................................................... 40

Item 13-1 DOE seeks comments on any potential subgroups of fluorescent lamp ballast 

manufacturers that it should consider in a manufacturer subgroup analysis. ............................... 42
52

Item 13-2 DOE seeks comment 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............................................................................... 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................................................................................................... 44

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. ............................ 46

Item 17-1 DOE requests comment about the approach it plans to use for estimating monetary 

benefits associated with emissions reductions.............................................................................. 47