Revised on 4/27/2010

ES-i 

EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES ......................................... 1

ES.2 KEY RESULTS OF THE ANALYSIS .............................................................................. 3

ES.2.1 Determination of Scope .......................................................................................... 3

ES.2.2 Market and Technology Assessment ...................................................................... 3

ES.2.3 Screening Analysis.................................................................................................. 5

ES.2.4 Engineering Analysis .............................................................................................. 5

ES.2.5 Energy Use Characterization .................................................................................. 6

ES.2.6 Markups Analysis ................................................................................................... 7

ES.2.7 Life-Cycle Cost and Payback Period Analyses ...................................................... 8

ES.2.8 Shipments Analysis ............................................................................................... 10

ES.2.9 National Impact Analysis ...................................................................................... 14

ES.2.9.1 National Energy Savings Analysis................................................ 15

ES.2.9.2 Net Present Value Analysis .......................................................... 17

ES.2.10 Preliminary Manufacturer Impact Analysis .............................................. 19

ES.2.11 Other Analyses .......................................................................................... 20

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT ............................................. 20

ES.3.1 Test Procedures ..................................................................................................... 20

ES.3.2 Scope of Coverage ................................................................................................ 20

ES.3.3 Product Classes ..................................................................................................... 21

ES.3.4 Technology Options .............................................................................................. 21

ES.3.5 Screening Analysis................................................................................................ 21

ES.3.6 Candidate Standard Levels for Representative Product Classes ........................... 22

ES.3.7 Maximum Technologically Feasible Ballast ........................................................ 22

ES.3.8 Manufacturer Production Costs ............................................................................ 22

ES.3.9 Candidate Standard Levels for Non-Representative Product Classes .................. 22

ES.3.10 Cumulative and Future Regulation ........................................................... 22

ES.3.11 Operating Profiles for Energy Use Characterization ................................ 23

ES.3.12 Lighting Controls and Ballast Operating Profiles ..................................... 23

ES.3.13 Price Markups ........................................................................................... 23

ES.3.14 Electricity Prices for LCC and PBP Analyses .......................................... 24

ES.3.15 Effects of Energy Efficient Design on Ballast Life .................................. 24

ES.3.16 Average Ballast Lifetimes and Failure Distributions................................ 24

ES.3.17 Historical Shipments Data ........................................................................ 24

ES.3.18 Shipment Trends ....................................................................................... 25

ES.3.19 NIA and External Benefits ........................................................................ 25

ES.3.20 Trial Standard Levels ................................................................................ 25

ES.3.21 Impact on Manufacturers .......................................................................... 25

ES.3.22 Valuing Air-Borne Emission Reductions ................................................. 25

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ES-ii

LIST OF TABLES

Table ES.2.1 Scope of Coverage for Fluorescent Lamp Ballast Rulemaking .................................3

Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts .........................................................4

Table ES.2.3 Summary of Baselines and Candidate Standard Levels for Fluorescent 

Lamp Ballast Representative Product Classes .........................................................5

Table ES.2.4 Summary of Incremental Manufacturer Selling Prices Over the Baseline for 

Fluorescent Lamp Ballast Representative Product Classes .....................................6

Table ES.2.5 Average Annual Lamp-and-Ballast System Operating Hours by Sector ..................6

Table ES.2.6 Annual Energy Consumption by Ballast Product Class ............................................7

Table ES.2.7 Markups for Ballasts .................................................................................................8

Table ES.2.8 Life-Cycle Cost and Payback Period Results for Ballasts ........................................9

Table ES.2.9 Cumulative National Energy Savings for Ballasts Under the Existing 

Technologies, Shift Scenario (2014–2044)............................................................16

Table ES.2.10 Cumulative National Energy Savings for Ballasts Under the Emerging 

Technologies, Roll-Up Scenario (2014–2044) ......................................................17

Table ES.2.11 Cumulative NPV Results for Ballasts Under the Existing Technologies, 

Shift Scenario (2014–2044) ...................................................................................18

Table ES.2.12 Cumulative NPV Results for Ballasts Under the Emerging Technologies, 

Roll-Up Scenario (2014–2044) ..............................................................................19

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Rulemaking 

Process .....................................................................................................................2

Figure ES.2.1 Ballast Distribution Channels ...................................................................................8

Figure ES.2.2 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot MBP 

Lamps (Commercial Sector, Existing and Emerging Technologies 

Scenarios) ...............................................................................................................11

Figure ES.2.3 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot RDC 

HO Lamps (Excluding Sign Ballasts) ....................................................................12

Figure ES.2.4 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot SP 

Slimline Lamps ......................................................................................................12

Figure ES.2.5 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot T5 

MiniBP SO and HO Lamps (Existing and Emerging Technologies 

Scenarios) ...............................................................................................................13

Figure ES.2.6 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot MBP 

Lamps in the Residential Sector ............................................................................14

Figure ES.2.7 Base-Case Forecasted Shipments for Sign Ballasts Operating Eight-Foot 

RDC HO Lamps .....................................................................................................14

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EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

 Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that are technologically feasible and economically 

justified, and that would achieve the maximum improvement in energy efficiency. This executive 

summary highlights the activities associated with this preliminary analysis that DOE conducted 

when considering amended energy conservation standards for fluorescent lamp ballasts. The 

executive summary also describes key results from DOE’s preliminary analysis and delineates 

issues on which DOE seeks comment. These issues are highlighted in the public meeting 

presentation and are further discussed in chapter 2 of the preliminary technical support document 

(TSD). 

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases; DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the pre-NOPR analyses. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 

EERE-2007-BT-STD-0016 COMMENT 25
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ES-2

Figure ES.1.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Rulemaking 

Process

EERE-2007-BT-STD-0016 COMMENT 25
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ES-3

ES.2 KEY RESULTS OF THE ANALYSIS 

 The following sections describe in detail the key analyses DOE performed. 

ES.2.1 Determination of Scope 

 Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) direct DOE to 

determine whether to amend energy conservation standards for fluorescent lamp ballasts and 

whether such standards should be made applicable to additional fluorescent lamp ballasts. (42 

U.S.C. 6295(g)(7)(B)) After identifying additional ballasts for consideration, DOE assessed 

whether each ballast type met the criteria for prescribing new or amended standardsi.e., 

potential for significant energy savings, technological feasibility, and economic justification. (42 

U.S.C. 6295(o)(2)(A)) The following table summarizes the fluorescent lamp ballast market and 

indicates ballasts included in coverage by this rulemaking and ballasts not included in coverage 

(indicated by shading). 

Table ES.2.1 Scope of Coverage for Fluorescent Lamp Ballast Rulemaking 

Ballast-Specific Characteristic Lamp-Specific Characteristic

Dimmable Input Voltage

V Lamp Base

Nominal Lamp 

Length

Feet

Lamp Diameter Rated Lamp Wattage

W 

Not 

Dimmable

Can operate 

within the range 

of 120 to 277V

Medium Bipin Four T8 and T12 ≥ 25

Miniature Bipin Four T5 ≥ 26 for std output

≥ 49 for high output

Single Pin Eight T8 and T12 ≥ 52

Recessed Double 

Contact Eight T8 and T12 All

ES.2.2 Market and Technology Assessment 

A market and technology assessment characterizes the relevant product markets and 

technology options, including prototype designs. See chapter 3 of the preliminary TSD for 

details. 

 DOE generally divides covered products into product classes by the type of energy used 

or by capacity or other performance-related features that affect efficiency. Different energy 

conservation standards may apply to different product classes. (42 U.S.C. 6295(q)) Table ES.2.2

describes all of the product classes DOE is considering in this rulemaking.

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ES-4

Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts

Ballast and Lamp 

Type

Starting 

Method* 

Ballast 

Factor**

Number of Lamps

One Two Three Four Five Six

4-Foot MBP and 2-

Foot U-Shaped 

IS and RS 

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

4-Foot T5 MiniBP 

SO All

High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A

Low 41 42 N/A N/A N/A N/A

4-Foot T5 MiniBP All All 43 44 45 46 N/A N/A

8-Foot SP Slimline All 

High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A

Low 51 52 N/A N/A N/A N/A

8-Foot RDC HO

IS and RS All 53 54 N/A N/A N/A N/A

PS All 55 56 N/A N/A N/A N/A

Residential Ballast, 

4-Foot MBP and 2-

Foot U-Shaped

IS and RS All 57 58 59 60 N/A N/A

PS All 61 62 63 64 N/A N/A

Sign Ballasts All All 65 66 67 68 69 70

*Starting methods include instant start (IS), rapid start (RS), and programmed start (PS)

** DOE classifies a low ballast factor as less than or equal to 0.78, a normal ballast factor as 

greater than 0.78 but less than 1.1, and a high ballast factor as greater than or equal to 1.1. 

DOE addresses (1) manufacturer market share and characteristics, (2) existing regulatory 

and non-regulatory initiatives for improving product efficiency, and (3) trends in product 

characteristics and retail markets. This information provides data and resource material 

throughout the analysis. 

DOE reviews literature and interviews manufacturers to develop an overall understanding 

of the fluorescent lamp ballast industry. Industry publications, including trade journals, literature 

from manufacturers, government agencies, and trade organizations provide the bulk of the 

information, including: (1) manufacturers and their market share; (2) shipments by product type; 

(3) product information; and (4) industry trends. 

 DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. The identified technologies initially include all those DOE 

believes are technologically feasible. 

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ES-5

ES.2.3 Screening Analysis 

 DOE develops an initial list of options for enhancing efficiency from the technologies 

that the technology assessment identified as feasible. In consultation with interested parties, DOE 

reviews the list to assess whether the technologies are practicable to manufacture, install, and 

service; would adversely affect product utility or availability; or would have adverse impacts on 

health and safety. In the subsequent engineering analysis, DOE further examines the technology 

options that it did not remove from consideration in the screening analysis. See chapter 4 of the 

preliminary TSD for details.

ES.2.4 Engineering Analysis 

The engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups to 

convert manufacturer production cost (MPC) to manufacturer selling price (MSP) (chapter 5). 

The engineering analysis analyzed ten key product classes that cover the range of product 

classes within the fluorescent lamp ballast market. For each product class, DOE chose 

appropriate baseline ballasts and identified more efficient replacements. For each candidate 

lamp-and-ballast design, DOE calculated the manufacturer selling price, measured the ballast 

efficacy factor (BEF), and used the values to generate cost-efficiency curves for each 

representative product class. To calculate MSP, DOE generated a bill of materials by 

disassembling multiple manufacturers’ ballasts that spanned a range of efficiency levels. DOE 

then developed a cost model that converted the bill of materials pricing into MPCs. By applying 

derived manufacturer markups to the MPCs, DOE calculated the MSPs. DOE was not able to 

generate a bill of materials for all ballasts in this engineering analysis. In these cases, DOE 

developed a scaling method using retail prices to estimate an MSP for each one. See chapter 5 of 

the preliminary TSD for details.

Table ES.2.3 presents the BEF identified for each baseline and candidate standard level 

(CSL) in the engineering analysis. Table ES.2.4 presents the incremental MSP for each of these 

more efficient options. 

Table ES.2.3 Summary of Baselines and Candidate Standard Levels for Fluorescent Lamp 

Ballast Representative Product Classes

Representative Product Class Baseline CSL1 CSL2 CSL3

BEF BEF BEF BEF

Two-Lamp Normal BF 4-Foot MBP IS & RS 1.359 1.450 1.535 1.561

Two-Lamp Normal BF 4-Foot MBP PS 1.418 1.518 N/A N/A

Four-Lamp Normal BF 4-Foot MBP IS & RS 0.768 0.781 N/A N/A

Four-Lamp Normal BF 4-Foot MBP PS 0.708 0.755 N/A N/A

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.309 1.441 1.482 N/A

Two-Lamp 4-Foot T5 MiniBP HO 0.688 0.791 0.837 N/A

Two-Lamp Normal BF 8-Foot SP Slimline 0.797 0.807 N/A N/A

Two-Lamp 8-Foot RDC HO IS & RS 0.440 0.500 0.549 N/A

Two-Lamp 4-Foot MBP IS & RS Residential 1.277 1.457 1.492 N/A

Four-Lamp Sign Ballasts 0.196 0.238 N/A N/A

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ES-6

Table ES.2.4 Summary of Incremental Manufacturer Selling Prices Over the Baseline for 

Fluorescent Lamp Ballast Representative Product Classes

Representative Product Class CSL1 CSL2 CSL3

$ $ $

Two-Lamp Normal BF 4-Foot MBP IS & RS (2.83)* (0.26) (1.33)

Two-Lamp Normal BF 4-Foot MBP PS 3.51 N/A N/A

Four-Lamp Normal BF 4-Foot MBP IS & RS 1.37 N/A N/A

Four-Lamp Normal BF 4-Foot MBP PS 3.48 N/A N/A

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 0.24 0.37 N/A

Two-Lamp 4-Foot T5 MiniBP HO 0.22 3.18 N/A

Two-Lamp Normal BF 8-Foot SP Slimline 6.92 N/A N/A

Two-Lamp 8-Foot RDC HO IS & RS 0.34 1.58 N/A

Two-Lamp 4-Foot MBP IS & RS Residential 3.40 6.45 N/A

Four-Lamp Sign Ballasts (4.64) N/A N/A

*Parentheses indicate a negative value.

ES.2.5 Energy Use Characterization

The energy use characterization, which assesses the potential energy savings resulting 

from amended efficiency standards, provides the basis for developing the energy savings used in 

the life-cycle cost (LCC) and subsequent analyses. Ballasts are designed to operate fluorescent 

lamps, which are not subject to the energy efficiency standards being developed in the 

fluorescent ballast standards rulemaking. However, because fluorescent ballasts are not intended 

to operate without lamps, the input power of the complete lamp-and-ballast system was required 

for the energy use analysis. DOE determined the annual energy consumption of the lamp-andballast systems using information on input power (i.e., the rate of energy they consume) and the 

way consumers use them (i.e., operating hours per year). Table ES.2.5 summarizes the average 

annual operating hours used for the energy use characterization, organized by market sector.

Table ES.2.5 Average Annual Lamp-and-Ballast System Operating Hours by Sector 

Sector Average Annual Operating Hours

hrs/year

Residential 789

Commercial 3,435

Commercial (PS)* 2,405

Industrial 4,795 * Programmed start (PS) ballasts operating 4-foot MBP lamps on 

occupancy sensors.

The engineering analysis references measured system input power and normalized system 

input power, with the latter used to normalize input power between baseline and standards-case 

systems to maintain the same approximate light output. Table ES.2.6 shows the average annual 

electricity use in kilowatt-hours (kWh) for each efficiency level in each product class that DOE 

is considering in this rulemaking. 

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ES-7

Table ES.2.6 Annual Energy Consumption by Ballast Product Class 

Representative Product Class Market Sector CSL Annual Energy Consumption

kWh

Measured Normalized

Two-Lamp Normal BF 4-Foot MBP IS & 

RS 

(T8 Baseline)

Commercial Baseline/1 207.5 207.5

2 192.4 195.8

3 193.7 194.1

Two-Lamp Normal BF 4-Foot MBP PS Commercial Baseline 152.7 152.7

1 136.8 142.1

Two-Lamp Normal BF 4-Foot MBP IS &

RS (T12 Baseline)

Commercial Baseline 218.1 218.1

1 207.5 202.7

2 192.4 191.3

3 193.7 189.6

Four-Lamp Normal BF 4-Foot MBP IS & 

RS

Commercial Baseline 383.0 383.0

1 393.0 379.9

Four-Lamp Normal BF 4-Foot MBP PS Commercial Baseline 289.3 289.3

1 279.2 274.7

Two-Lamp 8-Foot RDC HO IS & RS (T12 

Baseline)

Industrial Baseline 999.3 999.3

1 815.2 879.4

1 767.2 902.9

2 684.7 1,049.1

Two-Lamp 8-Foot RDC HO IS & RS (T8 

Baseline)

Industrial Baseline/1 767.2 767.2

2 684.7 891.4

Two-Lamp Normal BF 8-Foot SP Slimline 

(T12 Baseline)

Commercial Baseline 381.6 381.6

1 376.1 376.5

Two-Lamp Normal BF 8-Foot SP Slimline 

(T8 Baseline)

Commercial Baseline 376.8 376.8

1 371.0 367.2

Two-Lamp Normal BF 4-Foot T5 MiniBP 

SO

Commercial Baseline 267.2 267.2

1 222.9 222.9

2 224.6 215.4

Two-Lamp 4-Foot T5 MiniBP HO Industrial Baseline 688.1 688.1

1 598.4 598.4

2 586.9 571.1

Two-Lamp 4-Foot MBP IS & RS

(T12 Baseline)

Residential Baseline 36.2 36.2

1 41.9 31.2

2 43.6 30.5

Two-Lamp 4-Foot MBP IS & RS

(T8 Baseline)

Residential Baseline/1 41.9 41.9

2 43.6 40.9

Four-Lamp Sign Ballasts Commercial Baseline 1,352.0 1,352.0

1 906.8 1,113.3

Four-Lamp Sign Ballasts Industrial Baseline 1,887.3 1,887.3

1 1,265.9 1,554.1

 See chapter 2 and chapter 6 of the preliminary TSD for details. 

ES.2.6 Markups Analysis

 A markups analysis converts the manufacturer costs derived from the engineering 

analysis to end-user prices. In developing markups, DOE determined the distribution channels 

for ballasts and the markup associated with each party in the distribution channel, as well as the 

appropriate sales tax. 

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ES-8

 Two types of distribution channels describe how most ballasts pass from the 

manufacturer to the end-user (Figure ES.2.1). The first distribution channel applies to ballasts 

installed in fixtures. In this distribution channel, the manufacturer sells the ballast to the fixture 

manufacturer, who sells it to a distributor. The ballast then passes to a contractor, and finally 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 a

distributor, who sells it to a contractor, who sells it to the end-user.

Figure ES.2.1 Ballast Distribution Channels

 DOE developed separate markups for baseline products and for the cost increase 

associated with improvements required to produce more-efficient products. Table ES.2.7

summarizes the markups developed for ballasts. 

Table ES.2.7 Markups for Ballasts

Markup Baseline Incremental

OEM 1.51 1.16

Wholesaler 1.39 1.10

Sales Tax* 1.07 1.07 * Weighted national average.

 See chapter 2 and chapter 7 of the preliminary TSD for details. 

ES.2.7 Life-Cycle Cost and Payback Period Analyses 

 An energy conservation standard usually results in an increase in purchase price and a 

decrease in operating expenses. DOE analyzed the net effect of amended standards on consumers 

by evaluating the net LCC using the cost-efficiency relationship derived in the engineering 

analysis, as well as the energy costs derived from the energy use characterization analysis. All 

BALLAST MANUFACTURER

OEM FIXTURE 

MANUFACTURER

ELECTRICAL WHOLESALER

CONTRACTOR

END-USER OF LIGHTING SYSTEM

FIXTURE

BALLASTS

REPLACEMENT

BALLASTS

EERE-2007-BT-STD-0016 COMMENT 25
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ES-9

replacement options are designed around two possible ballast purchasing events—ballast 

failure/replacement and new construction/renovation—when consumers can be affected by an 

amended energy conservation standard. The LCC spreadsheet calculates the LCC impacts for 

each scenario. 

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher efficiency product. The length of time 

required for products to reach this cost-equivalence point is known as the payback period (PBP). 

 Inputs to the LCC calculation include the installed cost to the consumer, operating 

expenses, lifetime of the equipment, and a discount rate. Chapter 2 of this preliminary TSD 

summarizes the LCC and payback period (PBP) analyses; chapter 8 provides a detailed 

description of these analyses and the results. Table ES.2.8 presents the key findings. 

Table ES.2.8 Life-Cycle Cost and Payback Period Results for Ballasts

Ballast Product Class Purchasing Event CSL LCC

$ 

LCC 

Savings

$

PBP*

yrs

Two-Lamp Normal BF 4-Foot MBP IS & 

RS 

(T8 Baseline)

Replacement Baseline/1 273.24 n/a n/a

2 265.90 7.35 3.9

3 264.88 8.37 2.5

New Construction/ 

Renovation

Baseline/1 275.52 n/a n/a

2 271.21 4.30 5.1

3 267.57 7.95 2.6

Two-Lamp Normal BF 4-Foot MBP PS Replacement Baseline 251.57 n/a n/a

1 238.54 13.03 1.9

New Construction/ 

Renovation

Baseline 253.99 n/a n/a

1 246.29 7.70 2.8

Two-Lamp Normal BF 4-Foot MBP IS & 

RS (T12 Baseline)

Replacement Baseline 315.84 n/a n/a

1 273.24 42.59 -7.8

2 265.90 49.94 -3.7

3 264.88 50.96 -4.4

New Construction/ 

Renovation

Baseline 318.14 n/a n/a

1 271.47 46.67 -6.6

2 267.40 50.74 -3.6

3 263.79 54.35 -4.0

Four-Lamp Normal BF 4-Foot MBP IS & 

RS

Replacement Baseline 489.53 n/a n/a

1 503.97 -14.44 (Never)

New Construction/ 

Renovation

Baseline 491.78 n/a n/a

1 495.25 -3.47 21.5

Four-Lamp Normal BF 4-Foot MBP PS Replacement Baseline 454.92 n/a n/a

1 447.61 7.31 2.9

New Construction/ 

Renovation

Baseline 457.36 n/a n/a

1 445.47 11.89 2.0

Two-Lamp 8-Foot RDC HO IS & RS 

(T12 Baseline)

Replacement Baseline 757.35 n/a n/a

1 679.49 77.86 0.3

1 523.52 233.82 -0.5

2 492.41 264.94 -0.3

New Construction/ Baseline 759.81 n/a n/a

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ES-10

Renovation 1 710.06 49.75 0.4

1 585.50 174.32 -0.7

2 654.86 104.95 -0.7

Two-Lamp 8-Foot RDC HO IS & RS (T8 

Baseline)

Replacement Baseline/1 523.52 n/a n/a

2 492.41 31.11 1.0

New Construction/ 

Renovation

Baseline/1 525.92 n/a n/a

2 585.63 -59.71 (Never)

Two-Lamp Normal BF 8-Foot SP 

Slimline 

(T12 Baseline)

Replacement Baseline 516.55 n/a n/a

1 525.09 -8.54 26.1

New Construction/ 

Renovation

Baseline 518.85 n/a n/a

1 527.67 -8.82 27.8

Two-Lamp Normal BF 8-Foot SP 

Slimline 

(T8 Baseline)

Replacement Baseline 463.12 n/a n/a

1 458.81 4.31 1.1

New Construction/ 

Renovation

Baseline 465.38 n/a n/a

1 457.95 7.42 0.7

Two-Lamp Normal BF 4-Foot T5 

MiniBP SO

Replacement Baseline 326.11 n/a n/a

1 291.02 35.10 0.5

2 303.62 22.50 3.4

New Construction/ 

Renovation

Baseline 328.63 n/a n/a

1 293.32 35.31 0.5

2 298.32 30.31 2.8

Two-Lamp 4-Foot T5 MiniBP HO Replacement Baseline 403.19 n/a n/a

1 366.26 36.93 0.4

2 369.13 34.06 1.7

New Construction/ 

Renovation

Baseline 405.66 n/a n/a

1 368.69 36.97 0.4

2 364.61 41.06 1.4

Two-Lamp 4-Foot MBP IS & RS 

Residential (T12 Baseline)

Replacement Baseline 115.82 n/a n/a

1 113.98 1.84 (Never)

2 122.79 -6.97 (Never)

New Construction/ 

Renovation

Baseline 118.20 n/a n/a

1 104.04 14.16 -5.5

2 110.01 8.19 1.9

Two-Lamp 4-Foot MBP IS & RS 

Residential (T8 Baseline)

Replacement Baseline/1 113.98 n/a n/a

2 122.79 -8.81 (Never)

New Construction/ 

Renovation

Baseline/1 116.37 n/a n/a

2 122.05 -5.68 62.0

Four-Lamp Sign Ballasts Commercial Replacement Baseline 1,552.56 n/a n/a

1 1,167.42 385.14 -0.3

New Construction/ 

Renovation

Baseline 1,554.86 n/a n/a

1 1,343.48 211.38 -0.5

Four-Lamp Sign Ballasts Industrial Replacement Baseline 1,242.84 n/a n/a

1 959.50 283.33 -0.3

New Construction/ 

Renovation

Baseline 1,245.17 n/a n/a

1 1,088.40 156.77 -0.5

* Negative PBP values indicate standards that reduce operating costs and installed costs. Entries of “Never” indicate 

standards that do not reduce operating costs.

ES.2.8 Shipments Analysis

Shipment forecasts are needed to calculate the national impacts of amended standards on 

energy use, the net present value (NPV) of consumer costs and savings, and future manufacturer 

cash flows for each ballast product class under consideration. DOE followed a three-step process 

EERE-2007-BT-STD-0016 COMMENT 25
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ES-11

to forecast ballast shipments. First, DOE used historical shipment data from the U.S. Census 

Bureau to estimate the total historical shipments of each ballast type. Second, DOE calculated an 

installed stock for each ballast type based on individual average service lifetime. Third, by 

modeling ballast purchasing for replacement and new construction/renovation and applying 

growth rate, replacement rate, and emerging technologies (i.e., solid-state lighting) penetration 

rate assumptions, DOE developed annual shipment projections. 

 Chapter 2 and chapter 9 of the preliminary TSD provide additional detail on the 

shipments analysis. 

Figure ES.2.2 through Figure ES.2.7 present the base case shipments forecasts from 

2014–2044 for the ballast product classes under consideration, modeled from the 2006 installed 

stock based on 1990–2005 historical shipments. Estimated historic shipment numbers for ballasts 

exhibited some variation on a year-to-year basis. Preliminary assumptions regarding ballast 

lifetime and failure distributions propagate this variability to produce periodic surges in some 

shipment projections; DOE seeks comment on these assumptions to further refine its shipment 

model (see section ES.3.16).

Figure ES.2.2 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot MBP 

Lamps (Commercial Sector, Existing and Emerging Technologies Scenarios)

0

10,000,000

20,000,000

30,000,000

40,000,000

50,000,000

60,000,000

70,000,000

80,000,000

90,000,000

100,000,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

4-foot T8 MBP Base-Case Existing Tech Forecast

4-foot T12 MBP Base-Case Existing Tech Forecast

4-foot T8 MBP Base-Case Emerging Tech Forecast

4-foot T12 MBP Base-Case Emerging Tech Forecast

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-12

Figure ES.2.3 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot RDC 

HO Lamps (Excluding Sign Ballasts)

Figure ES.2.4 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot SP 

Slimline Lamps

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

8-foot T8 RDC HO Base-Case Forecast 8-foot T12 RDC HO Base-Case Forecast

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

8-foot T8 Slimline Base-Case Forecast 8-foot T12 Slimline Base-Case Forecast

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-13

Figure ES.2.5 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot T5 

MiniBP SO and HO Lamps (Existing and Emerging Technologies Scenarios)

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

40,000,000

45,000,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

4-foot T5 MiniBP SO Base-Case Emerging Tech Forecast

4-foot T5 MiniBP HO Base-Case Emerging Tech Forecast

4-foot T5 MiniBP SO Base-Case Existing Tech Forecast

EERE-2007-BT-STD-0016 COMMENT 25
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ES-14

Figure ES.2.6 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot MBP 

Lamps in the Residential Sector

Figure ES.2.7 Base-Case Forecasted Shipments for Sign Ballasts Operating Eight-Foot 

RDC HO Lamps

ES.2.9 National Impact Analysis 

The national impact analysis (NIA) estimates the following national impacts from 

possible candidate standard levels: (1) national energy savings (NES), (2) monetary value of the 

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

4-foot T8 MBP Base-Case Forecast 4-foot T12 MBP Base-Case Forecast

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

4,000,000

4,500,000

2014 2019 2024 2029 2034 2039 2044

Shipments 

Year

 

8-foot T12 HO Base-Case Forecast

EERE-2007-BT-STD-0016 COMMENT 25
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ES-15

energy savings due to standards, (3) increased total installed costs of the considered products due 

to standards, and (4) the net present value (NPV) of energy savings (difference between value of 

energy savings and increased total installed costs). DOE prepared a spreadsheet model to 

forecast energy savings and national consumer economic costs and savings resulting from new 

standards. Chapter 2 of the preliminary TSD summarizes the methodology for the NIA; TSD 

chapter 10 provides additional detail on the analysis. 

ES.2.9.1 National Energy Savings Analysis 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without amended energy conservation standards) and in each higher efficiency 

standard case. DOE estimated energy consumption and savings based on site energy and 

converted the electricity consumption and savings to source energy. Cumulative energy savings 

are the sum of the annual NES over the time period of the analysis (2014–2044). 

Table ES.2.9 and Table ES.2.10 show the cumulative NES results under the existing 

technologies shift scenario, which reflects the upper bound of energy savings, and the emerging 

technologies roll-up scenario, which reflects the lower bound. Energy savings for individual 

ballast product classes are provided to illustrate the approximate relative energy savings of each 

ballast type under a CSL.

 Due to a larger reduction in the installed stock of ballasts, the emerging technologies 

base-case forecast results in lower energy savings than the existing technologies base-case 

forecast. Because more consumers move to higher-efficacy ballasts in the shift scenario than in 

the roll-up scenario, the shift scenario results in greater energy savings. NES results are 

presented as undiscounted and based on a 7- and 3-percent real discount rate.

EERE-2007-BT-STD-0016 COMMENT 25
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ES-16

Table ES.2.9 Cumulative National Energy Savings for Ballasts Under the Existing 

Technologies, Shift Scenario (2014–2044) 

CSL Ballast Product Class NES Discount*

quads

None Percentage

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.632 0.359 0.813

Two-Lamp Normal BF 4-Foot MBP PS 0.251 0.050 0.120

Four-Lamp Normal BF 4-Foot MBP IS & RS -0.395 -0.088 -0.197

Four-Lamp Normal BF 4-Foot MBP PS 0.133 0.025 0.062

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.013 0.005 0.009

Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 0.000

Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.022 0.005 0.011

Two-Lamp Normal BF 4-Foot T5 Minibp SO 1.923 0.345 0.877

Two-Lamp 4-Foot T5 MiniBP HO 0.710 0.149 0.346

Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.135 -0.029 -0.066

Four-Lamp Sign Ballasts 4.986 1.069 2.453

Total 9.140 1.891 4.427

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.725 0.388 0.868

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.014 0.006 0.010

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 2.264 0.422 1.050

Two-Lamp 4-Foot T5 MiniBP HO 0.744 0.161 0.368

Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.136 -0.029 -0.067

Total 4.382 0.949 2.228

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.725 0.388 0.868

Total 1.727 0.388 0.868 * Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total 

energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.

EERE-2007-BT-STD-0016 COMMENT 25
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ES-17

Table ES.2.10 Cumulative National Energy Savings for Ballasts Under the Emerging 

Technologies, Roll-Up Scenario (2014–2044) 

CSL Ballast Product Class NES Discount*

quads

None Percentage

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.000 0.000 0.000

Two-Lamp Normal BF 4-Foot MBP PS 0.135 0.032 0.069

Four-Lamp Normal BF 4-Foot MBP IS & RS -0.242 -0.062 -0.129

Four-Lamp Normal BF 4-Foot MBP PS 0.067 0.015 0.034

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.006 0.003 0.005

Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 0.000

Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.022 0.005 0.011

Two-Lamp Normal BF 4-Foot T5 Minibp SO 0.825 0.178 0.407

Two-Lamp 4-Foot T5 MiniBP HO 0.582 0.126 0.288

Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.006 -0.002 -0.003

Four-Lamp Sign Ballasts 4.986 1.069 2.453

Total 6.375 1.365 3.136

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.913 0.235 0.488

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.016 0.007 0.011

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.209 0.261 0.597

Two-Lamp 4-Foot T5 MiniBP HO 0.744 0.161 0.368

Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.136 -0.029 -0.067

Total 2.746 0.635 1.397

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.050 0.270 0.562

Total 1.050 0.270 0.562 * Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total 

energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.

ES.2.9.2 Net Present Value Analysis

DOE calculated NPV as the difference between total savings in operating costs and 

increases in total installed costs in the base case and standards case. DOE calculated savings over 

the life of the product using discount rates of 7- and 3-percent to discount future costs and 

savings to the present. 

Table ES.2.11 and Table ES.2.12 show the NPV results under the existing technologies 

and emerging technologies scenarios. An NPV greater than zero shows that the CSL would 

reduce customer expenditures relative to the base case in present value terms. An NPV less than 

zero indicates that the CSL would result in a net increase in customer expenditures in present 

value terms.

EERE-2007-BT-STD-0016 COMMENT 25
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ES-18

Table ES.2.11 Cumulative NPV Results for Ballasts Under the Existing Technologies, Shift 

Scenario (2014–2044) 

CSL Ballast Product Class Percent NPV Discount*

billion 2008$

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 9.046 18.490

Two-Lamp Normal BF 4-Foot MBP PS 0.276 0.872

Four-Lamp Normal BF 4-Foot MBP IS & RS -1.536 -3.062

Four-Lamp Normal BF 4-Foot MBP PS 0.143 0.459

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.060 0.089

Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000

Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.007 0.049

Two-Lamp Normal BF 4-Foot T5 Minibp SO 3.408 9.204

Two-Lamp 4-Foot T5 MiniBP HO 1.049 2.570

Two-Lamp Low BF 4-Foot MBP IS & RS Residential 0.000 -0.268

Four-Lamp Sign Ballasts 9.900 23.364

Total 22.353 51.770

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 14.931 25.847

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.091 0.134

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 4.366 11.284

Two-Lamp 4-Foot T5 MiniBP HO 1.169 2.762

Two-Lamp Low BF 4-Foot MBP IS & RS Residential 0.000 -0.270

Total 20.557 39.757

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 14.931 25.847

Total 14.945 25.877

* Note that NPV for individual ballast product classes (due to separate regulation) do not sum to equal total NPV 

achieved at the CSLs due to standards-induced substitution effects among ballast types.

EERE-2007-BT-STD-0016 COMMENT 25
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ES-19

Table ES.2.12 Cumulative NPV Results for Ballasts Under the Emerging Technologies, 

Roll-Up Scenario (2014–2044) 

CSL Ballast Product Class Percent NPV Discount

billion 2008$

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.000 0.000

Two-Lamp Normal BF 4-Foot MBP PS 0.181 0.520

Four-Lamp Normal BF 4-Foot MBP IS & RS -1.060 -1.945

Four-Lamp Normal BF 4-Foot MBP PS 0.088 0.256

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.035 0.051

Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000

Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.007 0.049

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.633 4.035

Two-Lamp 4-Foot T5 MiniBP HO 0.822 2.010

Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.012 -0.042

Four-Lamp Sign Ballasts 9.900 23.364

Total 11.594 28.299

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 2.830 5.736

Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.106 0.153

Two-Lamp Normal BF 4-Foot T5 MiniBP SO 2.667 6.345

Two-Lamp 4-Foot T5 MiniBP HO 1.169 2.762

Two-Lamp Low BF 4-Foot MBP IS & RS Residential (T12 Baseline) 0.000 -0.270

Total 6.773 14.725

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 10.189 16.086

Total 10.189 16.086

* Note that NPV for individual ballast product classes (due to separate regulation) do not sum to equal total NPV 

achieved at the CSLs due to standards-induced substitution effects among ballast types.

ES.2.10 Preliminary Manufacturer Impact Analysis

A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of 

energy conservation standards on manufacturers, such as effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs. Potential impacts 

might lead to changes in manufacturing practices for fluorescent lamp ballasts. DOE identified 

potential impacts through interviews with manufacturers and other interested parties. 

DOE identified three key issues for fluorescent lamp ballasts: impacts on profitability; 

product conversion costs/diminishing returns to consumers; and product innovation. See chapter 

12 of the preliminary TSD for details. 

EERE-2007-BT-STD-0016 COMMENT 25
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ES-20

ES.2.11 Other Analyses

The remaining chapters of the preliminary TSD address the analyses to be performed for the 

notice of proposed rulemaking (NOPR): 

The life-cycle cost analysis for subgroups evaluates the effects of energy conservation 

standards on various national subgroups (chapter 11). 

The utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 13).

The employment impact analysis examines the effects of energy conservation standards on 

national employment (chapter 14). 

The environmental assessment examines the effects of energy conservation standards on 

various airborne emissions. 

The regulatory impact analysis examines the national impacts of non-regulatory alternatives 

to mandatory energy conservation standards. 

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE 

especially invites comments or data to improve DOE’s analysis, including information that will 

respond to the following questions and concerns that were raised in response to the framework 

document and in preparation of the preliminary TSD. 

ES.3.1 Test Procedures

Manufacturers have observed non-compliant ballasts that were labeled as compliant in 

the marketplace. DOE requests comments on ways to enhance the certification and enforcement 

procedures for fluorescent lamp ballasts. 

ES.3.2 Scope of Coverage 

In chapter 2, DOE considers including the following ballasts in its scope of coverage: 

(1) ballasts that operate one, two, three, four, five, or six 4-foot medium bipin lamps with 

a rated wattagea

(2) ballasts that operate one, two, three, four, five, or six 2-foot U-shaped lamps with a

rated wattage of 25W or more and an input voltage at or between 120V and 277V; 

 of 25W or more and an input voltage at or between 120V and 277V; 

 

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

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-21

(3) ballasts that operate one or two 8-foot recessed double contact high output lamps with 

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

(4) ballasts that operate one or two 8-foot single pin slimline lamps with a rated wattage 

of 52W or more and an input voltage at or between 120V and 277V; 

(5) ballasts that operate one or two 4-foot miniature bipin standard output lamps with a 

rated wattage of 26W or more and an input voltage at or between 120V and 277V; 

(6) ballasts that operate one, two, three, or four 4-foot miniature bipin high output lamps 

with a rated wattage of 49W or more and an input voltage at or between 120V and 

277V; 

(7) ballasts that operate one, two, three, or four 4-foot medium bipin lamps with a rated 

wattage of 25W or more, an input voltage at or between 120V and 277V, a power 

factor of less than 0.90, and that are designed and labeled for use in residential 

applications; and 

(8) ballasts that operate one, two, three, four, five, or six 8-foot recessed double contact 

high output lamps with an input voltage at or between 120V and 277V, and that 

operate at ambient temperatures of 20 °F or less and are used in outdoor signs. 

 DOE invites comment on its rationale for extending coverage and also its proposed scope 

of coverage. DOE specifically requests comment on its exclusion of dimming ballasts from the 

scope of coverage.

ES.3.3 Product Classes

 DOE considered 10 potential class-setting factors: (1) lamp length, (2) the maximum 

number of lamps operated, (3) ballast factor, (4) lumen package (or lamp output), (5) lamp 

diameter, (6) starting method, (7) market sector, (8) cold temperature operation, (9) input 

voltage, and (10) universal voltage. Using the statutory criteria described above (i.e., type of 

energy consumed or capacity or other performance-related feature affecting efficiency), DOE 

eliminated many of these. DOE defined product classes based on lamp length, lumen package, 

maximum number of lamps operated, starting method, ballast factor, and market sector. These 

class-setting factors created 70 product classes, summarized in Table ES.2.2. DOE seeks 

comments on these product classes – including comments on the appropriate starting method 

definitions to use in the regulatory language and the ranges attributed to high, low, and normal 

ballast factor.

ES.3.4 Technology Options 

DOE identified several technology options to improve the efficiency of a fluorescent 

lamp ballast. DOE invites comment on these options, discussed in preliminary TSD chapter 3. 

ES.3.5 Screening Analysis

 DOE invites comment on the technology option eliminated during the screening analysis. 

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-22

ES.3.6 Candidate Standard Levels for Representative Product Classes

DOE tested many manufacturers’ product offerings for BEF and ballast efficiency to 

determine their efficiency. DOE identified the most prevalent BEF values in the range of 

available products and established CSLs based on those products. Within a given product class, 

no currently available products or working prototypes appear to exist that have a distinguishably 

higher BEF than commercially available ballasts. Therefore, the highest CSL presented, which 

represents the most efficient tier of commercially available ballasts, is the “max-tech” level that 

DOE determined for this preliminary rulemaking. DOE requests comment on its selection of 

representative product classes, baseline ballasts, and the lamp-and-ballast systems chosen to 

represent baseline and increasing efficiency. 

ES.3.7 Maximum Technologically Feasible Ballast 

 Within a given product class, no working products or prototypes appear to exist that have 

a distinguishably higher BEF than commercially available ballasts. Therefore, the highest CSL 

presented, which represents the most efficient tier of commercially available ballasts, is the

“max-tech” level that DOE determined for this preliminary rulemaking. However, DOE presents 

additional research in appendix 5D of the preliminary TSD to explore whether technologies used 

in products similar to ballasts can be used to improve the efficiency of ballasts currently on the 

market. DOE requests comments on the maximum technologically feasible ballast efficiency 

and its associated MSP. 

ES.3.8 Manufacturer Production Costs

To estimate MPCs for fluorescent lamp ballasts, DOE conducted a teardown analysis for 

many high-volume ballasts. Given the large number of available ballasts and the fact that DOE 

was unable to tear down certain ballasts due to physical restrictions (potting), DOE used scaling 

techniques estimate the MPC for those ballasts that it did not tear down. DOE then calculated 

MSPs by applying overhead and manufacturer markups. DOE requests comments on its 

estimates of manufacturer production costs, as well as DOE’s estimates for overhead and the 

manufacturer markup. 

ES.3.9 Candidate Standard Levels for Non-Representative Product Classes

 To determine CSLs for non-representative product classes, DOE tested the BEF of 

certain ballasts in those product classes and compared these values to the representative classes 

to create scaling relationships. These scaling relationships were used to create CSLs for those 

product classes not directly analyzed. DOE requests comments on its scaling methodology and 

the proposed CSLs for fluorescent lamp ballasts in non-representative product classes. 

ES.3.10 Cumulative and Future Regulation 

 DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or 

amended DOE standards and other regulatory actions affecting the same equipment. DOE will 

analyze and consider the impact on manufacturers of multiple, product-specific regulatory 

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-23

actions in the NOPR. DOE invites comment on regulations applicable to ballast manufacturers 

that contribute to their cumulative regulatory burden. 

In addition to existing regulation, several possible upcoming regulations could affect the 

engineering and life-cycle cost analysis for fluorescent lamp ballasts. DOE requests comments 

on how safety requirements for system interconnects, safety requirements for lamp end-of-life 

protection, electromagnetic field requirements, and hazardous material regulation could affect 

the efficiency of commercially available ballasts. DOE also requests information on the cost of 

low and high efficiency ballasts that are expected to be compliant with these regulations so that 

DOE can assess how these requirements may affect payback calculations. 

ES.3.11 Operating Profiles for Energy Use Characterization

To characterize the country’s average use of lamp-and-ballast systems for a typical year, 

DOE developed annual operating hours by sector using data published in the U.S. Lighting 

Market Characterization: Volume I, Residential Energy Consumption Survey, the Commercial 

Building Energy Consumption Survey, and the Manufacturer Energy Consumption Survey. DOE 

assumed a primary sector for each ballast product class analyzed (Table ES.2.6) and applied 

average annual operating hours based on sector (Table ES.2.5). DOE welcomes comments on the 

basis and assignment of these end-use operating profiles for the ballast types covered under this 

rulemaking. See chapter 2 of the preliminary TSD for details. 

ES.3.12 Lighting Controls and Ballast Operating Profiles 

 Except for programmed-start (PS) ballasts operating four-foot medium bipin lamps in the 

commercial sector, DOE did not modify the operating hour data from the U.S. Lighting Market 

Characterization to reflect use of lighting controls for other ballast product classes. Based on its 

market research and feedback from interested parties, DOE assumed that PS ballasts operating 

four-foot medium bipin lamps in the commercial sector are controlled with occupancy sensors, 

resulting in reduced annual operating hours. However, DOE is unsure how it would account for 

lighting controls, as there is uncertainty about which types of control systems are specified in 

practice, and DOE did not receive or identify comprehensive data on the impact of lighting 

controls. DOE invites comments on this issue, as well as details on the use of lighting controls in 

the commercial, industrial, and residential sectors. See chapter 2 of the preliminary TSD for 

details. 

ES.3.13 Price Markups

 In the framework document, DOE solicited comments on typical ballast pricing and

distributor and contractor markups. Unable to obtain any detailed pricing or markup data for the 

preliminary analyses, DOE developed OEM and wholesaler markups using financial data from 

U.S. Securities and Exchange Commission form 10-K reports for publicly owned companies. 

DOE seeks comments on typical markups, as well as ballast pricing data that DOE could use to 

verify the price markups it developed for the preliminary analysis. See chapter 2 of the 

preliminary TSD for details. 

EERE-2007-BT-STD-0016 COMMENT 25
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ES-24

ES.3.14 Electricity Prices for LCC and PBP Analyses

DOE estimates electricity prices for commercial, industrial, and residential consumers 

using Energy Information Administration (EIA) data. DOE received a number of comments on 

the potential effects of energy efficient ballast designs on electricity demand charges and how 

DOE accounts for these effects in its LCC and PBP analyses. DOE’s approach for forecasting 

electricity prices does not include evaluating demand load profiles or allow for quantifying the 

potential impacts on peak demand for electricity from changes in product efficiency. DOE 

requests comments on alternate data sources, methods for quantifying changes in demand 

charges, and their impacts on electricity prices. See chapter 2 of the preliminary TSD for details. 

ES.3.15 Effects of Energy Efficient Design on Ballast Life

DOE received multiple comments on the potential effects of energy efficient design on 

ballast life. Some commenters observed that energy efficient ballasts should operate cooler, 

which would result in longer operating life. Another commenter remarked that ballasts are 

generally operating at higher temperatures due to the trend toward smaller fixtures and ballast 

enclosures. DOE acknowledges the general trend toward smaller fixtures and ballast enclosures, 

and assumed ballast operating temperatures equal to or greater than those for current ballast 

designs, with no extended life for energy efficient ballast designs. DOE welcomes additional 

comments and data on operating lifetimes for energy efficient ballasts. See chapter 2 of the 

preliminary TSD for details. 

ES.3.16 Average Ballast Lifetimes and Failure Distributions

For the LCC/PBP analyses and shipment projections, DOE assumed average ballast 

lifetimes as 15 years (commercial and residential sectors) and 10 years (industrial sector). These 

average values suggest that a majority of ballast failures occur later in the service lifetime. DOE 

seeks comment on the assumed average ballast lifetimes, as well as the distribution of failures 

around the average values. In particular, DOE seeks comment on how many years beyond 

average lifetimes that ballasts potentially remain in service. See chapter 2 of the preliminary 

TSD for details.

ES.3.17 Historical Shipments Data

DOE requested historical ballast and residential fixture shipments data from the National 

Electrical Manufacturers Association (NEMA), but these data were not available for the 

preliminary shipments analysis. Consequently, DOE used data from the U.S. Census Bureau to 

estimate the total historical shipments of each ballast type analyzed, which required 

disaggregating the Census data and adjusting it to include estimated non-NEMA shipments. 

DOE seeks actual, disaggregated ballast and residential fixture shipments data to help verify its 

shipments analysis. See chapter 2 of the preliminary TSD for details. 

EERE-2007-BT-STD-0016 COMMENT 25
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ES-25

ES.3.18 Shipment Trends 

 DOE modeled ballast purchasing events (e.g., replacement and new construction) and 

applied growth rate, replacement rate, and emerging technologies (i.e., solid-state lighting)

penetration rate assumptions to develop annual shipment projections. DOE based future ballast 

shipment trends on manufacturer interviews and market trends identified in the 2009 Lamps 

Rule; DOE assumes that these trends integrate various regulatory and non-regulatory initiatives 

in the lighting marketplace. DOE requests comments on the magnitude and timing of its 

forecasted ballast shipment trends (e.g., rising and declining shipments, plateaus, etc.) as well as 

the impacts of current regulatory initiatives on future ballast shipments. See chapter 2 of the 

preliminary TSD for details. 

ES.3.19 NIA and External Benefits

DOE acknowledges that there may be certain “external” benefits resulting from the 

improved efficiency of ballasts that are not captured by the equipment’s users. These include 

both environmental and energy security-related externalities that are also not already reflected in 

energy prices, such as reduced emissions of greenhouse gases and reduced use of fossil fuels for 

electricity generation. DOE invites comments on the nature and magnitude of such benefits. See

chapter 2 of the preliminary TSD for details. 

ES.3.20 Trial Standard Levels

 For the NOPR, DOE will develop trial standard levels (TSLs) based on the candidate 

standard levels for fluorescent lamp ballasts. DOE is considering several criteria in developing 

the TSLs, including, but not limited to, minimum LCC, maximum NPV, and maximum 

technologically-feasible efficiency. These TSLs may include combinations of CSLs and the 

interaction between product classes such as ballasts that operate 4-foot medium bipin and 8-foot 

single pin slimline fluorescent lamps. From the list of TSLs developed, DOE will select one as 

its proposed standard for the NOPR. DOE invites comment on the criteria it should use as the 

basis for selection of TSLs. 

ES.3.21 Impact on Manufacturers

 DOE requests comment on its identification of key issues and requests data and 

information from interested parties that can assist in evaluating the potential impact on 

manufacturers.

ES.3.22 Valuing Air-Borne Emission Reductions

 DOE will conduct an environmental assessment as part of the next phase of the standards 

rulemaking, the NOPR. The primary environmental effects of energy conservation standards for 

ballasts are to reduce power plant emissions resulting from reduced consumption of electricity. 

DOE will assess these environmental effects by using NEMS-BT to provide key inputs to its 

analysis. The portion of the environmental assessment that will be produced by NEMS-BT 

considers carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), and mercury (Hg). 

EERE-2007-BT-STD-0016 COMMENT 25
Revised on 4/27/2010

ES-26

DOE also plans on monetizing the emission reductions due to standards consistent with methods 

used in recent DOE standards rulemakings pertaining to commercial clothes washers and other 

consumer products and commercial equipment. For example, in the case of CO2, the most recent 

interagency estimates of the potential global benefits resulting from reduced CO2 emissions in 

2010 were $4.7, $21.4, $35.1, and $64.9 per metric ton in 2007 dollars. DOE invites comments 

on the approaches for monetizing the emission savings due to energy conservation standards. 

EERE-2007-BT-STD-0016 COMMENT 25