Revised on 4/27/2010

ES -i 

### EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVIT IES

......................................... 1

ES.2 KEY RESULTS OF THE A NALYSIS

.............................................................................. 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 a nd 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 ................................................. 25Revised on 4/27/2010

ES

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### 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 b y 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 Scenari o (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 Balla sts 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 Lam ps ...................................................................................................... 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

..................................................................................................... 14Revised on 4/27/2010

ES

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### EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMIN ARY ANALYSIS ACTIVIT IES

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

sum mary 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 specialknowledge 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.Revised on 4/27/2010

ES

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

ProcessRevised on 4/27/2010

ES

- 3 

### ES.2 KEY RESULTS OF THE A NALYSIS

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.Revised on 4/27/2010

ES

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### 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 1 3 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 th an 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 informatio n provides data and resource material throughout the analysis.

DOE reviews literature and interview s 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.Revised on 4/27/2010

ES

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### ES.2.3 Screenin g 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 ( BE F), 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 span ned a range of efficiency levels. DOE then developed a cost model that convert ed the bill of material s 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 the se 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

- L amp Normal BF 4

- F oot MBP IS & RS 1.359 1.450 1.535 1.561

Two

- L amp Normal BF 4

- F oot MBP PS 1.418 1.518 N/A N/A

Four

- L amp Normal BF 4

- F oot MBP IS & RS 0.768 0.7 81 N/A N/A

Four

- L amp Normal BF 4

- F oot MBP PS 0.708 0.75 5 N/A N/A

Two

- L amp Normal BF 4

- F oot T5 MiniBP SO 1.309 1. 441 1. 482 N/A

Two

- L amp 4

- F oot T5 MiniBP HO 0.688 0.791 0.8 37 N/A

Two

- L amp Normal BF 8

- F oot SP Slimline 0.797 0.807 N/A N/A

Two

- L amp 8

- F oot RDC HO IS & RS 0.440 0.500 0.549 N/A

Two

- L amp 4

- F oot MBP IS & RS Residential 1.277 1.4 57 1. 492 N/A

Four

- L amp Sign Ballasts 0.196 0.238 N/A N/ARevised on 4/27/2010

ES

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### 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

- L amp Normal BF 4

- F oot MBP IS & RS ( 2. 83 )* (0. 26 ) (1.3 3 )

Two

- L amp Normal BF 4

- F oot MBP PS 3. 51 N/A N/A

Four

- L amp Normal BF 4

- F oot MBP IS & RS 1.3 7 N/A N/A

Four

- L amp Normal BF 4

- F oot MBP PS 3.48 N/A N/A

Two

- L amp Normal BF 4

- F oot T5 MiniBP SO 0.2 4 0.3 7 N/A

Two

- L amp 4

- F oot T5 MiniBP HO 0.2 2 3.1 8 N/A

Two

- L amp Normal BF 8

- F oot SP Slimline 6. 92 N/A N/A

Two

- L amp 8

- F oot RDC HO IS & RS 0.3 4 1.5 8 N/A

Two

- L amp 4

- F oot MBP IS & RS Residential 3.40 6.45 N/A

Four

- L amp 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- and

ballast 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 clas s that DOE is considering in this rulemaking.Revised on 4/27/2010

ES

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### 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.Revised on 4/27/2010

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 s ells 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.



### S ee chapter 2 and chapter 7 of the preliminary TSD for detail s.

ES.2.7 Life -Cycle Cost and Payback Period Analyses

An energy conservation standard usually result s in an increase in purchase price and a decrease in operating expenses. DOE analyzed the net effect of a mended 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

BALLASTSRevised on 4/27/2010

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- than

baseline 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) analys es; chapter 8 provides a detailed description of the se analys es 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/aRevised on 4/27/2010

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 manufacture r cash flows for each ballast product class under consideration. DOE followed a three- step processRevised on 4/27/2010

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 ballas t 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 emer ging 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 bal last

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 Sc enarios) 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 2044Shipments

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 ForecastRevised 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 2044Shipments



### 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 2044Shipments



### Year

8

- foot T8 Slimline Base

- Case Forecast 8

- foot T12 Slimline Base

- Case ForecastRevised 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 Eme rging 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 2044Shipments

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 ForecastRevised on 4/27/2010

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 2044Shipments



### 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 2044Shipments



### Year

8

- foot T12 HO Base

- Case ForecastRevised on 4/27/2010

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 f or 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 techn ologies 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.Revised on 4/27/2010

ES

- 16 

### Table ES.2.9 Cumulative National Energy Savings for Ballasts U nder 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 Mini BP 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 Mini BP SO 2.264 0.422 1.050

Two

- Lamp 4

- Foot T5 Mini BP 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.Revised on 4/27/2010

ES

- 17 

### Table ES.2.10 Cumulative National Energy Savings for Ballasts U nder 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 scenario s. 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.Revised on 4/27/2010

ES

- 18 

### Table ES.2.11 Cumulative NPV Results for Ballasts U nder the Existing Technologies, Shift Scenario (2014–2044)

CSL Ball ast Product Class Percent NPV Discount *

billion 2008$

7 3

1 Two

- L amp 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 Mini BP 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 Mini BP SO 4.366 11.284

Two

- Lamp 4

- Foot T5 Mini BP 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.Revised on 4/27/2010

ES

- 19 

### Table ES.2.12 Cumulative NPV Results for Ballasts U nder the Emerging Technologies,

Roll -Up Scenario (2014–2044)

CSL Ballast Product Class Percent NPV Discount billion 2008$

7 3

1 Two

- L amp Normal BF 4

- F oot MBP IS & RS 0.000 0.000

Two

- L amp Normal BF 4

- F oot MBP PS 0.181 0.520

Four

- L amp Normal BF 4

- F oot MBP IS & RS

- 1.060

- 1.945

Four

- L amp Normal BF 4

- F oot MBP PS 0.088 0.256

Two

- L amp Normal BF 8

- F oot RDC HO IS & RS 0.035 0.051

Two

- L amp Normal BF 8

- F oot SP Slimline (T12 Baseline) 0.000 0.000

Two

- L amp Normal BF 8

- F oot SP Slimline (T8 Baseline) 0.007 0.049

Two

- L amp Normal BF 4

- F oot T5 MiniBP SO 1.633 4.035

Two

- L amp 4

- F oot T5 MiniBP HO 0.822 2.010

Two

- L amp Low BF 4

- F oot MBP IS & RS Residential

- 0.012

- 0.042

Four

- L amp Sign Ballasts 9.900 23.364

Total 11.594 28.299

2 Two

- L amp Normal BF 4

- F oot MBP IS & RS 2.830 5.736

Two

- L amp Normal BF 8

- F oot RDC HO IS & RS 0.106 0.153

Two

- L amp Normal BF 4

- F oot T5 MiniBP SO 2.667 6.345

Two

- L amp 4

- F oot T5 MiniBP HO 1.169 2.762

Two

- L amp Low BF 4

- F oot MBP IS & RS Residential (T12 Baseline) 0.000

- 0.270

Total 6.773 14.725

3 Two

- L amp Normal BF 4

- F oot 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 prelimin ary 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 impac ts 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.Revised on 4/27/2010

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 imp act 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 PUBL IC 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 wattage a


### (2) ballasts that operate one, two, three, four, five, or six 2-foot U-shaped l amps with a rated wattage of 25 W 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.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 inpu t 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 request s 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 (1 0) 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

c lass

- 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 com ment 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.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 the ir efficiency. DOE identif ied 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 efficienc y.

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 M PCs 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 cost s , as well as DOE’s estimate s 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 value s 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 la mp 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. D OE will analyze and consider the impact on manufacturers of multiple, product- specific regulatoryRevised 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 additi on 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 lam p 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 y ear, 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 c overed under this rulemaking. See chapter 2 of the preliminary TSD for details

.

ES.3.12 Lighting Controls and Ballast Operating Profiles

E xcept 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- foo t 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 system s 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 se ctors. 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 comment s 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

.Revised on 4/27/2010

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 effi ciency. 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 r eceived 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 balla sts 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 gr eater 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 Aver age 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

aver age 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

.Revised on 4/27/2010

ES

- 25 

### ES.3.18 Shipment Trend s

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 bas ed 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 o n 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 detai ls

.

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 ex ternalities 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 (CO 2 

### ), sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), and mercury (Hg).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 com mercial clothes washers and other consumer products and commercial equipment . For example, in the case of CO 2 

### , the most recent interagency estimates of the potential global benefits resulting from reduced CO 2 

### 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.