August 8, 2011 

VIA EMAIL TO: CCE-2010-BT-CE-0014@ee.doe.gov

Ms. Brenda Edwards 

US Department of Energy 

Buildings Technologies Program 

Mail Stop EE-2J 

1000 Independence Ave, SW 

Washington, DC 20585-0121 

Energy Conservation Program: Certification, Compliance and Enforcement for Consumer Products and 

Commercial and Industrial Equipment 

Docket Number: EERE 2010-BT-CE-0014

RIN Number 1904-AC23

NEMA continued request for extension to the DOE CCE Rule for Metal Halide Lamp Ballasts and 

Fixtures 

NEMA thanks the DOE for allowing us to review the draft CCE extension and for allowing us to meet in person 

to further discuss out concerns. NEMA and its member companies are strong advocates for energy efficiency. 

We have met with DOE in the past regarding business concerns related to non-compliant products in the market 

place. We support the DOE efforts to improve product compliance and enforcement for energy regulations. We 

believe that this rule will provide long term benefits to our members’ businesses. However, NEMA and its 

members still have strong concerns that the proposed three month extension does not allow enough time for 

products to be tested and reported. 

As noted in our recent face to face meeting with representatives of DOE, NEMA and its members overlooked 

the March 9, 2010 final rule for Test Procedures for MH lamp ballasts that increased test sample size from 1 to 

not fewer than 4 units. Since they realized and understood this change, the member companies have begun the 

additional testing. NEMA feels all parties involved contributed to the need for a delay and we need to work 

together to set a workable time line. 

DOE has requested additional information regarding the testing of MH lamp ballasts. The information below 

describes the testing process and coordination with luminaires that use those ballasts. 

• The number of ballast models covered by the energy standard varies significantly based on the individual 

ballast manufacturer. Several ballast manufacturers indicate that they have about 40-50 covered ballasts, 

but a few larger manufacturers may have well over 100 covered ballasts. 

• One luminaire manufacturer has indicated they purchase over 1000 covered ballast models from 15 different 

vendors. 

1300 North 17th Street, Suite 1752 - Rosslyn, VA 22209 - 703.841.3200 - 703.841.5900 fax 
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• Ballast manufacturers have indicated that testing ballast efficiency typically requires about 2 hours; however 

the entire set up of calibration and stabilization can result in a total lab test time of 8 to 24 hours per ballast. 

The variation depends on the type of ballast and stabilization requirements. Of comments received from 

ballast manufacturers, the most commonly sited timeframe is 3 working days to complete the minimum 

sampling of four ballasts for a single ballast model. 

• Ballast manufacturers have noted that the sample of 4 ballasts is very likely to meet the mean ballast

efficiency, but a larger sample is required to achieve the 99% LCL. Therefore additional samples and test 

time is very likely to be required. A less stringent confidence level would help to ensure that additional 

testing is not necessary. 

• Most ballast manufacturers have one lab bench dedicated to ballast testing. Ballast manufacturers use this 

bench to test ballasts that are not covered by the energy standard and it is unrealistic to assume the bench 

can be 100% dedicated to testing covered ballasts for an extended period of time. 

Based on the data above, in a best case scenario (40 models, 3 days to test three additional samples, test lab 

dedicated to only testing covered MH ballasts), the ballast testing will require 24 weeks with test data available 

to luminaire manufacturers around January 2012. 

In a more realistic scenario (40 models, 5 days to test sufficient samples to achieve 99% LCL, lab 75%

dedicated to testing covered MH ballasts), the ballast testing will require 53 weeks with test data available to 

luminaire manufacturers around August 2012. 

NEMA has previously provided input regarding the logistics for luminaire manufacturers to correlate each 

ballast model for each vendor to each luminaire basic model. One luminaire manufacturer recently informed 

NEMA that their 2010 FTC report included over 260 basic luminaire models of covered products. Each of these 

models covered multiple wattages and uses multiple ballast vendors and they may prefer to report each basic 

model for separate wattages and ballast vendors to minimize compliance risks. This would increase the number 

of basic models reported to DOE to several hundred basic models. The logistics of compiling, analyzing and 

reporting the basic luminaire models is expected to require around 3 months. 

NEMA ballast and luminaire manufacturers find that an extension to October 1, 2011 will not provide sufficient 

time to conduct the necessary ballast testing and correlation with luminaire basic models. 

We again suggest that for MH luminaires, DOE delay the enforcement of compliance reporting for MH 

luminaires until a date no earlier than September 1, 2012 to allow for a reasonable and accurate process to 

compile the tests and submit based the testing and reporting requirements. This date coincides with the annual 

reporting date, minimizing the burden of multiple reports within the same year. 

If you have any questions or comments, please do not hesitate to contact Alex Boesenberg of NEMA 

Government Relations at (703) 841-3268 or alex.boesenberg@nema.org. 

Sincerely,