5-i 

CHAPTER 5 ENGINEERING ANALYSIS

 

TABLE OF CONTENTS

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 METRIC .......................................................................................................................... 5-1

5.3 METHODOLOGY OVERVIEW .................................................................................... 5-2

5.4 EFFICIENCY LEVELS................................................................................................... 5-4

5.4.1 General Methodology .......................................................................................... 5-4

5.4.2 Eight-foot HO IS and RS Product Class .............................................................. 5-4

5.4.3 Conversion of Existing BEF Standards to BLE ................................................... 5-5

5.4.4 Maximum Technologically Feasible Efficiency Levels ...................................... 5-6

5.5 MEASUREMENT VARIATION AND COMPLIANCE REQUIREMENTS ............... 5-6

5.6 PRICING ANALYSIS OVERVIEW .............................................................................. 5-6

5.6.1 Teardown-sourced MSPs ..................................................................................... 5-7

5.6.1.1 Manufacturer Production Costs ............................................................... 5-7

5.6.1.2 Manufacturer Markup .............................................................................. 5-9

5.6.2 Blue book-sourced MSPs ................................................................................... 5-12

5.6.3 Manufacturer-sourced MSPs ............................................................................. 5-12

5.6.4 Final MSP .......................................................................................................... 5-12

5.7 REPRESENTATIVE PRODUCT CLASSES ............................................................... 5-13

5.8 REPRESENTATIVE BALLAST TYPES ..................................................................... 5-13

5.9 INSTANT AND RAPID START BALLASTS THAT OPERATE TWO FOUR-FOOT 

MBP AND TWO-FOOT U-SHAPED LAMPS IN THE COMMERCIAL SECTOR .. 5-15

5.9.1 Baseline Models ................................................................................................. 5-15

5.9.2 Efficiency Levels ............................................................................................... 5-17

5.9.3 Lamp and Ballast Prices..................................................................................... 5-19

5.9.4 Results ................................................................................................................ 5-20

5.10 INSTANT AND RAPID START BALLASTS THAT OPERATE FOUR FOUR-FOOT 

MBP AND TWO-FOOT U-SHAPED LAMPS IN THE COMMERCIAL SECTOR .. 5-24

5.10.1 Baseline Models ................................................................................................. 5-24

5.10.2 Efficiency Levels ............................................................................................... 5-25

5.10.3 Lamp and Ballast Prices..................................................................................... 5-26

5.10.4 Results ................................................................................................................ 5-27

5.11 INSTANT AND RAPID START BALLASTS THAT OPERATE TWO EIGHT-FOOT 

SP SLIMLINE LAMPS ................................................................................................. 5-29

5.11.1 Baseline Models ................................................................................................. 5-29

5.11.2 Efficiency Levels ............................................................................................... 5-30

5.11.3 Lamp and Ballast Prices..................................................................................... 5-32

5.11.4 Results ................................................................................................................ 5-32

5.12 INSTANT START AND RAPID START BALLASTS THAT OPERATE TWO FOURFOOT MBP AND TWO-FOOT U-SHAPED LAMPS IN THE RESIDENTIAL SECTOR

........................................................................................................................................ 5-35

5.12.1 Baseline Models ................................................................................................. 5-35

5.12.2 Efficiency Levels ............................................................................................... 5-36
5-ii

5.12.3 Lamp and Ballast Prices..................................................................................... 5-38

5.12.4 Results ................................................................................................................ 5-39

5.13 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT MBP 

AND TWO-FOOT U-SHAPED LAMPS ...................................................................... 5-42

5.13.1 Baseline Models ................................................................................................. 5-42

5.13.2 Efficiency Levels ............................................................................................... 5-43

5.13.3 Lamp and Ballast Prices..................................................................................... 5-44

5.13.4 Results ................................................................................................................ 5-45

5.14 PROGRAMMED START BALLASTS THE OPERATE FOUR FOUR-FOOT MBP 

AND FOUR TWO-FOOT U-SHAPED LAMPS .......................................................... 5-47

5.14.1 Baseline Models ................................................................................................. 5-47

5.14.2 Efficiency Levels ............................................................................................... 5-48

5.14.3 Lamp and Ballast Prices..................................................................................... 5-49

5.14.4 Results ................................................................................................................ 5-50

5.15 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP 

T5 SO LAMPS ............................................................................................................... 5-52

5.15.1 Baseline Models ................................................................................................. 5-52

5.15.2 Efficiency Levels ............................................................................................... 5-53

5.15.3 Lamp and Ballast Prices..................................................................................... 5-54

5.15.4 Results ................................................................................................................ 5-55

5.16 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP 

T5 HO LAMPS .............................................................................................................. 5-57

5.16.1 Baseline Models ................................................................................................. 5-57

5.16.2 Efficiency Levels ............................................................................................... 5-58

5.16.3 Lamp and Ballast Prices..................................................................................... 5-59

5.16.4 Results ................................................................................................................ 5-60

5.17 BALLASTS THAT OPERATE TWO EIGHT-FOOT RDC HO LAMPS ................... 5-62

5.17.1 Baseline Models ................................................................................................. 5-62

5.17.2 Efficiency Levels ............................................................................................... 5-63

5.17.3 Lamp and Ballast Prices..................................................................................... 5-65

5.17.4 Results ................................................................................................................ 5-65

5.18 BALLASTS THAT OPERATE FOUR EIGHT-FOOT HO LAMPS IN COLD 

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS ..................................... 5-68

5.18.1 Baseline Models ................................................................................................. 5-68

5.18.2 Efficiency Levels ............................................................................................... 5-69

5.18.3 Lamp and Ballast Prices..................................................................................... 5-70

5.18.4 Results ................................................................................................................ 5-71

5.19 SCALING TO PRODUCT CLASSES NOT ANALYZED .......................................... 5-73

5.20 EFFICIENCY LEVEL SUMMARY ............................................................................. 5-73

5.21 MSP COMPARISON .................................................................................................... 5-76

LIST OF TABLES

Table 5.1 Existing BEF Standards Converted to BLE ................................................................. 5-5

Table 5.2 Ballast Types for Teardowns ....................................................................................... 5-9

Table 5.3 Gross Profit Margin for Four Fluorescent Lamp Ballast Manufacturers*................. 5-11
5-iii

Table 5.4 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts ........................... 5-11

Table 5.5 Representative Product Classes ................................................................................. 5-13

Table 5.6 Baseline Ballasts for the 2-lamp MBP IS and RS Representative Ballast Type ....... 5-16

Table 5.7 Lamps for Use with F32T8 and F34T12 Ballasts ...................................................... 5-17

Table 5.8 Summary of ELs for Two-Lamp MBP IS and RS Ballasts ...................................... 5-18

Table 5.9 2-Lamp 4-Foot MBP Commercial Ballasts in the IS and RS Representative Ballast 

Type ............................................................................................................................... 5-19

Table 5.10 Summary of the Manufacturing Selling Prices for the 2-Lamp MBP IS and RS 

Commercial Representative Ballast Type ...................................................................... 5-20

Table 5.11 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps ............................. 5-20

Table 5.12 Two-lamp MBP IS and RS Representative Ballast Type with F32T8 Baseline ..... 5-22

Table 5.13 Two-lamp MBP IS and RS Representative Ballast Type with F34T12 Baseline ... 5-23

Table 5.14 Baseline Ballast for the 4-lamp MBP IS and RS Representative Ballast Type ....... 5-24

Table 5.15 Lamp for Use with F32T8 Ballasts .......................................................................... 5-25

Table 5.16 Summary of ELs for Four-lamp MBP IS and RS Ballasts ...................................... 5-25

Table 5.17 Ballast Designs for the 4-lamp MBP IS and RS Representative Ballast Type ........ 5-26

Table 5.18 Summary of the Manufacturing Selling Price for the 4-lamp MBP IS and RS 

Representative Ballast Type .......................................................................................... 5-27

Table 5.19 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps ............................. 5-27

Table 5.20 Four-Lamp MBP IS and RS Representative Ballast Type with F32T8 Baseline .... 5-28

Table 5.21 Baseline Ballasts for the Eight-Foot SP Slimline Representative Ballast Type ...... 5-30

Table 5.22 Lamps for Use with F96T8 and F96T12/ES Ballasts .............................................. 5-30

Table 5.23 Summary of ELs for Eight-foot SP Slimline Ballasts ............................................. 5-31

Table 5.24 Ballast Designs for the Eight-Foot SP Slimline Representative Ballast Type ........ 5-32

Table 5.25 Manufacturing Selling Prices for the Eight-Foot SP Slimline Representative Ballast 

Type ............................................................................................................................... 5-32

Table 5.26 Retail Prices for Eight-Foot SP Slimline Fluorescent Lamps................................. 5-32

Table 5.27 Eight-Foot SP Slimline Representative Ballast Type with F96T12/ES Baseline .... 5-33

Table 5.28 Eight-Foot SP Slimline Representative Ballast Type with F96T8 Baseline ........... 5-34

Table 5.29 Baseline Ballasts for the Residential Representative Ballast Type ......................... 5-36

Table 5.30 Lamps for Use with F32T8 and F34T12 Ballasts .................................................... 5-36

Table 5.31 Summary of ELs for Residential Ballasts ................................................................ 5-37

Table 5.32 Ballast Designs for the Residential Representative Ballast Type ............................ 5-38

Table 5.33 Manufacturing Selling Prices for the Residential Representative Ballast Type ..... 5-38

Table 5.34 Retail Prices for Four-Foot MBP Fluorescent Lamps ............................................ 5-39

Table 5.35 Residential Representative Ballast Type with F34T12 Baseline ............................. 5-40

Table 5.36 Residential Representative Ballast Type with F32T8 Baseline ............................... 5-40

Table 5.37 Baseline Units for the 2-lamp MBP PS Representative Ballast Type ..................... 5-42

Table 5.38 Lamps for Use with F32T8 Ballasts ........................................................................ 5-42

Table 5.39 Summary of ELs for Two-Lamp MBP PS Ballasts ................................................ 5-43

Table 5.40 Ballast Designs for the 2-lamp MBP PS Representative Ballast Type.................... 5-44

Table 5.41 Summary of the Manufacturing Selling Prices for the 2-lamp MBP PS Representative 

Ballast Type ................................................................................................................... 5-44

Table 5.42 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps ............................. 5-45

Table 5.43 Two-lamp MBP PS Representative Ballast Type .................................................... 5-46

Table 5.44 Baseline Ballasts for the 4-lamp MBP PS Representative Ballast Type ................. 5-47
5-iv

Table 5.45 Lamps for Use with F32T8 Ballasts ........................................................................ 5-47

Table 5.46 Summary of ELs for Four-lamp MBP PS Ballasts .................................................. 5-48

Table 5.47 Ballast Designs for the 4-lamp MBP PS Representative Ballast Type.................... 5-49

Table 5.48 Summary of the Manufacturing Selling Price for the 4-lamp MBP PS Representative 

Ballast Type ................................................................................................................... 5-50

Table 5.49 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps ............................. 5-50

Table 5.50 Four-Lamp MBP PS Representative Ballast Type with F32T8 Baseline ............... 5-51

Table 5.51 Baseline Ballast for Four-Foot T5 MiniBP SO Representative Ballast Type ......... 5-52

Table 5.52 Lamps for Use with F28T5 Ballasts ........................................................................ 5-53

Table 5.53 Summary of ELs for 4-foot T5 SO Ballasts ............................................................ 5-53

Table 5.54 Ballast Designs for the Four-Foot T5 MiniBP SO Representative Ballast Type .... 5-54

Table 5.55 Manufacturing Selling Prices for the Four-Foot T5 MiniBP SO Representative 

Ballast Type ................................................................................................................... 5-55

Table 5.56 Retail Prices for Four-Foot MiniBP SO Fluorescent Lamps .................................. 5-55

Table 5.57 Four-Foot T5 MiniBP SO Representative Ballast Type with F28T5 Baseline ....... 5-56

Table 5.58 Baseline Ballast for the Four-Foot T5 MiniBP HO Representative Ballast Type ... 5-57

Table 5.59 Lamps for Use with F54T5HO Ballasts .................................................................. 5-58

Table 5.60 Summary of ELs for Four-foot T5 HO Ballasts ...................................................... 5-58

Table 5.61 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Ballast Type .... 5-59

Table 5.62 Manufacturing Selling Prices for the Four-Foot T5 MiniBP HO Representative 

Ballast Type ................................................................................................................... 5-60

Table 5.63 Retail Prices for Four-Foot MiniBP HO Fluorescent Lamps ................................. 5-60

Table 5.64 Four-Foot T5 MiniBP HO Representative Ballast Type with F54T5HO Baseline . 5-61

Table 5.65 Baseline Ballasts for the Eight-Foot RDC HO Representative Ballast Type .......... 5-63

Table 5.66 Lamps for Use with F96T8HO and F96T12HO/ES Ballasts .................................. 5-63

Table 5.67 Summary of ELs for Eight-foot RDC HO Ballasts ................................................ 5-64

Table 5.68 Ballast Designs for the Eight-Foot RDC HO Representative Ballast Type ............ 5-65

Table 5.69 Manufacturing Selling Prices for the Eight-Foot RDC HO Representative Ballast 

Type ............................................................................................................................... 5-65

Table 5.70 Retail Prices for Eight-Foot RDC HO Fluorescent Lamps..................................... 5-65

Table 5.71 Eight-Foot RDC HO Representative Ballast Type with F96T12HO/ES Baseline .. 5-67

Table 5.72 Eight-Foot RDC HO Representative Ballast Type with F96T8HO Baseline .......... 5-67

Table 5.73 Baseline Ballasts for the Sign Ballast Representative Ballast Type ........................ 5-68

Table 5.74 Lamps for Use with Cold Temperature F96T12HO Ballasts .................................. 5-69

Table 5.75 Summary of ELs for Sign Ballasts ......................................................................... 5-69

Table 5.76 Ballast Designs for the Sign Ballast Representative Ballast Type .......................... 5-70

Table 5.77 Manufacturing Selling Prices for the Sign Ballast Representative Ballast Type ... 5-71

Table 5.78 Retail Prices for Eight-Foot HO Cold Temperature Fluorescent Lamps ................ 5-71

Table 5.79 Sign Ballast Representative Ballast Type with F96T12HO Baseline ...................... 5-72

Table 5.80 Summary of ELs for the 8-foot HO PS Product Class ............................................ 5-73

Table 5.81 Efficiency Level Equations With Variation Reduction ........................................... 5-73

Table 5.82 Efficiency Level Equations Without Variation Reduction ...................................... 5-74

Table 5.83 Summary of MSP Data ............................................................................................ 5-76
5-v 

LIST OF FIGURES

Figure 5.1 Manufacturer Selling Price ......................................................................................... 5-7

Figure 5.2 Efficiency Levels for the 2-lamp MBP IS and RS Representative Ballast Type ..... 5-19

Figure 5.3 Efficiency Levels for the 4-lamp MBP IS and RS Representative Ballast Type ..... 5-26

Figure 5.4 Efficiency Levels for the Eight-Foot SP Slimline Representative Ballast Type ...... 5-31

Figure 5.5 Efficiency Levels for the Residential Representative Ballast Type ......................... 5-38

Figure 5.6 Efficiency Levels for the 2-lamp MBP PS Representative Ballast Type ................. 5-44

Figure 5.7 Efficiency Levels for the 4-lamp MBP PS Representative Ballast Type ................. 5-49

Figure 5.8 Efficiency Levels for the Four-Foot T5 MiniBP SO Representative Ballast Type .. 5-54

Figure 5.9 Efficiency Levels for the Four-Foot T5 MiniBP HO Representative Ballast Type . 5-59

Figure 5.10 Efficiency Levels for the Eight-Foot RDC HO Representative Ballast Type ........ 5-64

Figure 5.11 Efficiency Levels for the Sign Ballast Representative Ballast Type ...................... 5-70

Figure 5.12 IS and RS Product Class ......................................................................................... 5-74

Figure 5.14 Eight-foot HO Product Class .................................................................................. 5-75

Figure 5.16 Two-lamp MBP IS and RS Representative Ballast Type MSP Data ..................... 5-77

Figure 5.17 2-lamp MBP IS and RS Representative Ballast Type MSP Data .......................... 5-78

Figure 5.18 8-foot SP Slimline Representative Ballast Type MSP Data ................................... 5-78
5-1 

CHAPTER 5 ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed an engineering analysis to establish 

the relationship between the manufacturer production cost (MPC) and the energy efficiency of 

fluorescent lamp ballasts (hereafter “ballasts”). The relationship between the MPC and energy 

efficiency, or the cost-efficiency relationship, serves as the basis for cost-benefit calculations for 

individual customers, manufacturers, and the Nation. This section provides an overview of the 

engineering analysis, discusses the representative product classes, establishes baseline unit 

specifications for those product classes, discusses incremental efficiency levels, discusses the 

analysis and results for the representative product classes, and establishes a scaling methodology 

to those product classes not analyzed. 

The primary inputs of the engineering analysis are the design options from the screening 

analysis (technical support document (TSD) chapter 4). Additional inputs include cost and 

efficiency data derived from the teardown analysis and test data. The primary output of the 

engineering analysis is a set of cost-efficiency curves. In a subsequent life-cycle cost (LCC) 

analysis (TSD chapter 8), DOE used the industry cost-efficiency curves to determine customer 

prices for each product analyzed in the engineering analysis by applying the appropriate 

distribution channel markups. 

5.2 METRIC

In the fluorescent lamp ballast active mode test procedure supplementary notice of 

proposed rulemaking (SNOPR), DOE proposed a new metric for describing the performance of a 

fluorescent lamp ballast called ballast luminous efficiency (BLE). After the compliance date of 

any standards promulgated by this fluorescent lamp ballast standards rulemaking, ballasts would 

be tested using the new BLE procedure, not the existing BEF procedure. Information on the 

active mode test procedure can be found on DOE’s website.a

Ballast luminous efficiency means the total fluorescent lamp arc power divided by the 

fluorescent lamp ballast input power multiplied by the appropriate frequency adjustment factor. 

BLE describes the percentage of ballast input power that is used in the lamp column to produce 

light.b This percentage is then multiplied by a frequency adjustment factor depending on the 

frequency at which a ballast operates a lamp. Low-frequency operation of a lamp produces fewer 

lumens per lamp arc watt than high-frequency operation, so DOE uses an adjustment factor to 

account for the decrease in system efficacy. In general, the BLE metric results in reduced 

measurement variation, reduced testing burden, and a more straightforward efficiency metric 

than the existing BEF metric and test procedure. 

 

a DOE’s website for fluorescent lamp ballasts can be found at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html. b Power delivered to the lamp cathodes (filaments) is not included in the output measurement and is considered a 

loss.
5-2 

5.3 METHODOLOGY OVERVIEW

DOE typically structures its engineering analysis around one of three methodologies: (1) 

the design-option approach, which calculates the incremental cost of adding specific design 

options to the baseline model; (2) the efficiency-level approach, which calculates the relative 

costs of achieving increases in energy efficiency levels, without regard to the particular design 

options used to achieve such increases; and/or (3) the reverse engineering cost-assessment 

approach, which involves a “bottom-up” manufacturing cost assessment based on a detailed bill 

of materials (BOM) derived from teardowns of products being analyzed. Deciding which 

methodology to use for the engineering analysis depends on the product, the technologies under 

study, and any historical data DOE can draw upon. To establish the industry cost-efficiency 

curves for ballasts, DOE used both the efficiency-level approach to identify incremental 

improvements in efficiency for each product and the cost-assessment approach to develop a cost 

for each efficiency level. 

DOE generally follows five steps in the engineering analysis:

Determine Representative Product Classes: DOE first reviews covered ballasts and the 

associated product classes. When multiple product classes exist, DOE selects certain classes as 

“representative” and concentrates its analytical effort on these. DOE selects representative 

product classes primarily because of their high market volumes. For those product classes it does 

not analyze, DOE extrapolates the efficiency levels (ELs) from representative product classes to 

other product classes. 

Select Baseline Ballasts: Within the representative product classes, DOE analyzes 

representative ballast types. For each representative ballast type, DOE establishes baseline 

ballasts. Generally, a baseline ballast is a commercially available ballast that just meets existing 

Federal energy conservation standards and provides basic consumer utility. The baseline serves 

as a reference point for each representative ballast type, against which DOE measures changes 

from potential amended energy conservation standards. To determine energy savings and 

changes in price, DOE compares each higher energy-efficiency level with the baseline unit. 

If no standard exists for that specific ballast, the baseline ballast represents the typical 

ballast sold within a representative ballast type with the lowest ballast luminous efficiency. To 

determine the BLE, DOE tests a range of ballasts from multiple manufacturers. Appendix 5C 

presents these test results. DOE selects specific characteristics such as starting method, ballast 

factor (BF), and input voltage to characterize the most common ballast. DOE also selects 

multiple baseline ballasts for some representative ballast types to ensure consideration of 

different consumer economics. 

Select More Efficient Lamp-and-Ballast Designs: DOE selects commercially available 

ballasts with higher BLEs as replacements for each baseline ballast in the representative ballast 

types by considering the design options identified in the technology assessment and screening 

analysis (TSD chapter 4). DOE can identify many of the distinguishing design options associated 

with each ballast. However, at some levels, these design options cannot be identified by the 

product number or catalog description, and therefore are assumed to be used in the ballast to 

achieve a higher BLE. In identifying more efficient substitutes, DOE uses a database of 
5-3 

commercially available ballasts. DOE then tests these ballasts to establish their appropriate BLE. 

Appendix 5C presents these test results. All BLE values were calculated according to the method 

proposed in the active mode test procedure SNOPR. 

Because fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE 

considers properties of the entire lamp and ballast system in the engineering analysis. Though 

ballasts are capable of operating several different lamp wattages, DOE chooses the most 

common fluorescent lamp used with each ballast for analysis. DOE develops the engineering 

analysis based on two substitution cases. In the first case, the consumer is not allowed to change 

the spacing of the fixture and therefore replaces one baseline ballast with a more efficient ballast. 

In this case, light output is maintained to within 10 percent of the baseline system lumen output.c

In the second case, the consumer is allowed to change the spacing of the fixture. Therefore, the 

consumer either purchases more or fewer ballasts to maintain light output and DOE normalizes 

the light output relative to the baseline ballast. 

Determine Efficiency Levels. DOE develops ELs based on three factors: (1) the design 

options associated with the specific ballasts studied; (2) the ability of ballasts operating lamps 

across different lamp wattages to comply with the EL of a given product class; and (3) the 

maximum technologically feasible efficiency level. Therefore, DOE’s efficiency levels are based 

upon test data collected from products currently on the market. As discussed in section 5.4, DOE 

developed efficiency levels using an equation that relates the lamp arc power operated by a 

ballast to a ballast luminous efficiency. 

Conduct Price Analysis. DOE generates a bill of materials by disassembling multiple 

manufacturers’ ballasts that span a range of efficiency levels for each of the representative ballast 

types. The BOMs describe the product in detail, including all manufacturing steps required to 

make and/or assemble each part. DOE then develops a cost model that converts the BOMs and 

efficiency levels into MPCs. By applying derived manufacturer markups to the MPCs, DOE 

calculates the manufacturer selling prices (MSPs)d

 and constructs industry cost-efficiency 

curves. 

DOE was not able to generate a BOM for all ballasts in this engineering analysis. In these 

cases, DOE evaluated blue book and retail prices for those ballasts and estimated an MSP for 

each one. For fluorescent lamps, DOE referenced the retail price for those lamps in the 

rulemaking for general service fluorescent and incandescent reflector lamps (hereafter “the 2009 

Lamps Rule”).e

The sections that follow discuss how DOE applies this methodology to each product class 

to create the engineering analysis and the methodology DOE used to develop ballast prices.

 

c In some instances (e.g., when switching from T12 to T8 ballasts), light output slightly exceeds these limits. These 

instances are discussed in more depth in the appropriate sections below. d The MSP is the price at which the manufacturer can recover all production and non-production costs and earn a 

profit. Non-production costs include selling, general, and administration (SG&A) costs, the cost of research and 

development, and interest.

e The final rule for general service fluorescent and incandescent reflector lamps was published in the Federal 

Register on July 14, 2009. It is available at http://edocket.access.gpo.gov/2009/pdf/E9-15710.pdf.
5-4 

5.4 EFFICIENCY LEVELS

5.4.1 General Methodology 

For the NOPR, DOE sought to determine whether developing an equation that relates 

total lamp arc power to BLE could be an effective means of setting energy conservation 

standards for fluorescent lamp ballasts. DOE tested many different types of ballasts from various 

manufacturers which included extensive testing of the representative ballast types. DOE tested 

fivef samples for ballasts included in the representative ballast type categories and three samples 

for non-representative ballast types. After compiling the test data, DOE plotted BLE versus total 

lamp arc power for both standard and high efficiency product lines from multiple manufacturers. 

DOE observed distinct groupings when comparing a single manufacturer’s high and standard 

efficiency product families.

After developing several regression lines, DOE found a logarithmic relationship best 

modeled the observed trend between total lamp arc power and BLE. A logarithmic relationship 

has a positive slope that is largest (steepest) at low lamp arc power levels and has a decreasing 

slope with increasing lamp power. Furthermore, the use of a natural logarithm (ln) to relate total 

lamp arc power to BLE is consistent with current energy conservation standards for external 

power supplies (which also use an equation to define efficiency as a function of output power). 

Power supplies perform a similar power conversion function as fluorescent lamp ballasts. 

Next, DOE plotted curves that aligned with certain key divisions in product offerings. 

Using an equation of the form BLE = coefficient * ln (total lamp arc power) + constant, DOE 

adjusted the coefficient and constant to delineate different efficiency levels. In general, DOE 

found that ballasts that generate a total lamp arc power of 50 watts or less had a greater range of 

efficiency than ballasts that operated a total lamp arc power of 50 watts or more. DOE also found 

that the more efficient ballast product lines generally had a reduced (flatter) slope than the 

standard efficiency products. To reflect this observation, DOE decreased the coefficient of the 

more stringent EL equations and increased the coefficient of the less stringent EL equations. 

Based on analysis of test data for representative ballast types, DOE identified certain natural 

divisions in BLE. DOE then generated curves that corresponded to these divisions. 

After developing EL equations based on the average BLE of the tested samples, DOE 

applied a reduction to account for testing variation. As described in section 5.5, DOE applied a 

0.8 percent reduction to the EL equations to account for lab-to-lab variation and compliance 

requirements. DOE presents both sets of the equations in sections 5.9 through 5.19. The energy 

conservation standard proposal uses the EL equations with the 0.8 percent reduction. 

5.4.2 Eight-foot HO IS and RS Product Class

Because the ballasts tested in the 8-foot RDC HO IS and RS product class operate a 

narrow range of lamp arc powers (about 140W to 150W), DOE did not develop the shape 

(coefficient) of the EL equations using the 8-foot HO IS and RS test data. Instead, DOE used the 

 

f Some ballasts in the representative ballast type categories were tested with less than five, but at least three samples. 

This was because certain models were placed on backorder due to limited supply/production.
5-5 

coefficient of the EL equation for the sign ballast product class because this data set represented 

the most similar ballast category in terms of lamp type operated and lamp arc power.

5.4.3 Conversion of Existing BEF Standards to BLE 

When selecting a baseline unit for a representative ballast type with an existing energy 

conservation standard, DOE uses the ballast with a measured BLE that just meets the existing 

standard. Because DOE proposes to set standards using the BLE metric, DOE converted the 

existing BEF standards to BLE so that it could compare the measured BLE values to the 

standard. Using a relationship between BLE and BEF, DOE converted the existing BEF 

standards to BLE. 

First, DOE determined that the existing BEF standard corresponded to two BLE values: 

one for low-frequency ballasts and a second for high-frequency ballasts. For low-frequency 

ballasts, DOE multiplied BEF by the number of lamps assigned to the standard, by the lowfrequency reference lamp arc power included in the fluorescent lamp ballast test procedure 

SNOPR (75 FR 71570, 71583 (Nov. 24, 2010)), an adjustment factor, and then divided by 100 as 

shown in the following equation: 

BLE = BEF * Number of Lamps * Reference Lamp Arc Power * Adjustment Factor / 100 

Inclusion of the adjustment factor in the correlation is necessary because the BLE metric is equal 

to lamp arc power divided by ballast input power and multiplied by the appropriate adjustment 

factor for each ballast type. The results of this conversion are listed in Table 5.1. The conversion 

provides a good estimate of the corresponding BLE standard for the existing BEF standards. 

However, depending on testing variation, a ballast’s BF, and other electrical characteristics, 

measured BLE values could be slightly different than predicted by the conversion equation. For 

example, a ballast could just meet the BEF standard but be non-compliant with the calculated 

BLE standard. 

Table 5.1 Existing BEF Standards Converted to BLE 

Application for 

operation of

BEF 

Standard

Equivalent BLE

Low Freq High Freq

One F40T12 lamp 2.29 80.4 83.2

Two F40T12 lamps 1.17 82.1 85.0

Two F96T12 lamps 0.63 85.1 89.7

Two F96T12/HO 

lamps 0.39 74.4 78.0 

One F34T12 lamp 2.61 75.2 77.8

Two F34T12 lamps 1.35 77.8 80.5

Two F96T12/ES lamps 0.77 83.9 88.4

Two F96T12/HO/ES 

lamps 0.42 68.0 71.3 
5-6 

5.4.4 Maximum Technologically Feasible Efficiency Levels 

The most stringent EL in each product class represents the maximum technologically 

feasible level of efficiency identified by DOE. All max-tech ELs were developed based on 

commercially available ballasts that DOE purchased and tested. DOE developed the equations to 

just allow the most efficient tested units that are technologically feasible for a sufficient diversity 

of products (spanning several ballast factors, number of lamps per ballast, and types of lamps 

operated) within each product class. However, in an advanced technology scenario (discussed in 

appendix 5F), DOE explores the potential for ballasts in the IS and RS product class to reach an 

even higher level of efficiency. For the advanced technology scenario DOE developed an EL 

based on the most efficient 2-lamp slimline and 4-lamp 4-foot MBP ballasts tested, and assumed 

2-lamp 4-foot MBP (commercial and residential) ballasts could be redesigned to meet this level.

5.5 MEASUREMENT VARIATION AND COMPLIANCE REQUIREMENTS

Like many test procedures, the proposed fluorescent lamp ballast test procedure (75 FR 

71570, (Nov. 24, 2010)) yields slightly different results when testing a unit at different 

laboratories or during repeated measures within the same laboratory. For the representative 

ballast types analyzed in this NOPR, DOE tested five samples of each model number and used 

the average to represent the overall efficiency of the model. For non-representative ballast types, 

DOE used the average of three samples. After developing efficiency levels using these average 

tested values, DOE studied the impact of measurement variation and compliance requirements 

on the average BLE. 

DOE tested a subset of the ballast models obtained for the engineering analysis at a 

second laboratory for comparison with the data measured at the primary lab. The ballasts DOE 

selected included certain two- and 4-lamp IS and PS, T5 SO, and T5 HO ballasts. These results

provided data on the lab to lab variability present when testing the same ballast models 

(reproducibility). DOE found the second laboratory results to be, on average, 0.6 percent less 

than the average values used in the engineering analysis. 

DOE also considered the impact of the compliance reporting requirements. For example, 

after measuring a minimum of four samples, the existing requirements direct manufacturers to 

report the lower of the sample average or an equation that calculates the lower 99 percent 

confidence limit divided by 0.99. DOE evaluated both values for the ballasts analyzed and found 

that, on average, the lower value was that calculated by the compliance equation. DOE found the 

compliance value to be, on average, 0.2 percent less than the mean of the samples. 

In consideration of the lab to lab variability and the compliance reporting requirements, 

DOE applied a 0.8 percent reduction to the efficiency level equations developed using the 

engineering data. The proposed standard levels include this reduction. 

5.6 PRICING ANALYSIS OVERVIEW

For the NOPR, DOE developed prices using three main inputs. The first input was 

teardown data. DOE compared teardown-sourced MSPs from the same manufacturer to establish 

incremental costs between ELs for a representative ballast type. The second input was blue book 
5-7 

prices from manufacturer price lists. DOE estimated MSPs from these blue-book prices by using 

manufacturer specific ratios between blue book prices and teardown- or aggregated 

manufacturer-sourced MSPs. The third input was confidential manufacturer-supplied MSPs and 

incremental MPC values. DOE aggregated these inputs to establish MSPs for ELs of 

representative ballast types for which all data were available. In addition, DOE used ratios of 

online supplier retail prices to scale to certain ELs where both teardown and blue book prices 

were unavailable. In general, DOE used a combination of the teardown- and blue book-sourced 

prices throughout the analysis and used the aggregated manufacturer supplied MSPs for 

normalization and comparison purposes. 

5.6.1 Teardown-sourced MSPs

Developing the teardown-sourced MSPs for different fluorescent lamp ballasts involved 

two main inputs: a teardown analysis to develop the MPC and a markup analysis to arrive at the 

MSP. Figure 5.1 shows the general breakdown of costs and profit associated with manufacturing 

and selling a product. The full cost of production is broken down into two main costs: the full 

production cost or manufacturer production cost, and the non-production cost. The nonproduction cost plus profits is equal to the manufacturer markup. DOE totaled the cost of 

materials, labor, and direct overhead used to manufacture a product in order to calculate the 

MPC.g Section 5.6.1.1 describes how DOE arrived at the MPC. Section 5.6.1.2 describes how 

DOE established a markup that estimates non-production costs and profit. 

 Figure 5.1 Manufacturer Selling Price 

5.6.1.1 Manufacturer Production Costs

The MPC is composed of direct labor, direct material, and overhead costs. DOE 

conducted a teardown analysis to in which it created a bill of materials included in the ballast and 

an estimate of the direct labor required to assemble and test the finished product. The following 

paragraphs describe the inputs to the direct labor and materials costs and DOE’s method of 

estimating overhead.

 

g When viewed from the company-wide perspective, the sum of all material, labor, and overhead costs equals the 

company’s sales cost, also referred to as the cost of goods sold (COGS).
5-8 

Direct material costs represent the direct purchase price of components (resistors, 

connecting wires, etc.) identified in the teardown bill of materials. DOE conducted customized 

teardown analyses for select commercially available fluorescent lamp ballasts. DOE also 

conducted a teardown analysis on some ballasts removed from a manufacturing facility before 

adding potting, a type of black pitch. For these ballasts, DOE needed to estimate the cost of 

potting material to calculate the full material and labor costs. Based on information provided by 

members of the potting industry, DOE estimated the material and labor costs for potting to be 

about 60 cents for the standard ballast enclosure, which is 1 x 1.5 x 8 inches. Therefore, DOE 

added 60 cents to the teardown estimates for “pre-potting” ballasts to estimate the full material 

and labor costs. 

Manufacturers commented that the materials involved in ballast manufacturing are highly 

correlated to commodity pricing. Due to recent economic trends in the commodities market, the 

estimated MPCs could exhibit significant variation depending on the timeframe for component 

materials price quotes. The teardown estimates reflect component pricing for January 2009. DOE 

investigated how January 2009 estimates would change if a 5-year average of materials prices 

was used instead of a January 2009 spot price. As described in appendix 5A, DOE found the 

price variation to be insignificant and did not incorporate these material price changes into its 

analysis.

 The direct labor costs include fabrication and assembly labor. The teardown results also 

included estimates for direct labor costs associated with the assembly of the product. Separate 

labor rates were used for components that required manual (hand) insertion versus those that 

were automated. Based on conversations with manufacturers, DOE assumed the ballasts were 

manufactured in Mexico and China and applied the corresponding labor rates.

 The teardown results did not include overhead estimates. Overhead includes indirect 

material and labor costs, maintenance, depreciation, taxes, and insurance related to assets. DOE 

used financial data to estimate the overhead cost by calculating it as a percentage of the MPC.

DOE estimated the depreciation cost from a representative electronics fabrication 

company’s U.S. Securities and Exchange Commission (SEC) 10-k, finding it to be about 2.6 

percent of the cost of goods sold or the MPC. To determine the material and labor percentage, 

DOE marked down aggregated confidential MSPs to an MPC using the manufacturer markup 

(5.6.1.2). Then, DOE computed the ratio of aggregated teardown-sourced material and labor 

costs to the manufacturer markdown sourced MPC. DOE found the material and labor costs to be 

about 93.8 percent of the MPC. DOE then subtracted the materials and labor and depreciation 

percentages from 100 percent to back out the remainder of overhead as a percentage of MPC. 

Overhead was estimated to be 3.6 percent of the MPC, which is reasonable as electronics 

manufacturing generally has low overhead costs. DOE found overhead and depreciation to be 

about 6.2 percent of the MPC or 6.6 percent of the material and labor costs. The 6.6 percent 

factor was then used to mark up the material and labor costs contained in the teardown results to 

the full production cost or MPC. 

Selection of Units
5-9 

DOE carefully selected units for the teardown analysis to create useful data to estimate 

manufacturer production costs. DOE mapped out a matrix of product specifications and then 

compared ballasts that differ by only one attribute. Ballasts are described by a long list of 

specifications, so DOE concentrated on the specifications it expected to have the greatest effect 

on efficiency. This list included high versus regular advertised efficiency, maximum number of 

lamps driven, starting method, and universal versus single input voltage. In addition to 

strategically selecting ballast specification characteristics, DOE also selected common ballast 

models from major manufacturers. This choice helped DOE capture the most accurate 

incremental price difference by tearing down high volume, mainstream products. 

Unfortunately, DOE was only able to select unpotted ballasts for the teardown analysis. 

Some ballast manufacturers add potting to the ballast enclosure to improve durability. The 

potting reduces vibration damage and acts as a heat sink for the circuit board. Because the sticky 

potting inhibits visual observation of the components, DOE was unable to reverse engineer many 

ballasts through a teardown analysis. As a result, DOE only conducted teardowns for unpotted 

ballasts and ballasts removed from a manufacturing facility before the potting procedure. Section 

5.6 discusses how DOE estimated prices for those ballasts it could not or chose not to tear down. 

DOE selected thirteen fluorescent lamp ballasts to tear down for the engineering analysis. 

Table 5.2 lists the ballast types submitted for teardowns.

Table 5.2 Ballast Types for Teardowns 

Ballast Starting 

Method

For Operation 

of Input Voltage Regular vs. High Efficiency

1 PS 2 F32T8 Universal HE

2 PS 2 F32T8 Single REG

3 and 4 IS 2 F32T8 Universal HE

5 IS 2 F32T8 Universal REG

6 IS 2 F32T8 Single REG

7 IS 4 F32T8 Single REG

8 IS 4 F32T8 Universal REG

9 IS 4 F32T8 Universal HE

10 and 11 IS 2 F59T8 Universal HE

12 IS 2 F59T8 Single REG

13 IS 2 F59T8 Universal REG

5.6.1.2 Manufacturer Markup

More efficient products typically have higher manufacturing costs than baseline products. 

To meet new or amended energy conservation standards, manufacturers often must introduce 

design changes to their existing products or discontinue less efficient products, resulting in 

standards-compliant products that have higher MPCs than baseline products. Depending on the 

competitive environment for these particular products, some or all of the increased production 

costs can be “passed through” from manufacturers to customers in the form of higher purchase 

prices. As production costs increase, manufacturers also typically incur additional overhead at 

the factory and corporate levels. The MSP must cover both of these additional contributions to 

overhead if a company is to maintain its current level of profitability. 
5-10

As discussed previously, overhead costs within the DOE model are a function of 

investments, material costs, labor costs, or total costs, depending on the overhead category. 

Together, materials, labor, and factory overhead comprise the manufacturer production cost. 

DOE applies another multiplier to the manufacturer production cost to account for corporate 

non-production costs and profit. This latter multiplier, the manufacturer markup, is the focus of 

this section.

The manufacturer markup is an integral part of the overall markup from production costs 

to installation costs. However, the manufacturer markup is different than the other markups in 

the distribution chain (which includes wholesalers, distributors, retailers, contractors, etc.) that 

convert MSP to customer price. The customer prices and installation costs are key inputs to the 

LCC analysis, payback period (PBP) analysis, and national impact analysis (NIA). Through the 

use of the manufacturer and distribution chain markups and installation costs, DOE can calculate 

the first costs that customers would face under the various efficiency levels. DOE evaluates the 

tradeoff between the increase in first cost and the resulting energy cost savings at each efficiency 

level in the LCC and PBP analyses (preliminary TSD chapter 8) and NIA analysis (preliminary 

TSD chapter 10). In this section, DOE presents its methodology for converting the MPCs to 

manufacturer selling prices using the manufacturer markup. 

DOE calculated the MSP for fluorescent lamp ballasts by multiplying the MPC by the 

calculated manufacturer markup. In general, the manufacturer markup should ensure that the 

MSP of the product is high enough to recover the full cost of the product (i.e., full production 

and non-production costs), and yield a satisfactory profit. 

Publicly owned companies are required by law to disclose financial information on a 

regular basis by filing different forms with the U.S. Securities and Exchange Commission. The 

SEC form 10-K, filed by companies on an annual basis, provides a comprehensive overview of 

the company’s business and financial conditions. Relevant information in the 10-K reports 

includes the company’s revenues and direct and indirect costs. For the manufacturer markup, 

DOE used 10-K reports from publicly owned ballast manufacturing companies. The financial 

figures necessary for calculating the manufacturer markup are net sales, costs of sales, and gross 

profit. The income statement section of the 10-K reports often reports these figures. 

DOE calculated the manufacturer markup by using financial figures from manufacturers’ 

SEC 10-K reports, such as the net sales (revenues) and cost of sales to calculate gross profit and 

gross profit margins. DOE used averages of the financial figures spanning 2002 to 2008 to 

calculate the markup. DOE used the following equations to calculate the gross profit and gross 

profit margins: 

Equation 5.6-1 

Gross Profit ($) = Net Sales – Cost of Sales 

Equation 5.6-2 

 
5-11

Table 5.3 contains the calculated gross profit margins for four sample manufacturers.

Table 5.3 Gross Profit Margin for Four Fluorescent Lamp Ballast Manufacturers*

Parameter

IndustryWeighted 

Average

Manufacturer

A B C D 

Net Sales Million $ 66,614 90,705 46,952 38,118 63,862

Cost of Sales Million $ 44,203 58,350 29,567 27,562 44,804

Gross Profit Million $ 22,411 32,355 17,385 10,556 19,057

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8

* Data taken from 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports. 

To calculate the time-average gross profit margin for each firm, DOE first summed the 

gross profit for all the years and then divided the result by the sum of the net sales for those 

years. Each manufacturer’s markup was calculated as: 

Equation 5.6-3 

 

Table 5.4 shows the manufacturer markups using this method. 

Table 5.4 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts

Manufacturer Manufacturer Markup

Manufacturer A 1.55

Manufacturer B 1.59

Manufacturer C 1.38

Manufacturer D 1.43

Average 1.50

DOE calculated the average manufacturer markup to be 1.50 based on the estimated 

market share of each manufacturer. In other words, fluorescent lamp ballast manufacturers, on 

average, sell their products to the next party in the distribution channel at 50 percent above the 

manufacturing production cost. 

 Although publicly owned companies file SEC 10-K reports, the financial information 

summarized is not always exclusive to the fluorescent lamp ballast portion of their business. It 

can include financial information from other product sectors, whose margins could be quite 

different from those of the fluorescent lamp ballast industry. Therefore, during interviews, DOE 

asked manufacturers to provide both the manufacturer markup and the manufacturer selling price 

of fluorescent lamp ballasts sold through two main distribution chains: from the manufacturer to 

an original equipment manufacturer (OEM), and from the manufacturer to a distributor. 

 

 DOE supplemented the information provided in Table 5.4 with information from 

manufacturer interviews. During interviews, manufacturers generally indicated that the average 
5-12

markups for fluorescent lamp ballasts were lower than the markup for the parent company. After 

considering these two additional sources of information, DOE determined that a manufacturer 

markup of approximately 1.40 on an aggregate basis for the fluorescent lamp ballast industry 

was appropriate. 

DOE used these multipliers in the engineering analysis to determine the teardownsourced MSPs for each representative ballast type. DOE used a constant markup to reflect the 

MSPs of the baseline products as well as more efficient products. DOE took this approach 

because amended standards may make high-efficiency products, which currently are considered 

premium products, the baseline and commodity products in the future. 

DOE noticed that teardowns of ballasts from different manufacturers sometimes resulted 

in different MSPs, although they had approximately the same measured BLE. DOE believed this 

could potentially be due to differences in the brand of component used in the ballasts or design 

preferences particular to different manufacturers. As a result, DOE normalized the teardownsourced MSPs so that the incremental difference between ELs would be less impacted by 

differences in component prices from one manufacturer to another. Using this technique, DOE 

assigned teardown-sourced MSPs to efficiency levels at which a ballast was torn down. 

5.6.2 Blue book-sourced MSPs

For the blue book-sourced MSPs, DOE developed manufacturer-specific discount ratios 

between blue book prices and either teardown-sourced MSPs or aggregated manufacturersupplied MSPs. If teardown-sourced MSPs were available, DOE used these values to create 

discount ratios; otherwise DOE selected an aggregated manufacturer-supplied MSP. When a blue 

book value was not available from any manufacturer for a particular EL, DOE used a retail price 

scaling technique. DOE scaled the blue book-sourced price of an adjacent efficiency level using 

a ratio of retail prices (from a single online supplier) between ballasts in the adjacent EL and the 

EL without a blue book-sourced price. For example, if a blue book value was not available for 

EL2, a ratio of retail prices between EL2 and EL3 could be used to scale the blue book-sourced 

MSP from EL3 to EL2. 

5.6.3 Manufacturer-sourced MSPs

DOE received confidential MSPs and incremental price and cost data from 

manufacturers. To develop the confidential manufacturer-supplied MSPs, DOE aggregated the 

prices so that confidential information was not revealed. If an MSP was not available from 

multiple manufacturers, DOE did not report the value or use it for normalization purposes. For 

representative ballast types with prices normalized to a teardown value, DOE normalized the 

manufacturer-supplied MSPs to the teardown MSP. 

5.6.4 Final MSP

To calculate the final MSP for each EL in each product class, applied the following 

methodology. For ELs with teardown-sourced MSPs, DOE averaged the teardown-sourced MSP 

with the blue book-sourced MSP to assign the final MSP value. For ELs without a teardownsourced MSP, DOE used the blue book MSP directly as the final MSP. 
5-13

As mentioned in sections 5.6.2 and 5.6.3, DOE selected certain teardown MSPs or 

manufacturer supplied MSPs for normalization. DOE generally normalized to the primary 

baseline (baseline with the most shipments) or the least stringent EL with either a teardown- or 

manufacturer-sourced MSP. For example, DOE normalized to the F32T8 baseline/EL1 for the 2-

lamp 4-foot MBP IS and RS representative ballast type (using a teardown-sourced MSP) because 

this baseline represents the majority of shipments prior to the imposition of standards. Table 5.83

indicates the EL used for normalization for each representative ballast type.

5.7 REPRESENTATIVE PRODUCT CLASSES

As discussed in the market and technology assessment (NOPR TSD chapter 3), DOE is 

proposing to revise the existing product classes defined by the Energy Policy and Conservation 

Act (EPCA). DOE decided to analyze four of the five product classes as representative. The

representative product classes represent the most commonly sold ballasts and the majority of the 

ballast shipment volume. 

Although DOE did not analyze the product class for PS ballasts that operate 8-foot high 

output lamps as representative, DOE established standards based on another representative 

product class directly analyzed. Section 5.19 provides more information on extending standards 

to the product classes DOE did not directly analyze.

Table 5.5 Representative Product Classes

Description Product Class Number**

IS and RS ballasts that operate

 4-foot MBP lamps 

 8-foot slimline lamps

1 (representative)

PS ballasts that operate

 4-foot MBP lamps 

 4-foot MiniBP SO lamps

 4-foot MiniBP HO lamps

2 (representative)

IS and RS ballasts that operate

 8-foot HO lamps 3 (representative)

PS ballasts that operate

 8-foot HO lamps 4 

Ballasts that operate

 8-foot HO lamps in cold 

 temperature outdoor signs 

5 (representative)

*Includes both commercial and residential ballasts

**Efficiency levels for all product classes are based on an equation 

5.8 REPRESENTATIVE BALLAST TYPES

DOE chose to analyze at least one representative ballast type for each lamp type. 

Analyzing multiple ballast types allows for a more accurate assessment of the impacts of 

standards as each ballast type consumes a different amount of energy and has a different MPC. 

summarizes the representative ballast types analyzed in the NOPR.
5-14

The IS and RS product class includes ballasts that operate 4-foot MBP and 2-foot Ushaped lamps and 8-foot slimline lamps. For the ballasts that operate 4-foot MBP and 2-foot Ushaped lamps, DOE chose to analyze multiple representative ballast types. U.S. Census data 

indicate that approximately 50 percent of ballasts that operate F32T8 lamps (the most common 

4-foot MBP lamp) are one and two-lamp ballasts while the remaining 50 percent are three- and 

four-lamp ballasts.1 Based on its discussions with manufacturers and industry experts, DOE 

estimates that approximately 40 percent of ballasts that operate F32T8 lamps are two-lamp 

ballasts, 30 percent are four-lamp ballasts, 20 percent are three-lamp ballasts, and the remaining 

10 percent are one-lamp ballasts. U.S. Census data also indicates that the vast majority of ballasts 

that operate 4-foot MBP T12 lamps are two-lamp ballasts. Therefore, DOE chose to concentrate 

on analyzing four-lamp and two-lamp ballasts that operate 4-foot MBP lamps as representative 

ballast types. DOE limited its representative ballast types to only include those ballasts that 

exhibit a normal ballast factor (BF), as this BF is the most common.

h

 DOE also chose to study 

residential IS and RS ballasts that operate two 4-foot MBP lamps as a representative ballast type. 

Residential ballasts are a significant portion of the 4-foot MBP ballast market and the 2-lamp IS 

and RS variety is the most common. Finally, DOE estimates that the majority of ballast that 

operate 8-foot slimline lamps are two-lamp ballasts. Therefore, DOE analyzes 2-lamp 8-foot 

slimline lamps as a representative ballast type.

The PS product class includes ballasts that operate 4-foot MBP and 2-foot U-shaped 

lamps, 4-foot T5 miniature bipin (MiniBP) standard-output (SO) lamps, and 4-foot T5 miniature 

bipin (MiniBP) high-output (HO) lamps. DOE estimates the majority of ballasts that operate 4-

foot T5 miniature bipin standard-output lamps operate two lamps. Therefore, DOE analyzed the 

two-lamp variant as the representative ballast type for ballasts that operate T5 SO lamps. DOE 

also decided to study two-lamp ballasts that operate 4-foot T5 MiniBP HO lamps as a 

representative ballast type. Based on discussions with manufacturers and industry experts, DOE 

estimates that approximately 60 percent of ballasts that operate 4-foot T5 MiniBP HO lamps are 

two-lamp ballasts, 30 percent are three-lamp ballasts, and the remainder are one-lamp or fourlamp ballasts. Although IS and RS ballasts are the most common ballasts that operate 4-foot 

MBP lamps, PS ballasts are growing in market share. DOE found that similar to IS and RS 

ballasts, PS ballasts that operate 4-foot MBP lamps are commonly two- and four-lamp ballasts. 

Therefore, DOE analyzed two-lamp and four-lamp PS ballasts that operate 4-foot MBP lamps as 

representative ballast types.

For the sign ballast product class, DOE chose to analyze four-lamp sign ballasts as a 

representative ballast type because industry experts report these are the most common sign 

ballasts. 

For the 8-foot HO IS and RS product class, DOE chose to study only the IS and RS 

ballasts that operate two 8-foot HO lamps as representative ballast type as the two lamp variety is 

the most common type. 

Sections 5.9 through 5.18 describe how the EL equations delineate the representative 

ballast types. In these sections, DOE presents representative ballasts at each EL for each 

 

h DOE defines low ballast factor as being less than or equal to 0.78, normal ballast factor as being greater than 0.78 

but less than 1.10, and high ballast factor as being greater than or equal to 1.10.
5-15

representative ballast type. When discussing these representative units, DOE presents the tested 

BLE of the unit. Because DOE is setting efficiency levels in terms of an equation that relates 

lamp arc power to BLE, the particular efficiency value a ballast is subject to is specific to the 

lamp arc power provided by the ballast. The representative units present a “representative” 

efficiency level that just meets the EL requirements based on the representative unit’s total lamp 

arc power. 

5.9 INSTANT AND RAPID START BALLASTS THAT OPERATE TWO FOURFOOT MBP AND TWO-FOOT U-SHAPED LAMPS IN THE COMMERCIAL SECTOR

The IS and RS product class includes four representative ballast types, including IS and 

RS ballasts that operate two 4-foot MBP and 2-foot U-shaped lamps in the commercial sector. 

DOE presents its analysis of this ballast type in the following sections.

5.9.1 Baseline Models 

DOE selected baseline models as reference points for each representative ballast type, 

against which DOE measured changes resulting from potential amended energy conservation 

standards. As discussed in section 5.3, a baseline ballast just meets current Federal energy 

conservation standards and provides basic consumer utility. To determine energy savings and 

changes in price, DOE compared each higher energy efficiency level with the baseline unit. 

DOE chose to analyze two baseline ballasts for the two-lamp 4-foot and 2-foot U-shaped 

MBP IS and RS normal BF representative ballast type (hereafter referred to as the 2-lamp MBP

IS and RS representative ballast type). Census data indicate that 2001 shipments of 4-foot and 2-

foot U-shaped MBP T12 ballasts represented 14 percent of all 4-foot and 2-foot U-shaped MBP 

ballast shipments, while 4-foot and 2-foot U-shaped MBP T8 ballasts represented 86 percent of 

all 4-foot and 2-foot U-shaped MBP ballast shipments.i

 Therefore, DOE analyzed both T12 and 

T8 ballasts as a baseline ballast. Because the 2009 Lamps Rule eliminated all currently 

commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with 

the 2009 Lamps Rule to pair with T12 ballasts (see Table 5.7). DOE chose to analyze only those 

T12 ballasts that operate F34T12 lamps because only the most efficient T12 lamps will be 

available when this ballast rulemaking takes effect. For the T8 baseline, DOE chose to analyze 

only those ballasts that operate the F32T8 lamp because it is the most common 4-foot MBP T8 

lamp. 

DOE considered the ballast’s characteristics in choosing the most appropriate F32T8 and 

F34T12 ballasts for the 2-lamp MBP IS and RS representative ballast type. These characteristics 

included the ballast’s starting method (e.g., RS, or IS), input voltage (277 volts (V) vs. 120V), 

power factor (PF), total harmonic distortion (THD), ballast factor, input power, BLE, and type 

(electronic vs. magnetic), and whether the ballast can operate at multiple voltagesj

 (universal 

voltage) or only one (single voltage). Finally, DOE considered whether the ballast just meets 

 

i

More recent census data for ballasts are available. However, shipments of T12 ballasts have not been publicly 

released for all product classes after 2001. DOE used 2001 Census data for all analysis in this chapter. 

j

Universal voltage ballasts can operate at 120V or 277V.
5-16

existing Federal minimum energy conservation standards. In considering each of these 

characteristics, DOE chose a baseline ballast that exhibits the characteristics of the least efficient 

and most common ballast. 

The Federal minimum energy conservation standard for ballasts that operate two F34T12 

lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 

(m)(5)). This energy conservation standard effectively allowed only electronic F34T12 ballasts. 

Therefore, DOE chose an electronic ballast as the F34T12 baseline ballast. To determine the 

BLE of the baseline ballast, DOE tested multiple ballasts operating a reference F34T12 lamp. 

The BLE, BF, and input power of the most common T12 ballast that just meets the minimum 

energy conservation standard of 80.5 percent (BEF of 1.35k) is shown in Table 5.6 below. The 

majority of F34T12 electronic ballasts in product catalogs are RS, single voltage, have a high PF 

(~0.98) and a THD <20 percent. The ballast that just meets the energy conservation standard also 

exhibits these characteristics. DOE also chose a ballast that has an input voltage of 277V because 

the majority of ballasts operate in commercial buildings at 277V. 

Currently there is no federal minimum energy conservation standard for ballasts that 

operate F32T8 lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose 

the most common, least efficient ballast on the market. DOE tested a range of F32T8 ballasts 

from multiple ballast manufacturers and found that the least efficient but most common ballast 

exhibited the characteristics shown in Table 5.6 below. The vast majority of T8 ballasts are IS, 

electronic, and have a high PF (>0.97). Furthermore, the least efficient T8 ballasts are single 

voltage and have a THD <20 percent. Finally, like the F34T12 baseline ballast, DOE chose a 

ballast that has an input voltage of 277V as the majority of ballasts operate in commercial 

buildings at 277V. 

Table 5.6 Baseline Ballasts for the 2-lamp MBP IS and RS Representative Ballast Type 

For 

operation 

of

Starting Method, Input 

Voltage, Ballast Type, 

PF, THD

BF

Input 

Power

W 

BLE (%)

Federal Energy 

Conservation 

Standard

2, F34T12 

lamps

RS, 277V, Electronic, 

Single Voltage >0.98 PF, 

<20% THD

0.80 60.7 78.3% 80.5% 

2, F32T8 

lamps

IS, 277V, Electronic, 

Single Voltage, >0.98 

PF, <20% THD

0.90 61.1 85.8% N/A

DOE paired both commercial and industrial 4-foot and 2-foot U-shaped MBP ballasts 

with an appropriate F34T12 and F32T8 lamp. DOE chose 4-foot lamps that just meet the energy 

conservation standard (ECS) issued in the 2009 Lamps Rule, which becomes effective in 2012, 

as these will be the most common lamps available after the ballast rule takes effect. The 2009 

Lamps Rule proposed a standard that eliminated T12 lamps that are currently commercially 

available. However, the 2009 Lamps Rule did not prohibit manufacturers from developing a 

more efficient T12 lamp that can meet the standard by the time the rulemaking takes effect in 

2012. Because the ballast rulemaking takes effect in 2014, the efficacy of T12 lamps can 

potentially be improved by the use of rare earth phosphor to a point at which it complies with the 

 

k The conversions of BEF to BLE are presented in section 5.4
5-17

2009 Lamps Rule. Therefore, DOE paired T12 ballasts with a T12 lamp it invented that just 

meets the energy conservation standard adopted by the 2009 Lamps Rule. The characteristics of 

the T12 and T8 lamps paired with 4-foot MBP ballasts in this rulemaking are listed in the table 

below. 

Table 5.7 Lamps for Use with F32T8 and F34T12 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F34T12 4,100 92.3 3,138 2,825 24,000 N/A

F32T8 4,100 92.3 3,000 2,850 24,000 85

* Rated efficacy is based on the rated wattage of the lamps, which is 34W for the F34T12 lamp, and 

32.5W for the F32T8 lamp. 

These combinations of lamps and ballasts represent the most common configurations for these 

ballasts in existing and new installations. Together, these lamp and ballast combinations create a 

system lumen package of approximately 4,505 mean lumens (and 5,005 initial lumens) for the 

baseline F34T12 ballast and approximately 5,154 mean lumens (and 5,426 initial lumens) for 

the baseline F32T8 ballast. 

5.9.2 Efficiency Levels

For the 2-lamp MBP IS and RS representative ballast type, DOE conducted a survey of 

the fluorescent lamp ballast market to determine what types of products are available to 

consumers. As discussed in section 5.4, for each representative ballast type, DOE tested many of 

the manufacturers’ product offerings for BLE to develop efficiency level equations. After 

establishing these efficiency level equations, DOE selected representative units for each EL. 

Because the baseline ballasts have different BLE values and represent various design options, for

some representative ballast types, ELs affect only one of the two baseline ballasts. For example, 

EL1 may require a more efficient T12 ballast than the baseline T12 ballast, but not require a 

ballast more efficient than the T8 baseline. However, the full range of ELs ultimately specifies 

requirements that are above the BLE values of all the baseline ballasts sold, and therefore affect 

all baseline ballasts. Finally, DOE determined the maximum improvement in BLE that is 

technologically feasible (“max-tech”) for fluorescent lamp ballasts, as required by section 325(o) 

of EPCA. (42 U.S.C. 6295(o)). To determine this level, DOE conducted a survey of the 

fluorescent lamp ballast market and the research fields that support the market. DOE believes 

that within a given product class, no working prototypes exist that have a distinguishably higher 

BLE than currently available ballasts. However, DOE is exploring a level above that which is 

commercially available in appendix 5F of this NOPR TSD (hereafter referred to as the advanced 

technology scenario). 

The following section identifies the steps and technologies associated with each EL DOE 

considered for the 2-lamp MBP IS and RS representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE 

than the baseline ballast. Because the baseline ballast is an electronic ballast, improvements 
5-18

required the use of the following design options: improved components and improved circuit 

design. 

EL1. This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It is met 

by the least efficient F32T8 baseline ballast. No T12 ballasts meet this level. In addition, ballasts 

must use improved circuit designs (a starting method that is IS rather than RS). 

EL2. This level affects both the baseline ballasts. No T12 ballast that is commercially available 

can meet this level. Ballasts at this level use better components and more efficient circuit designs 

than those ballasts that just meet EL1. 

EL3. This level again affects both the baseline ballasts and represents the maximum 

technologically feasible level. This level represents a modest improvement in efficiency over 

EL2. Ballasts at this level use slightly better components and circuit designs than those ballasts 

that just meet EL2. 

Table 5.8 Summary of ELs for Two-Lamp MBP IS and RS Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.98 * ln(total lamp arc power) + 72.61 3 * ln(total lamp arc power) + 73.2

EL2 2.48 * ln(total lamp arc power) + 79.16 2.5 * ln(total lamp arc power) + 79.8

EL3 1.32 * ln(total lamp arc power) + 86.11 1.33 * ln(total lamp arc power) + 86.8

Figure 5.2 illustrates the three ELs on a plot of 2-lamp MBP IS and RS ballasts. A star indicates 

a representative unit selected by DOE. Diamonds indicate other 2-lamp MBP IS and RS ballasts 

tested by DOE. 
5-19

75.0

80.0

85.0

90.0

95.0

100.0

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

F34T12 Baseline

F32T8 Baseline

Figure 5.2 Efficiency Levels for the 2-lamp MBP IS and RS Representative Ballast Type

Table 5.9 provides detailed information on the 2-lamp MBP IS and RS ballast designs 

used in the engineering analysis and subsequent analyses. In general, for the 2-lamp MBP IS and 

RS representative ballast type, ballasts at higher efficiencies can operate at multiple voltages, 

have a lower THD, and similar BF and PF as the baseline ballast designs.

Table 5.9 2-Lamp 4-Foot MBP Commercial Ballasts in the IS and RS Representative 

Ballast Type Efficiency Level For Operation Of

Ballast Type

Starting Method

Input Voltage

Universal or 

Single Voltage

Power Factor

THD (%)

Ballast Factor

Input Power (W)

Lamp Arc Power 

(W) 

BLE (%)

Baseline 2 F34T12 

Lamps Electronic RS 277 Universal 0.99 <10% 0.80 60.7 47.5 78.3

Baseline

/EL1

2 F32T8 

Lamps Electronic IS 277 Single 0.98 <20% 0.90 61.1 52.4 85.8

EL2 2 F32T8 

Lamps Electronic IS 277 Universal 0.98 <10% 0.90 58.1 52.4 90.2

EL3 2 F32T8 

Lamps Electronic IS 277 Single 0.98 <10% 0.84 52.8 48.7 92.2

5.9.3 Lamp and Ballast Prices 
5-20

DOE analyzed each EL for the 2-lamp MBP IS and RS representative ballast type to 

develop appropriate MSPs. For the F34T12 baseline ballast, DOE based the price on blue booksourced MSPs described in section 5.6.2 and for the F32T8 ballasts (EL1 though EL3), DOE 

generated an MSP from an average of teardown- and blue book-sourced MSPs. As shown in 

Table 5.10, DOE found the MSP for the F34T12 ballast was higher than the baseline F32T8 

ballast. The F34T12 electronic ballast is sold at lower volumes than the electronic F32T8 

ballasts. DOE attributes the smaller shipments volume to its high cost relative to its efficiency.

Otherwise, MSP increases with increased efficiency. 

Table 5.10 Summary of the Manufacturing Selling Prices for the 2-Lamp MBP IS and RS

Commercial Representative Ballast Type 

Efficiency Level Lamp Type Starting Method MSP (2009$)

Baseline F34T12 RS 8.41

Baseline/EL1 F32T8 IS 6.94

EL2 F32T8 IS 8.85

EL3 F32T8 IS 9.27

 The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule. Although DOE calculated the performance characteristics of a T12 lamp 

such that it would comply with the standard adopted by the 2009 Lamps Rule, DOE assumed 

that the price of this T12 lamp would be the same as the representative T12 lamp that met trial 

standard level (TSL) 3 in the 2009 Lamps Rule. DOE believes that both TSL3 in the 2009 Lamps 

Rule and the market situation in 2014 are instances in which a very efficient T12 lamp competes 

directly with cheaper T8 lamps. Therefore, DOE believes that price competition will prevent 

manufacturers from raising the price of T12 lamps any higher than the price at which the most 

efficient T12 lamps are currently sold. 

Table 5.11 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F34T12 $5.83

F32T8 $2.82

5.9.4 Results

 

As discussed above, DOE evaluated multiple baseline ballasts for the relevant 

representative ballast types to provide a comprehensive understanding of the consumer 

economics. DOE based its engineering analysis on two substitution cases. In the first case, the 

consumer is not allowed to change the spacing of the fixtures and therefore replaces one baseline 

ballast with a more efficient ballast. In this case, light output is maintained to within 8 to 15 

percent of the baseline system lumen output dependent on comparison to a F32T8 or F34T12 

baseline. Percentage change in mean lumen output is shown in Table 5.12 and Table 5.13. In the 

second case, the consumer is allowed to change the spacing of the fixture. To show how energy 

savings would change due to this change in fixture spacing, DOE shows the normalized system 
5-21

input power. The following formula is used to normalize the system input power of the 

standards-case system to the mean lumen output of the baseline system:

Equation 5.9-1 

S dardsCase

S dardsCase

Baseline

S dardsCase InputPower MLO

MLO NormalizedInputPower tan

tan

tan = ∗

S dardsCase NormalizedInputPower tan = Input power of the standards-case system that 

matches the light output of the baseline system

MLOBaseline = Mean lumen output of the baseline system 

MLOS tan dardsCasee = Mean lumen output of the standards-case system

S dardsCasee InputPower tan = Input power of the standards-case system
5-22

Table 5.12 and Table 5.13 also present the retail price of the replacement lamps (e.g., if it is a 2-lamp system the retail price is 

the price of two lamps). Table 5.12 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 

system in the 2-lamp MBP IS and RS representative ballast type. Because the BFs of the standards-case systems are slightly lower 

than the baseline system, the normalized input power is slightly higher than the measured input power. If a direct substitution is made, 

mean lumen output does not change by more than eight percent relative to the mean lumen output of the baseline system. 

Table 5.12 Two-lamp MBP IS and RS Representative Ballast Type with F32T8 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline

/EL1

2 F32T8 

Lamps Electronic IS 277 Single 0.90 61.1 52.4 85.8 5,426 5,154 0.0% $6.94 $5.65 61.1

EL2 2 F32T8 

Lamps Electronic IS 277 Universal 0.90 58.1 52.4 90.2 5,423 5,152 0.0% $8.85 $5.65 58.1

EL3 2 F32T8 

Lamps Electronic IS 277 Single 0.84 52.8 48.7 92.2 5,033 4,782 -7.2% $9.27 $5.65 56.9

Table 5.13 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 system in the 2-lamp 

MBP IS and RS representative ballast type. If a direct substitution is made, mean lumen output does not change by more than 15 

percent relative to the mean lumen output of the baseline system. The representative F34T12 baseline ballast has a relatively low BF 

of 0.80. Typical F32T8 replacements have a higher ballast factor which results in increased total lumen output. 
5-23

Table 5.13 Two-lamp MBP IS and RS Representative Ballast Type with F34T12 Baseline 

Efficiency Level

For Operation Of

Ballast Type

Starting Method

Input Voltage

Universal or 

Single Voltage

Ballast Factor

Input Power (W)

Lamp Arc Power 

(W) 

BLE (%)

System Initial 

Light Output (lm)

System Mean 

Light Output (lm)

Percentage 

Change Mean 

Lumen Output 

(%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F34T12 

Lamps Electronic RS 277 Universal 0.80 60.7 47.5 78.3 5,005 4,505 0.0% $8.41 $11.65 60.7

EL1 2 F32T8 

Lamps Electronic IS 277 Single 0.90 61.1 52.4 85.8 5,426 5,154 14.4% $6.94 $5.65 53.4

EL2 2 F32T8 

Lamps Electronic IS 277 Universal 0.90 58.1 52.4 90.2 5,423 5,152 14.3% $8.85 $5.65 50.8

EL3 2 F32T8 

Lamps Electronic IS 277 Single 0.84 52.8 48.7 92.2 5,033 4,782 6.1% $9.27 $5.65 49.7
5-24

5.10 INSTANT AND RAPID START BALLASTS THAT OPERATE FOUR FOURFOOT MBP AND TWO-FOOT U-SHAPED LAMPS IN THE COMMERCIAL SECTOR

The IS and RS product class includes four representative ballast types, including IS and 

RS ballasts that operate four 4-foot MBP and 2-foot U-shaped lamps in the commercial sector. 

DOE presents its analysis of this ballast type in the following sections.

5.10.1 Baseline Models 

Although census data indicates that both T12 and T8 ballasts that operate 4-foot and 2-

foot U-shaped MBP lamps exist in the market, DOE research found that only T8 ballasts operate 

four lamps. Therefore, DOE analyzed only a T8 ballast as a baseline ballast for the 4-lamp 4-foot 

and 2-foot U-shaped MBP IS and RS normal BF representative ballast type (hereafter referred to 

as the 4-lamp MBP IS and RS representative ballast type). Furthermore, DOE chose to analyze 

only those ballasts that operate the F32T8 lamp because this lamp is the most common 4-foot 

MBP T8 lamp. 

In choosing the most appropriate F32T8 ballast for this representative ballast type, DOE 

considered the ballast’s characteristics. Because there is no Federal energy conservation 

standard, DOE chose a baseline ballast that exhibits the characteristics of the least efficient and 

most common ballast. 

DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and found that 

the least efficient but most common ballast exhibited the characteristics shown in Table 5.14

below. The vast majority of T8 ballasts are IS, electronic, and have a high PF (>0.98). 

Furthermore, the majority of the least efficient T8 ballasts are single voltage and have a THD 

<10 percent. Finally, DOE chose a ballast that has an input voltage of 277V as the majority of 

ballasts operate in commercial buildings at 277V. 

Table 5.14 Baseline Ballast for the 4-lamp MBP IS and RS Representative Ballast Type

For 

Operation 

of

Starting Method, 

Input Voltage, Ballast 

Type, PF, THD

BF

Input 

Power 

W

BLE (%)

Federal Energy 

Conservation 

Standard

4, F32T8 

Lamps

IS, 277V, Electronic, 

Single Voltage, >0.99 

PF, <10% THD

0.89 112.0 92.1% N/A

DOE paired both commercial and industrial 4-foot MBP and 2-foot U-shaped ballasts with an 

appropriate F32T8 lamp. As discussed above, DOE chose 4-foot lamps that just meet the ECS 

issued in the 2009 Lamps Rule (which becomes effective in 2012) as these will be the most 

common lamps available after the ballast rule takes effect. 74 FR 34080 (July 14, 2009). The 

characteristics of these lamps are listed in the table below. 
5-25

Table 5.15 Lamp for Use with F32T8 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F32T8 4,100 90.8 3,000 2,850 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F32T8 lamp is 32.5W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp and ballast combination creates a 

system lumen package of approximately 10,135 mean lumens (and 10,668 initial lumens) for the 

baseline F32T8 IS ballast. 

5.10.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 4-lamp MBP IS and RS representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE 

than the baseline ballast. Because the baseline ballast is an electronic T8 ballast, improvements 

required the use of the following design options: improved components and improved circuit 

design. For the 4-lamp MBP IS and RS representative ballast type, DOE identified three ELs. 

EL3 represents the maximum technologically feasible level.

Baseline/EL2. Though ballasts in other representative ballast types in the IS and RS product class 

were identified at EL1 or below, the least efficient 4-lamp MBP IS and RS ballasts tested just 

met EL2.

EL3. This level requires the use of improved components and represents the maximum 

technologically feasible level. 

Table 5.16 Summary of ELs for Four-lamp MBP IS and RS Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.98 * ln(total lamp arc power) + 72.61 3 * ln(total lamp arc power) + 73.2

EL2 2.48 * ln(total lamp arc power) + 79.16 2.5 * ln(total lamp arc power) + 79.8

EL3 1.32 * ln(total lamp arc power) + 86.11 1.33 * ln(total lamp arc power) + 86.8

Figure 5.3 illustrates the three ELs on a plot of 4-lamp MBP IS and RS ballasts. A star indicates 

a representative unit tested by DOE. Diamonds indicate other 4-lamp MBP IS and RS ballasts 

tested by DOE.
5-26

 

85.0

87.0

89.0

91.0

93.0

95.0

97.0

99.0

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

F32T8 Baseline

Figure 5.3 Efficiency Levels for the 4-lamp MBP IS and RS Representative Ballast Type 

Table 5.17 provides detailed information on the 4-foot MBP ballast designs used in the 

engineering analysis and subsequent analyses. In general, for the 4-lamp MBP IS and RS 

representative ballast type, ballasts at higher efficiencies can operate at multiple voltages and 

have a similar BF and PF as the baseline ballast designs. 

Table 5.17 Ballast Designs for the 4-lamp MBP IS and RS Representative Ballast Type

Baseline

/EL2

4 F32T8 

Lamps Electronic IS 277 Universal 0.99 <10 0.89 112.0 103.1 92.1

EL3 4 F32T8 

Lamps Electronic IS 277 Universal 0.98 <10 0.88 109.3 102.1 93.4

5.10.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 4-lamp MBP IS and RS representative ballast type to 

develop appropriate MSPs. The baseline/EL2 and EL3 MSPs were calculated using the average 

of the teardown- and blue book-sourced MSPs. DOE found that the MSP increased with 

increased efficiency for this representative ballast type as depicted in Table 5.18. Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor

Input Power

Lamp Arc Power

BLE (%)
5-27

Table 5.18 Summary of the Manufacturing Selling Price for the 4-lamp MBP IS and RS

Representative Ballast Type

Efficiency Level Lamp Type Starting Method MSP (2009$)

Baseline/EL2 F32T8 IS $9.79

EL3 F32T8 IS $11.63

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule (see section 5.9.3).

Table 5.19 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F32T8 $2.82

5.10.4 Results

Table 5.20 presents the engineering characteristics of the ballast replacement option for 

the baseline F32T8 system in the 4-lamp MBP IS and RS representative ballast type. Because the 

BF of EL3 is slightly lower than the baseline system, the normalized input power is higher than 

the measured input power. If a direct substitution is made, mean lumen output does not change 

by more than one percent relative to the mean lumen output of the baseline system. 
5-28

Table 5.20 Four-Lamp MBP IS and RS Representative Ballast Type with F32T8 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline/EL2 4 F32T8 

Lamps Electronic IS 277 Single 0.89 112.0 103.1 92.1 10,668 10,135 0.0% $9.79 $11.29 112.0

EL3 4 F32T8 

Lamps Electronic IS 277 Universal 0.88 109.3 102.1 93.4 10,560 10,032 -1.0% $11.63 $11.29 110.4
5-29

5.11 INSTANT AND RAPID START BALLASTS THAT OPERATE TWO EIGHTFOOT SP SLIMLINE LAMPS

The IS and RS product class includes four representative ballast types, including IS and 

RS ballasts that operate two 8-foot SP slimline lamps. DOE presents its analysis of this ballast 

type in the following sections. 

5.11.1 Baseline Models 

For the 2-lamp 8-foot SP slimline normal BF representative ballast type; hereafter 

referred to as the 8-foot SP slimline representative ballast type), DOE chose to analyze two 

baseline ballasts. Census data indicates that 2001 shipments of 8-foot SP slimline T12 ballasts 

represented approximately 50 percent of all shipments while 8-foot SP slimline T8 ballasts 

represented the remaining approximately 50 percent.12 Therefore, DOE analyzed both a T12 and 

T8 ballast as baseline ballasts. Because the 2009 Lamps Rule eliminated all currently 

commercially available T12 lamps by 2012, DOE created an F96T12/ES lamp that complied 

with the 2009 Lamps Rule to pair with T12 ballasts (see section 5.9.1). Because only the most 

efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to 

analyze only those T12 ballasts that operate F96T12/ES lamps for this rulemaking. For the T8 

baseline, DOE chose to analyze only those ballasts that operate the F96T8 lamp because this 

lamp is the most common 8-foot SP slimline T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two 

F96T12/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR 

Part 430.32 (m)(5)). This energy conservation standard effectively allowed only electronic 

F96T12/ES ballasts. Therefore, DOE chose an electronic ballast as the F96T12/ES baseline 

ballast. To determine the BLE of the baseline ballast, DOE tested multiple ballasts operating a 

reference F96T12/ES lamp. The BLE, BF, and input power of the most common F96T12/ES 

ballast that just meets the minimum energy conservation standard of 88.4 percent (BEF of 0.77) 

is shown in Table 5.21 below. All T12 electronic ballasts in product catalogs are IS, single 

voltage, and have a high PF. The ballast that just meets the energy conservation standard also 

exhibits these characteristics. DOE also chose a ballast that has an input voltage of 277V because 

the majority of ballasts operate in commercial buildings at 277V. There are multiple THD values 

for electronic F96T12/ES. These range from <20 percent to <14 percent and <10 percent. DOE 

chose a ballast with a THD of <20 percent because it represented the least efficient T12 ballast.

Currently there is no federal minimum energy conservation standard for ballasts that 

operate F96T8 lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose 

the most common, least efficient ballast on the market. DOE tested a range of F96T8 ballasts 

from multiple ballast manufacturers and found that the least efficient but most common ballast 

exhibited the characteristics shown in the table below. The vast majority of F96T8 ballasts are 

IS, electronic, and have a high PF (>0.98). Furthermore, the majority of the least efficient T8 

ballasts are universal voltage and have a THD <10 percent. Finally, like the F96T12/ES baseline 

 

12 More recent census data for ballasts is available. However, shipments of T12 ballasts have not been publicly 

released after 2001. T12 ballast shipments also include data for the 6-foot SP slimline ballast which DOE estimates 

is negligible when compared to the 8-foot shipments.
5-30

ballast, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate 

in commercial buildings at 277V. 

Table 5.21 Baseline Ballasts for the Eight-Foot SP Slimline Representative Ballast Type

For 

Operation of

Starting Method, Input 

Voltage, Ballast Type, 

PF, THD

BF

Input 

Power 

(W)

BLE (%)

Federal Energy 

Conservation 

Standard

2, F96T12/ES 

Lamps

IS, 277V, Electronic, 

Single Voltage, >0.98, 

PF, <20% THD

0.88 113.5 88.9 88.4

2, F96T8 

Lamps

IS, 277V, Electronic, 

Universal Voltage, >0.98 

PF, <10% THD

0.88 109.1 91.6 N/A

DOE paired 8-foot SP slimline ballasts with an appropriate F96T12/ES or F96T8 lamp. 

DOE chose 8-foot SP slimline lamps that just meet the ECS issued in the 2009 Lamps Rule 

which becomes effective in 2012 as these will be the most common lamps available after the 

ballast rule takes effect. The characteristics of these lamps are listed in the table below. 

Table 5.22 Lamps for Use with F96T8 and F96T12/ES Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F96T12/ES 4,100 98.2 5,939 5,516 15,000 N/A

F96T8 4,100 98.2 5,900 5,428 15,000 82

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12/ES lamp is 

60.5W and for the F96T8 lamp is 60.1W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp-and-ballast combination creates a 

system lumen package of approximately 9,699 mean lumens (and 10,443 initial lumens) for the 

baseline F96T12/ES ballast, approximately 9,520 mean lumens (and 10,348 initial lumens) for 

the baseline F96T8 IS ballast. 

5.11.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 8-foot SP slimline representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE 

than the baseline ballast. Because the baseline ballasts are electronic ballasts, improvements 

required the use of the following design options: improved components and improved circuit 

design. For the 8-foot SP slimline representative ballast type, DOE identified three ELs. EL3 

represents the maximum technologically feasible level.

Baseline/EL1. EL1 for the IS and RS representative product class does not affect the 8-foot SP 

slimline representative ballast type. The baseline T12 ballast just meets EL1.
5-31

Baseline/EL2. This level affects the baseline T12 ballast but not the baseline T8 ballast. The least 

efficient T8 ballast just meets this level. Ballasts at this level use better components and more 

efficient circuit designs than those ballasts that just meet EL1.

EL3. This level affects both the baseline T12 and T8 ballast. No T12 ballasts meet this level. T8 

ballasts at this level use slightly better components and circuit designs than those ballasts that

just meet EL2. EL3 also represents the maximum technologically feasible level.

Table 5.23 Summary of ELs for Eight-foot SP Slimline Ballasts

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.98 * ln(total lamp arc power) + 72.61 3 * ln(total lamp arc power) + 73.2

EL2 2.48 * ln(total lamp arc power) + 79.16 2.5 * ln(total lamp arc power) + 79.8

EL3 1.32 * ln(total lamp arc power) + 86.11 1.33 * ln(total lamp arc power) + 86.8

Figure 5.4 illustrates the three ELs on a plot of 8-foot SP Slimline ballasts. A star 

indicates a representative unit tested by DOE. Diamonds indicate other 8-foot SP Slimline 

ballasts tested by DOE. 

85.0

87.0

89.0

91.0

93.0

95.0

97.0

99.0

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%) F96T8 Baseline

F96T12/ES Baseline

Figure 5.4 Efficiency Levels for the Eight-Foot SP Slimline Representative Ballast Type

Table 5.24 provides detailed information on the 8-foot SP slimline ballast designs used in

the engineering analysis and subsequent analyses. For the F96T8 and F96T12/ES ballasts, the 

ballast characteristics remain the same as the baseline system.
5-32

Table 5.24 Ballast Designs for the Eight-Foot SP Slimline Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) Lamp Arc Power (W) 

BLE (%)

Baseline

/EL1

2 F96T12ES 

Lamps Electronic IS 277 Dedicated 0.98 <20 0.88 113.5 100.9 88.9

Baseline

/EL2

2 F96T8 

Lamps Electronic IS 277 Universal 0.98 <10 0.88 109.1 99.2 91.6

EL3 2 F96T8 

Lamps Electronic IS 277 Universal 0.98 <10 0.86 105.4 98.2 93.2

5.11.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 8-foot SP slimline representative ballast type to develop 

appropriate MSPs. DOE based the EL3 MSP on an average of teardown- and blue book-sourced 

MSPs, while the EL1 and EL2 MSPs were based on only blue book-sourced MSPs. DOE found 

that the MSP increased with increased efficiency for all ELs. 

Table 5.25 Manufacturing Selling Prices for the Eight-Foot SP Slimline Representative 

Ballast Type 

Efficiency Level Lamp Type MSP

(2009$)

Baseline/EL1 F96T12/ES $8.84

Baseline/EL2 F96T8 $10.05

EL3 F96T8 $10.29

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule (see section 5.9.3).

Table 5.26 Retail Prices for Eight-Foot SP Slimline Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F96T12/ES $7.00

F96T8 $5.92

5.11.4 Results

Table 5.27 presents the engineering characteristics of the ballast replacement options for 

the baseline F96T12/ES system in the 8-foot SP slimline representative ballast type. Because the 

BF of the standards-case systems are slightly less than the baseline system, the normalized input 

power is higher than the measured input power. If a direct substitution is made, mean lumen 

output does not change by more than four percent relative to the mean lumen output of the 

baseline system.
5-33

Table 5.27 Eight-Foot SP Slimline Representative Ballast Type with F96T12/ES Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm) System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline

/EL1

2 F96T12ES 

Lamps Electronic IS 277 Dedicated 0.88 113.5 100.9 88.9 10,443 9,699 0.0% $8.84 $14.00 113.5

Baseline

/EL2

2 F96T8 

Lamps Electronic IS 277 Universal 0.88 109.1 99.2 91.6 10,348 9,520 -1.8% $10.05 $11.84 111.2

EL3 2 F96T8 

Lamps Electronic IS 277 Universal 0.86 105.4 98.2 93.2 10,160 9,347 -3.6% $10.29 $11.84 109.3

Table 5.28 presents the engineering characteristics of the ballast replacement options for the baseline F96T8 system in the 8-

foot SP slimline representative ballast type. Because the BF of the standards-case systems are slightly less than the baseline system, 

the normalized input power is closer to the measured input power. If a direct substitution is made, mean lumen output does not change 

by more than two percent relative to the mean lumen output of the baseline system.
5-34

Table 5.28 Eight-Foot SP Slimline Representative Ballast Type with F96T8 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean 

Light Output (lm)

Percentage 

Change Mean 

Lumen Output 

(%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline

/EL2

2 F96T8 

Lamps Electronic IS 277 Universal 0.88 109.1 99.2 91.6 10,348 9,520 0.0% $10.05 $11.84 109.1

EL3 2 F96T8 

Lamps Electronic IS 277 Universal 0.86 105.4 98.2 93.2 10,160 9,347 -1.8% $10.29 $11.84 107.3
5-35

5.12 INSTANT START AND RAPID START BALLASTS THAT OPERATE TWO 

FOUR-FOOT MBP AND TWO-FOOT U-SHAPED LAMPS IN THE RESIDENTIAL 

SECTOR

The IS and RS product class includes four representative ballast types, including ballasts 

that operate two 4-foot MBP and 2-foot U-shaped lamps in the residential sector. DOE presents 

its analysis of this ballast type in the following sections. 

5.12.1 Baseline Models

For the residential 2-lamp 4-foot MBP and 2-foot U-shaped IS and RS representative 

ballast type (hereafter referred to as the residential representative ballast type), DOE chose to 

analyze two baseline ballasts. Census data indicates that the market share of low power factor 

magnetic ballasts was about 7 percent during the years from 1995 to 2002, and then decreased to 

about 1.5 percent in 2005.13 However, DOE believes that the Census data does not accurately 

reflect the residential ballast market. First, electronic ballasts are a common option for residential 

fluorescent lighting fixtures, but they are not reported in the Census data. Second, many 

residential ballasts are manufactured overseas by foreign companies which do not share shipment 

data with the U.S. Census. Through manufacturer interviews, DOE learned that both T12 and T8 

ballasts are popular in the residential market. Therefore, DOE analyzed both a T12 and T8 

ballast as a baseline ballast. Because the 2009 Lamps Rule will eliminate all currently 

commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with 

the 2009 Lamps Rule to pair with T12 ballasts (see section 5.9.1). Because only the most 

efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to 

analyze only those T12 ballasts that operate F34T12 lamps for this rulemaking. For the T8 

baseline, DOE paired its T8 baseline ballast with an F32T8 lamp because DOE believed it was 

the most common wattage lamp at that diameter.

The Federal minimum energy conservation standard for ballasts that operate two F34T12 

lamps is effective for residential ballasts manufactured on or after July 1, 2010. (10 CFR Part 

430.32 (m)(5)). This energy conservation standard effectively allowed only electronic F34T12 

ballasts. Therefore, DOE chose an electronic ballast as the T12 residential baseline ballast. To 

determine the BLE of the baseline ballast, DOE tested multiple ballasts operating a reference 

F34T12 lamp. The BLE, BF, and input power of the most common T12 ballast that just meets 

the minimum energy conservation standard of 80.5 percent (BEF of 1.35) is shown in Table 5.29

below. DOE research discovered that most ballasts sold in the residential market are sold as part 

of a fixture. Therefore, DOE researched the most common fixtures sold in the residential market. 

DOE then obtained the fixtures, removed the ballast, and tested the ballast to determine the least 

efficient and most common option. Other residential ballasts were procured independent of a 

fixture. The majority of ballasts in the residential market operate two lamps, have an input 

voltage of 120V, have a low power factor (0.5<PF<0.9), and are sold in striplights (also known 

 

13 Low power factor ballasts are ballasts with a power factor less than 0.9 and are typically used in residential 

applications.
5-36

as shoplights). The baseline T12 ballast exhibits these characteristics. The BLE, BF, and input 

power of the T12 and T8 baseline ballasts are shown in Table 5.29. 

For the T8 baseline, DOE also chose the most common, least efficient ballast on the 

market. DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and in 

multiple fixtures. DOE found that the least efficient but most common ballast exhibited the 

characteristics shown in the table below. The majority of F32T8 ballasts in the residential sector 

operate two lamps, are electronic, are IS, and operate at a single voltage of 120V. The 

characteristics of the T8 baseline ballast are summarized in Table 5.29. 

Table 5.29 Baseline Ballasts for the Residential Representative Ballast Type

For 

Operation 

of

Starting Method, 

Input Voltage, 

Ballast Type, PF

BF

Input 

Power 

(W)

BLE (%)

Federal Energy 

Conservation 

Standard

2, F34T12 

Lamps

RS, 120V, Electronic, 

Single Voltage, >0.50 

PF

0.82 62.6 77.7 80.5% 

2, F32T8 

Lamps

IS, 120V, Electronic, 

Single Voltage, >0.50 

PF

0.81 53.8 87.8 N/A

DOE paired 4-foot MBP ballasts with an appropriate F34T12 or F32T8 lamp. DOE chose 

4-foot MBP lamps that just meet the ECS adopted in the 2009 Lamps Rule which becomes 

effective in 2012 as these will be the most common lamps available after the ballast rule takes 

effect. The characteristics of these lamps are listed in the table below. 

Table 5.30 Lamps for Use with F32T8 and F34T12 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F34T12 4,100 92.3 3,138 2,825 24,000 N/A

F32T8 4,100 92.3 3,000 2,850 24,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F34T12 lamp is 34W and 

for the F32T8 lamp is 32.5W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, these lamp-and-ballast combinations create a 

system lumen package of approximately 4,609 mean lumens (and 5,119 initial lumens) for the 

baseline F34T12 ballast, and approximately 4,644 mean lumens (and 4,888 initial lumens) for 

the baseline F32T8 ballast. 

5.12.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the residential representative ballast type. As discussed in the screening 

analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE than the 
5-37

baseline ballast. Because the baseline ballasts are electronic ballasts, improvements required the 

use of the improved components and improved circuit design. For the residential representative 

ballast type, DOE identified three ELs. EL3 represents the maximum technologically feasible 

level.

EL1. This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. No T12 

ballasts meet this level. In addition, ballasts must use improved circuit designs (a starting method 

that is IS rather than RS).

EL2. This level affects both the baseline ballasts. DOE did not identify any residential ballasts 

currently in the market at EL2. 

EL3. This level again affects both baseline ballasts and represents the maximum technologically 

feasible level. This level represents a modest improvement in efficiency over EL2. Ballasts at 

this level use slightly better components and circuit designs than those ballasts that just meet 

EL2. 

Table 5.31 Summary of ELs for Residential Ballasts

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.98 * ln(total lamp arc power) + 72.61 3 * ln(total lamp arc power) + 73.2

EL2 2.48 * ln(total lamp arc power) + 79.16 2.5 * ln(total lamp arc power) + 79.8

EL3 1.32 * ln(total lamp arc power) + 86.11 1.33 * ln(total lamp arc power) + 86.8

Figure 5.5 illustrates the three ELs on a plot of residential ballasts. A star indicates a 

representative unit tested by DOE. Diamonds indicate other residential ballasts tested by DOE. 

 

75.0

80.0

85.0

90.0

95.0

100.0

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

F32T8 Baseline

F34T12 Baseline
5-38

Figure 5.5 Efficiency Levels for the Residential Representative Ballast Type

Table 5.32 provides detailed information on the 4-foot MBP ballast designs used in the 

engineering analysis and subsequent analyses.

Table 5.32 Ballast Designs for the Residential Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor

Input Power (W)

Lamp Arc Power 

(W) 

BLE (%)

Baseline 2 F34T12 

Lamps Electronic RS 120 Dedicated - <20 0.82 62.6 48.6 77.7

Baseline

/EL1

2 F32T8 

Lamps Electronic IS 120 Dedicated - - 0.81 53.8 47.3 87.8

EL2 2 F32T8 

Lamps - - - - - - - - - - 

EL3 2 F32T8 

Lamps Electronic IS 120 Dedicated 0.98 <120 0.87 54.7 50.3 92.0

5.12.3 Lamp and Ballast Prices 

DOE analyzed each EL for the residential representative ballast type to develop 

appropriate MSPs. For the baseline and EL1, DOE used blue book-sourced MSPs. For EL3, 

DOE used a manufacturer-sourced MSP. DOE found the MSP for the F34T12 ballast was higher 

than the baseline/EL1 F32T8 ballast. The F34T12 electronic ballast is sold at lower volumes than 

electronic F32T8 ballasts. DOE attributes the smaller shipments volume to its high cost relative 

to its efficiency. Table 5.33 lists the MSPs for the residential representative ballast type.

Table 5.33 Manufacturing Selling Prices for the Residential Representative Ballast Type 

Efficiency Level Lamp Type MSP

$

Baseline F34T12 $4.68

Baseline/EL1 F32T8 $3.77

EL3 F32T8 $4.62

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule. 
5-39

Table 5.34 Retail Prices for Four-Foot MBP Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F34T12 $5.83

F32T8 $2.82

5.12.4 Results

Table 5.35 presents the engineering characteristics of the ballast replacement options for 

the baseline F34T12 system in the residential representative ballast type. Because the BF of the 

EL3 system is higher than the baseline system, the normalized input power is lower than the 

measured input power. The opposite is true for EL1 compared to the F34T12 baseline. If a direct 

substitution is made, mean lumen output can increase by as much as eight percent over the mean 

lumen output of the baseline system because of the difference in ballast factor. For the residential 

sector, DOE believes that consumers are more likely to purchase replacement fixtures rather than 

direct ballast replacements. 
5-40

Table 5.35 Residential Representative Ballast Type with F34T12 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) 

BLE (%)

System Initial Light 

Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F34T12 

Lamps Electronic IS 120 Single 0.82 62.6 48.6 77.7 5,119 4,609 0.0% $4.68 $11.65 62.6

Baseline/EL1 2 F32T8 

Lamps Electronic IS 120 Single 0.81 53.8 47.3 87.8 4,888 4,644 0.8% $3.77 $5.65 53.4

EL2 2 F32T8 

Lamps

EL3 2 F32T8 

Lamps Electronic IS 120 Single 0.87 54.7 50.3 92.0 5,207 4,947 7.3% $4.62 $5.65 51.0

Table 5.36 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the 

residential representative ballast type. Because the BF of the standards-case system is slightly higher than the baseline system, the 

normalized input power is slightly lower than the measured input power. If a direct substitution is made, mean lumen output does not 

change by more than seven percent relative to the mean lumen output of the baseline system. 

Table 5.36 Residential Representative Ballast Type with F32T8 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) 

BLE (%)

System Initial 

Light Output (lm)

System Mean 

Light Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price

($)

Normalized Input 

Power (W)

Baseline/

EL1

2 F32T8 

Lamps Electronic IS 120 Dedicated 0.81 53.8 47.3 87.8 4,888 4,644 0.0% $3.77 $5.65 53.8

EL2 2 F32T8 

Lamps

EL3 2 F32T8 Electronic IS 120 Dedicated 0.87 53.8 50.3 93.6 5,207 4,947 6.5% 4.62 $5.65 51.2
5-41

Lamps
5-42

5.13 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT 

MBP AND TWO-FOOT U-SHAPED LAMPS

 

The PS product class includes four representative ballast types, including PS ballasts that 

operate two 4-foot MBP and 2-foot U-shaped lamps. DOE presents its analysis of this ballast 

type in the following sections. 

5.13.1 Baseline Models

For the 2-lamp 4-foot MBP and 2-foot U-shaped PS normal BF representative ballast 

type (hereafter the 2-lamp MBP PS representative ballast type), DOE found that only F32T8 

ballasts operate in this representative ballast type. DOE tested a range of F32T8 PS ballasts from 

multiple ballast manufacturers and found that the least efficient of these ballasts exhibited the 

characteristics shown in Table 5.37 below. This ballast, like the majority of PS ballasts on the 

market, is electronic, has a high PF (~0.98), has a low THD (<10 percent), and is universal 

voltage. 

Table 5.37 Baseline Units for the 2-lamp MBP PS Representative Ballast Type 

For

operation of

Starting Method, Input 

Voltage, Ballast Type, 

PF, THD

BF Input 

Power BLE (%)

Federal Energy 

Conservation 

Standards (BEF)

2, F32T8 

lamps

PS, 277V, Electronic, 

>0.98, <10% THD, 

Universal Voltage

0.91 63.1 83.5% N/A

DOE paired 4-foot MBP ballasts with an appropriate F32T8 lamp. DOE chose 4-foot 

MBP lamps that just meet the ECS adopted in the 2009 Lamps Rule which becomes effective in 

2012 as these will be the most common lamps available after this ballast rule takes effect. The 

characteristics of these lamps are listed in the table below. 

Table 5.38 Lamps for Use with F32T8 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F32T8 4,100 92.3 3,000 2,850 24,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F32T8 lamp is 32.5W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, these lamp-and-ballast combinations create a 

system lumen package of approximately 5,179 mean lumens (and 5,452 initial lumens) for the 

baseline F32T8 ballast. 
5-43

5.13.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 2-lamp MBP PS representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE considered design options that achieve a higher 

BLE than the baseline ballast. Because the baseline ballast is a T8 electronic ballast, 

improvements required the use of the following design options: improved components and 

improved circuit design. For the 2-lamp MBP PS ballasts, DOE identified three ELs. EL3 

represents the maximum technologically feasible level.

EL1. DOE did not identify 2-lamp 4-foot MBP PS ballasts at EL1, though other ballasts in the 

PS product class did fall in EL1. 

EL2. EL2 requires the use of improved circuit designs for the 2-lamp MBP PS ballast. 

Specifically, ballasts at this level use some reduction of cathode heating of the filament after the 

lamp starts. 

EL3. EL3 represents the maximum technologically feasible EL. Ballasts at this level will use 

slightly better components and circuit designs than those ballasts that just meet EL2. 

Table 5.39 Summary of ELs for Two-Lamp MBP PS Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.48 * ln(total lamp arc power) + 77.87 2.5 * ln(total lamp arc power) + 78.5

EL2 2.48 * ln(total lamp arc power) + 78.86 2.5 * ln(total lamp arc power) + 79.5

EL3 1.79 * ln(total lamp arc power) + 83.33 1.8 * ln(total lamp arc power) + 84

Figure 5.6 illustrates the three ELs on a plot of 2-lamp MBP PS ballasts. A star indicates a 

representative unit tested by DOE. Diamonds indicate other 2-lamp MBP PS ballasts tested by 

DOE. 
5-44

80.000

82.000

84.000

86.000

88.000

90.000

92.000

94.000

96.000

98.000

100.000

0.000 10.000 20.000 30.000 40.000 50.000 60.000 70.000 80.000 90.000 100.000

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

F32T8 Baseline

Figure 5.6 Efficiency Levels for the 2-lamp MBP PS Representative Ballast Type

Table 5.40 Ballast Designs for the 2-lamp MBP PS Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) Lamp Arc Power 

(W) 

BLE (%)

Baseline 2 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10% 0.91 63.1 52.7 83.5

EL1 2 F32T8 

Lamps - - - - - - - - - - 

EL2 2 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10% 0.91 58.6 52.7 90.0

EL3 2 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10% 0.91 57.7 52.6 91.2

5.13.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 2-lamp MBP PS representative ballast type to develop 

appropriate MSPs. DOE based the baseline and EL3 MSPs on an average of teardown- and blue 

book-sourced MSPs. For EL2, the MSP was based on blue-book sourced MSPs. DOE found that 

the MSP increased with increased efficiency for this representative ballast type as depicted in

Table 5.41. 

Table 5.41 Summary of the Manufacturing Selling Prices for the 2-lamp MBP PS 

Representative Ballast Type
5-45

Efficiency Level Lamp Type Starting Method MSP (2009$)

Baseline F32T8 PS $8.39

EL2 F32T8 PS $9.28

EL3 F32T8 PS $9.59

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule (see section 5.9.3).

Table 5.42 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F32T8 $2.82

5.13.4 Results

Table 5.43 presents the engineering characteristics of the ballast replacement options for the 

baseline F32T8 system in the 2-lamp MBP PS representative ballast type. If a direct substitution 

is made, mean lumen output does not change by more than 0.1 percent relative to the mean 

lumen output of the baseline system. 
5-46

Table 5.43 Two-lamp MBP PS Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W)

Lamp Arc Power 

(W) 

BLE (%)

System Initial Light 

Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F32T8 

Lamps Electronic PS 277 Universal 0.91 63.1 52.7 83.5 5,452 5,179 0.0% $8.39 $5.65 63.1

EL1 2 F32T8 

Lamps Electronic PS 277 - - - - - - - - - - - 

EL2 2 F32T8 

Lamps Electronic PS 277 Universal 0.91 58.6 52.7 90.0 5,455 5,182 0.1% $9.28 $5.65 58.5

EL3 2 F32T8 

Lamps Electronic PS 277 Universal 0.91 57.7 52.6 91.2 5,445 5,173 -0.1% $9.59 $5.65 57.8
5-47

5.14 PROGRAMMED START BALLASTS THE OPERATE FOUR FOUR-FOOT MBP 

AND FOUR TWO-FOOT U-SHAPED LAMPS

The PS product class includes four representative ballast types, including PS ballasts that 

operate four 4-foot MBP and 2-foot U-shaped lamps. DOE presents its analysis of this ballast 

type in the following sections. 

5.14.1 Baseline Models

For the 4-lamp 4-foot MBP and 2-foot U-shaped PS normal BF representative ballast 

type (hereafter referred to as the 4-lamp MBP PS representative ballast type), DOE also found 

that F32T8 lamps are the only MBP lamps operated. Currently there is no federal minimum 

energy conservation standard for ballasts that operate F32T8 lamps. Therefore, in choosing the 

baseline ballast for this representative ballast type, DOE chose the most common, least efficient 

ballast on the market. DOE tested a range of F32T8 PS ballasts from multiple ballast 

manufacturers and found that the least efficient of these ballasts exhibited the characteristics 

shown in Table 5.44. This ballast, like the majority of PS ballasts on the market, is electronic, 

has a high PF (~0.98) and has a low THD (<10 percent). 

Table 5.44 Baseline Ballasts for the 4-lamp MBP PS Representative Ballast Type 

For 

Operation 

of

Starting Method, 

Input Voltage, Ballast 

Type, PF, THD

BF

Input 

Power 

W

BLE (%)

Federal Energy 

Conservation 

Standard

4, F32T8 

Lamps

PS, 277V, Electronic, 

Single Voltage, 0.98 

PF, <10% THD

0.84 118.2 82.2% N/A

DOE paired 4-foot MBP ballasts with an appropriate F32T8 lamp. DOE chose 4-foot 

MBP lamps that just meet the ECS adopted in the 2009 Lamps Rule which becomes effective in 

2012 as these will be the most common lamps available after the ballast rule takes effect. The 

characteristics of these lamps are listed in the table below. 

Table 5.45 Lamps for Use with F32T8 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F32T8 4,100 92.3 3,000 2,850 24,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F34T12 lamp is 34W and 

for the F32T8 lamp is 32.5W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, these lamp-and-ballast combinations create a 

system lumen package of approximately 9,548 mean lumens (and 10,050 initial lumens) for the 

baseline F32T8 ballast. 
5-48

5.14.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL

DOE considered for the 4-lamp MBP PS representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE considered design options that achieve a higher 

BLE than the baseline ballast. Because the baseline ballast is a T8 electronic ballast, 

improvements required the use of the following design options: improved components and 

improved circuit design. For PS ballasts, DOE identified three ELs. EL3 represents the 

maximum technologically feasible level.

EL1. This level requires the use of improved circuit designs for the 4-lamp MBP PS ballast. 

Specifically, ballasts at this level use a reduced level of cathode heating of the filament after the 

lamp starts.

EL2. DOE did not identify 4-lamp MBP PS ballasts at EL2, though other ballasts in the PS 

product class did fall in EL2. 

EL3. This level represents the maximum technologically feasible level and an improvement in 

efficiency over EL1. Ballasts that just meet EL3 may use slightly higher levels of cathode 

cutback after the lamp starts as well as improved components. 

Table 5.46 Summary of ELs for Four-lamp MBP PS Ballasts

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.48 * ln(total lamp arc power) + 77.87 2.5 * ln(total lamp arc power) + 78.5

EL2 2.48 * ln(total lamp arc power) + 78.86 2.5 * ln(total lamp arc power) + 79.5

EL3 1.79 * ln(total lamp arc power) + 83.33 1.8 * ln(total lamp arc power) + 84

Figure 5.7 illustrates three ELs on a plot of 4-lamp MBP PS ballasts. A star indicates a 

representative unit tested by DOE. Diamonds indicate other 4-lamp MBP PS ballasts tested by 

DOE.

 
5-49

80.000

82.000

84.000

86.000

88.000

90.000

92.000

94.000

96.000

98.000

100.000

50.000 60.000 70.000 80.000 90.000 100.000 110.000 120.000 130.000 140.000 150.000

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

F32T8 Baseline

Figure 5.7 Efficiency Levels for the 4-lamp MBP PS Representative Ballast Type

Table 5.47 Ballast Designs for the 4-lamp MBP PS Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W)

Lamp Arc Power 

(W) 

BLE (%)

Baseline 4 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10 0.84 118.2 97.2 82.2

EL1 4 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10 0.91 116.8 105.9 90.6

EL2 4 F32T8 

Lamps - - - - - - - - - - 

EL3 4 F32T8 

Lamps Electronic PS 277 Universal 0.97 <10 0.91 113.6 105.6 93.0

5.14.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 4-lamp MBP PS representative ballast type to develop 

appropriate MSPs. The baseline, EL1, and EL3 MSPs were based on blue book-sourced MSPs. 

DOE found that the MSP increased with increased efficiency for this representative ballast type

as depicted in Table 5.48. 
5-50

Table 5.48 Summary of the Manufacturing Selling Price for the 4-lamp MBP PS 

Representative Ballast Type 

Efficiency Level Lamp Type Starting Method MSP (2009$)

Baseline F32T8 PS $9.05

EL1 F32T8 PS $11.84

EL3 F32T8 PS $13.33

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule (see section 5.9.3).

Table 5.49 Retail Prices for Four-Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F32T8 $2.82

5.14.4 Results

Table 5.50 presents the engineering characteristics of the ballast replacement option for 

the baseline F32T8 system in the PS representative ballast type. Because the BF of the standardscase systems at EL1 and EL3 is higher than the baseline system, the normalized input power is 

lower than the measured input power. If a direct substitution is made, mean lumen output does 

not change by more than 9 percent relative to the mean lumen output of the baseline system. 
5-51

Table 5.50 Four-Lamp MBP PS Representative Ballast Type with F32T8 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light 

Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 4 F32T8 

Lamps Electronic PS 277 Universal 0.84 118.2 97.2 82.2 10,050 9,548 0.0% $9.05 $11.29 118.2

EL1 4 F32T8 

Lamps Electronic PS 277 Universal 0.91 116.8 105.9 90.6 10,955 10,408 9.0% $11.84 $11.29 107.2

EL2 4 F32T8 

Lamps Electronic PS 277 - - - - - - - - - - - 

EL3 4 F32T8 

Lamps Electronic PS 277 Universal 0.91 113.6 105.6 93.0 10,926 10,380 8.7% $13.33 $11.29 104.5
5-52

5.15 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT 

MINIBP T5 SO LAMPS

The PS product class includes four representative ballast types, including ballasts that 

operate two 4-foot Mini-BP T5 SO lamps. DOE presents its analysis of this ballast type in the 

following sections. 

5.15.1 Baseline Models 

For the 2-lamp 4-foot MiniBP T5 SO normal BF representative ballast type (hereafter 

referred to as the 4-foot T5 SO representative ballast type), DOE chose to analyze one baseline 

ballast. DOE believes that F28T5 lamps encompass the vast majority of 4-foot T5 SO lamp 

sales.14 Therefore, DOE has chosen to only analyze the F28T5 baseline ballast. 

Currently there is no federal minimum energy conservation standard for ballasts that 

operate F28T5 lamps. In addition, only relatively efficient electronic 4-foot T5 SO ballasts are 

sold on the U.S. market. DOE recognizes, however, that electronic 4-foot T5 SO ballasts similar 

to the baseline levels of the 4-foot MBP T8 PS representative ballast type may be introduced to 

the U.S. market and purchased widely by consumers if a standard for 4-foot T5 SO ballasts is not 

established. Because these inefficient 4-foot T5 SO ballasts do not exist currently, DOE 

developed a baseline inefficient 4-foot T5 SO ballast by determining the difference in BLE 

between baseline and EL2 2-lamp MBP PS ballasts. More information on how DOE developed 

this baseline model is outlined in appendix 5B. The baseline 4-foot T5 SO ballast has the 

characteristics shown in the table below. Although this ballast is not commercially available 

today, it represents the lowest efficiency ballast that may be commercially available when 

standards take effect.

Table 5.51 Baseline Ballast for Four-Foot T5 MiniBP SO Representative Ballast Type 

For 

Operation 

of

BF Ballast Type 

Input 

Power 

(W)

BLE (%)

Federal Energy 

Conservation 

Standard

F28T5 1.01 Electronic 67.3 82.8% N/A

DOE paired the 2-lamp 4-foot SO ballast with an appropriate F28T5 lamp. DOE chose a 

4-foot SO lamp that just meets the ECS issued in the 2009 Lamps Rule which becomes effective 

in 2012 as this will be the most common lamp available after the ballast rule takes effect. The 

characteristics of this lamp are listed in the table below. 

 

14 Currently only one manufacturer sells a 4-foot MiniBP T5 lamp that is not a F28T5. This lamp is a reduced 

wattage (F26T5).
5-53

Table 5.52 Lamps for Use with F28T5 Ballasts 

Lamp Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F28T5 4,100 104.3 2,900 2,660 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F28T5 lamp is 27.8W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp-and-ballast combination creates a 

system lumen package of approximately 5,362 mean lumens (and 5,846 initial lumens). 

5.15.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 4-foot T5 SO representative ballast type. As discussed in the screening 

analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE than the 

baseline ballast. Because the baseline ballast is an inefficient ballast, improvements required the 

use of the following design options: improved components and improved circuit design. For the 

4-foot T5 SO representative ballast type, DOE identified three ELs. The highest EL represents 

the maximum technologically feasible level.

EL1. This level represents an improvement over the baseline T5 efficiency. This level is 

characterized by the least efficient electronic ballasts that are commercially available today.

EL2. Ballasts at this level use slightly better components and circuit designs than those ballasts 

that meet EL1. 

EL3. This level represents an improvement in efficiency over EL2. EL3 is just met by the most 

efficient T5 ballast tested and represents the max-tech EL. Ballasts at this level use slightly better 

components and circuit designs than those ballasts that meet EL2. 

Table 5.53 Summary of ELs for 4-foot T5 SO Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.48 * ln(total lamp arc power) + 77.87 2.5 * ln(total lamp arc power) + 78.5

EL2 2.48 * ln(total lamp arc power) + 78.86 2.5 * ln(total lamp arc power) + 79.5

EL3 1.79 * ln(total lamp arc power) + 83.33 1.8 * ln(total lamp arc power) + 84.0

Figure 5.8 illustrates the three ELs on a plot of 4-foot T5 SO ballasts. A star indicates a 

representative unit tested by DOE. A circle indicates a representative unit theoretically 

developed. Diamonds indicate other 4-foot T5 SO ballasts tested by DOE. 
5-54

 

80.000

82.000

84.000

86.000

88.000

90.000

92.000

94.000

96.000

98.000

100.000

0.000 10.000 20.000 30.000 40.000 50.000 60.000 70.000 80.000 90.000 100.000

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

0 F28T5 Baseline

Figure 5.8 Efficiency Levels for the Four-Foot T5 MiniBP SO Representative Ballast Type 

Table 5.54 provides detailed information on the 4-foot MiniBP SO ballast designs used in 

the engineering analysis and subsequent analyses. For the F28T5 ballasts, the ballast 

characteristics either improve or remain the same as the magnetic baseline system. 

Table 5.54 Ballast Designs for the Four-Foot T5 MiniBP SO Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%)

Baseline 2 F28T5 

Lamps Electronic PS 277 Universal 0.99 <10 1.01 67.3 55.7 82.8

EL1 2 F28T5 

Lamps Electronic PS 277 Universal 0.99 <10 1.01 63.2 56.0 88.7

EL2 2 F28T5 

Lamps Electronic PS 277 Universal 0.98 <10 0.97 60.1 53.9 89.6

EL3 2 F28T5 

Lamps Electronic PS 277 Universal 0.98 <10 1.08 64.9 59.9 92.3

5.15.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 4-foot T5 SO representative ballast type to develop 

appropriate MSPs. The EL1, EL2, and EL3 MSPs were estimated using the blue book-sourced 

MSPs as described in section 5.6.2. To determine a price for the baseline T5 ballast, DOE 
5-55

assumed that the ratio of the baseline 2-lamp, 4-foot T8 MBP PS ballast to the EL2 price for the 

same ballast type would be the same as the ratio of the baseline to EL1 for 4-foot T5 SO ballasts 

– a ballast type that operates a similar wattage. DOE found that the MSP increased with 

increased efficiency as depicted in the table below.

Table 5.55 Manufacturing Selling Prices for the Four-Foot T5 MiniBP SO Representative

Ballast Type 

Efficiency Level Lamp Type MSP (2009$)

Baseline F28T5 $10.78

EL1 F28T5 $10.85

EL2 F28T5 $11.92

EL3 F28T5 $15.36

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule. 

Table 5.56 Retail Prices for Four-Foot MiniBP SO Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F28T5 $3.20

5.15.4 Results

Table 5.57 presents the engineering characteristics of the ballast replacement options for 

the baseline F28T5 system for the 4-foot T5 SO representative ballast type. Because the BF of 

the standards-case system at EL2 is slightly lower than the baseline system, the normalized input 

power is slightly higher than the measured input power. The opposite is true at EL3. If a direct 

substitution is made, mean lumen output does not change by more than seven percent relative to 

the mean lumen output of the baseline system. 
5-56

Table 5.57 Four-Foot T5 MiniBP SO Representative Ballast Type with F28T5 Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F28T5 

Lamps Electronic PS 277 Universal 1.01 67.3 55.7 82.8 5,846 5,362 0.0% $10.78 $6.40 67.3

EL1 2 F28T5 

Lamps Electronic PS 277 Universal 1.01 63.2 56.0 88.7 5,846 5,362 0.0% $10.85 $6.40 63.2

EL2 2 F28T5 

Lamps Electronic PS 277 Universal 0.97 60.1 53.9 89.6 5,624 5,158 -3.8% $11.92 $6.40 62.5

EL3 2 F28T5 

Lamps Electronic PS 277 Universal 1.08 64.9 59.9 92.3 6,244 5,727 6.8% $15.36 $6.40 60.7
5-57

5.16 PROGRAMMED START BALLASTS THAT OPERATE TWO FOUR-FOOT 

MINIBP T5 HO LAMPS

The PS product class includes four representative ballast types, including ballasts that 

operate two 4-foot MiniBP T5 HO lamps. DOE presents its analysis of this ballast type in the 

following sections. 

5.16.1 Baseline Models 

For the 2-lamp 4-foot MiniBP T5 HO normal BF representative ballast type (hereafter 

referred to as the 4-foot T5 HO representative ballast type), DOE chose to analyze one baseline 

ballast. DOE believes that F54T5HO lamps encompass the vast majority of 4-foot T5 HO lamps 

sales.15 Therefore, DOE has chosen to only analyze the F54T5HO baseline ballast. 

Currently there is no federal minimum energy conservation standard for ballasts that 

operate F54T5HO lamps. In addition, only relatively efficient 4-foot T5 HO electronic ballasts 

are sold on the U.S. market. Like the 4-foot T5 SO representative ballast type, DOE recognizes 

that inefficient 4-foot T5 HO ballasts may be introduced to the U.S. market and purchased 

widely by consumers if a standard for 4-foot T5 HO ballasts is not established. Because 

inefficient 4-foot T5 HO ballasts do not exist currently, DOE developed a baseline model 4-foot 

T5 HO ballast by determining the difference in BLE between baseline and EL2 2-lamp MBP PS

ballasts. More information on how DOE developed this baseline model is outlined in appendix 

5B and section 5.15.1. The baseline 4-foot T5 HO ballast has the characteristics shown in the 

table below. Although this ballast is not commercially available today, it is the lowest efficiency 

ballast that may be commercially available when standards take effect.

Table 5.58 Baseline Ballast for the Four-Foot T5 MiniBP HO Representative Ballast Type 

For 

Operation 

of

BF Ballast Type

Input 

Power 

(W)

BLE (%)

Federal Energy 

Conservation 

Standard

F54T5HO 0.95 Electronic 122.3 84.2% N/A

DOE paired the 2-lamp 4-foot T5 HO ballast with an appropriate F54T5HO lamp. DOE 

chose a 4-foot T5 HO lamp that just meets the ECS issued in the 2009 Lamps Rule which 

becomes effective in 2012 as this will be the most common lamp available after the ballast rule 

takes effect. The characteristics of this lamp are listed in the table below. 

 

15 Currently only two manufacturers sell a 4-foot MiniBP T5 HO lamp that is not a F54T5HO. One manufacturer 

sells a reduced wattage (F51T5HO). Another manufacturer sells a F49T5HO.
5-58

Table 5.59 Lamps for Use with F54T5HO Ballasts

Lamp 

Type

CCT Rated Efficacy* Initial Light 

Output

Mean Light 

Output Life CRI

K lm/W lm lm hr

F54T5HO 4,100 92.9 5,000 4,600 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F54T5HO lamp is 

53.8W.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp-and-ballast combination creates a 

system lumen package of approximately 9,516 mean lumens (and 8,755 initial lumens). 

5.16.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 4-foot T5 HO representative ballast type. As discussed in the screening 

analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE than the 

baseline ballast. Because the baseline ballast is an inefficient electronic ballast, improvements 

required the use of the following design options: improved components and improved circuit 

design. The highest EL represents the maximum technologically feasible level.

EL1. This level represents an improvement over the baseline T5 efficiency. This level is 

characterized by the least efficient electronic ballasts on the market today.

EL2. Ballasts at this level use slightly better components and circuit designs than those ballasts 

that meet EL1. 

EL3. EL3 represents the maximum technologically feasible level. Ballasts at this level use 

slightly better components and circuit designs than those ballasts that meet EL2. 

Table 5.60 Summary of ELs for Four-foot T5 HO Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 2.48 * ln(total lamp arc power) + 77.87 2.5 * ln(total lamp arc power) + 78.5

EL2 2.48 * ln(total lamp arc power) + 78.86 2.5 * ln(total lamp arc power) + 79.5

EL3 1.79 * ln(total lamp arc power) + 83.33 1.8 * ln(total lamp arc power) + 84.0

Figure 5.9 illustrates the three ELs on a plot of 4-foot T5 HO ballasts. A star indicates a 

representative unit tested by DOE. A circle indicates a representative unit theoretically 

developed. Diamonds indicate other 4-foot T5 HO ballasts tested by DOE.
5-59

 

80.000

82.000

84.000

86.000

88.000

90.000

92.000

94.000

96.000

98.000

100.000

75.000 85.000 95.000 105.000 115.000 125.000 135.000 145.000

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

0 F54T5HO Baseline

Figure 5.9 Efficiency Levels for the Four-Foot T5 MiniBP HO Representative Ballast Type 

Table 5.61 provides detailed information on the 4-foot T5 HO ballast designs used in the 

engineering analysis and subsequent analyses. For the F54T5HO ballasts, the ballast 

characteristics either improve or remain the same as the magnetic baseline system. 

Table 5.61 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) Lamp Arc Power (W) 

BLE (%) 

Baseline 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.98 <10 0.95 122.3 103.0 84.2

EL1 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.98 <10 0.95 113.0 102.4 90.6

EL2 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.98 <8 0.94 111.2 101.6 91.4

EL3 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.98 <10 0.95 110.1 101.8 92.4 

5.16.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 4-foot T5 HO representative ballast type to develop 

appropriate MSPs. The EL1, EL2, and EL3 MSPs were estimated using the blue book-sourced 

MSPs as described in section 5.6.2. DOE used the same technique described for establishing the 
5-60

baseline T5 SO ballast MSP to establish an MSP for the baseline T5 HO baseline. DOE assumed 

that the ratio of the baseline 4-lamp 4-foot T8 MBP PS ballast to the 4-lamp 4-foot T8 PS EL3

ballast would be the same as the ratio between the baseline/EL2 to EL1 4-foot T5 HO ballasts. 

DOE found that the MSP increased with increased efficiency as depicted in the table below.

Table 5.62 Manufacturing Selling Prices for the Four-Foot T5 MiniBP HO Representative

Ballast Type 

Efficiency Level Lamp Type MSP (2009$)

Baseline F54T5HO $9.61

EL1 F54T5HO $12.58

EL2 F54T5HO $14.70

EL3 F54T5HO $16.76

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule. 

Table 5.63 Retail Prices for Four-Foot MiniBP HO Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F54T5HO $4.28

5.16.4 Results

Table 5.64 presents the engineering characteristics of the ballast replacement options for 

the baseline F54T5HO system in the 4-foot T5 HO representative ballast type. Because the BF of 

the standards-case system is slightly lower than the baseline system at EL2 and EL3, the 

normalized input power is slightly higher than the measured input power. If a direct substitution 

is made, mean lumen output does not change by more than one percent relative to the mean 

lumen output of the baseline system. 
5-61

Table 5.64 Four-Foot T5 MiniBP HO Representative Ballast Type with F54T5HO Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.95 122.3 103.0 84.2 9,516 8,755 0.0% $9.61 $8.56 122.3

EL1 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.95 113.0 102.4 90.6 9,516 8,755 0.0% $12.58 $8.56 113.0

EL2 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.94 111.2 101.6 91.4 9,445 8,689 -0.7% $14.70 $8.56 112.0

EL3 2 F54T5HO 

Lamps Electronic PS 277 Universal 0.95 110.1 101.8 92.4 9,456 8,700 -0.6% $16.76 $8.56 110.8
5-62

5.17 BALLASTS THAT OPERATE TWO EIGHT-FOOT RDC HO LAMPS

5.17.1 Baseline Models 

For the 2-lamp 8-foot RDC HO IS and RS representative ballast type (hereafter referred 

to as the 8-foot HO representative ballast type), DOE chose to analyze two baseline ballasts. 

DOE found the market share of 8-foot HO (T8 and T12) standard application ballasts (excluding 

cold temperature sign ballasts) to be about 0.5 percent. DOE believes most of the 8-foot HO 

ballasts currently shipped are T12. However, the 2009 Lamps Rule will reduce the number of 

T12 HO lamps and increase the number of T8 HO lamps shipped by promulgating more 

stringent lamp standards. Therefore, DOE analyzed both T12 and T8 ballasts as baseline ballasts. 

Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 

2012, DOE created an F96T12HO/ES lamp that complied with the 2009 Lamps Rule to pair with 

T12 ballasts (see section 5.9.1). Because only the most efficient T12 lamps will be available 

when this ballast rulemaking takes effect, DOE chose to analyze only those T12 ballasts that 

operate F96T12HO/ES lamps for this rulemaking. For the T8 baseline, DOE chose to analyze 

only those ballasts that operate the F96T8HO lamp because this lamp is the most common 8-foot 

HO T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two 

F96T12HO/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 

CFR Part 430.32 (m)(5)). This energy conservation standard did not eliminate magnetic ballasts 

from the market. Therefore, DOE chose a magnetic ballast as the F96T12HO/ES baseline ballast. 

To determine the BLE of the baseline ballast, DOE tested multiple ballasts operating a reference 

F96T12HO/ES lamp. The BLE, BF, and input power of the most common T12 ballast that just 

meets the minimum energy conservation standard of 68.0 percent (BEF of 0.42) is shown in 

Table 5.65 below. All T12 magnetic ballasts in product catalogs are RS, single voltage, and have 

a high PF (>0.90). The ballast that just meets the energy conservation standard also exhibits 

these characteristics. DOE also chose a ballast that has an input voltage of 277V because the 

majority of ballasts operate in commercial buildings at 277V. THD values range from <25 

percent to <18 percent. DOE chose a ballast with a THD of <18 percent because it represented 

the least efficient T12 ballast.

Currently there is no federal minimum energy conservation standard for ballasts that 

operate F96T8HO lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE 

chose the most common, least efficient ballast on the market. DOE tested a range of F96T8HO 

ballasts from multiple ballast manufacturers and found that the least efficient but most common 

ballast exhibited the characteristics shown in the table below. The vast majority of F96T8HO 

ballasts are electronic and have a high PF (>0.95). Furthermore, the majority of the least efficient 

T8 ballasts have a THD <20 percent. Finally, like the F96T12HO/ES baseline ballast, DOE 

chose a ballast that has an input voltage of 277V as the majority of ballasts operate in 

commercial buildings at 277V. 
5-63

Table 5.65 Baseline Ballasts for the Eight-Foot RDC HO Representative Ballast Type 

For Operation 

of

Starting Method, 

Input Voltage, Ballast 

Type, PF, THD

BF

Input 

Power 

(W)

BLE (%)

Federal Energy 

Conservation 

Standard

2, F96T12HO/ES 

Lamps

RS, 277V, Magnetic, 

Single Voltage, ≥0.90, 

PF, <18% THD

0.87 201.7 69.9%* 68.0%

2, F96T8HO 

Lamps

RS, 277V, Electronic, 

Single Voltage, >0.98 

PF, <20% THD

0.78 176.0 80.4%* N/A

DOE paired 8-foot HO ballasts with an appropriate F96T12HO/ES or F96T8HO lamp. 

DOE chose 8-foot HO lamps that just meet the ECS issued in the 2009 Lamps Rule which 

requires compliance in 2012 as these will be the most common lamps available after the ballast 

rule takes effect. The characteristics of these lamps are listed in the table below. 

Table 5.66 Lamps for Use with F96T8HO and F96T12HO/ES Ballasts 

Lamp Type

CCT Rated 

Efficacy*

Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F96T12HO/ES 4,100 91.9 8,910 8,019 12,000 N/A

F96T8HO 4,100 91.9 7,900 7,100 24,000 78

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12HO/ES lamp is 

97W and for the F96T8HO lamp is 86W. F96T12HO/ES lamps are rated with a low-frequency 

reference ballast. F96T8HO lamps are rated with a high-frequency reference ballast.

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp-and-ballast combination creates a 

system lumen package of approximately 13,954 mean lumens (and 15,505 initial lumens) for the 

baseline F96T12HO/ES ballast, approximately 11,107 mean lumens (and 12,359 initial lumens) 

for the baseline F96T8HO ballast. 

5.17.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the 8-foot RDC HO representative ballast type. As discussed in the 

screening analysis (NOPR TSD chapter 4), DOE used design options that achieved a higher BLE 

than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements 

required the use of the following design options: electronic ballasts, improved components, and 

improved circuit design. For the 8-foot RDC HO representative ballast type, DOE identified 

three ELs. EL3 represents the maximum technologically feasible level.

EL1. This level only affects the T12 baseline and represents a modest improvement over the 

baseline T12 efficiency. Ballasts at this level are electronic instead of magnetic. Both T12 and 

T8 ballasts can meet this level. 
5-64

EL2. Again, this level affects only the T12 baseline. No T12 ballasts meet this level. The least 

efficient T8 ballasts just meet this level.

EL3. This level affects both the T8 and T12 baseline. EL3 is met by the most efficient T8 ballast 

tested and represents the max-tech EL. These T8 ballasts use slightly better components and 

circuit designs than EL2. 

Table 5.67 Summary of ELs for Eight-foot RDC HO Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 1.49 * ln(total lamp arc power) + 72.22 1.5 * ln(total lamp arc power) + 72.8

EL2 1.49 * ln(total lamp arc power) + 83.33 1.5 * ln(total lamp arc power) + 84

EL3 1.49 * ln(total lamp arc power) + 84.32 1.5 * ln(total lamp arc power) + 85

Figure 5.10 illustrates the three ELs on a plot of 8-foot HO (IS and RS) ballasts. A star 

indicates a representative unit tested by DOE. Diamonds indicate other 8-foot RDC HO ballasts 

tested by DOE.

 

65.000

70.000

75.000

80.000

85.000

90.000

95.000

100.000

0.000 50.000 100.000 150.000 200.000 250.000

8ft HO EL3

8ft HO EL2

8ft HO EL1

Average measured lamp arc power (W)

BLE 

(%)

F96T8HO Baseline

F96T12HO/ES Baseline

Figure 5.10 Efficiency Levels for the Eight-Foot RDC HO Representative Ballast Type 

Table 5.68 provides detailed information on the 8-foot HO ballast designs used in the 

engineering analysis and subsequent analyses. For the more efficient F96T12HO/ES and 

F96T8HO ballasts, the ballast factor is lower than that of the baseline ballast.
5-65

Table 5.68 Ballast Designs for the Eight-Foot RDC HO Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) Lamp Arc Power 

(W) 

BLE (%)

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Dedicated 0.98 <20 0.87 201.7 156.6 69.9

EL1 2 F96T12HO/ES 

Lamps Electronic RS 277 Dedicated 0.98 <20 0.83 176.0 141.4 80.4

Baseline

/EL2

2 F96T8HO 

Lamps Electronic IS 277 Dedicated 0.95 <20 0.78 147.0 134.5 91.5

EL3 2 F96T8HO 

Lamps Electronic IS 277 Universal 0.97 <14 0.78 144.5 133.6 92.5

5.17.3 Lamp and Ballast Prices 

DOE analyzed each EL for the 8-foot HO representative ballast type to develop 

appropriate MSPs. The baseline, EL1, baseline/EL2 and EL3 were each estimated using blue 

book-sourced MSPs as described in section 5.6.2. 

Table 5.69 Manufacturing Selling Prices for the Eight-Foot RDC HO Representative 

Ballast Type 

Efficiency Level Lamp Type MSP

$

Baseline F96T12HO/ES $13.25

EL1 F96T12HO/ES $9.55

Baseline/EL2 F96T8HO $8.15

EL3 F96T8HO $11.05

The following table depicts the appropriate lamp prices for the baseline lamps as used in 

the 2009 Lamps Rule (see section 5.9.3).

Table 5.70 Retail Prices for Eight-Foot RDC HO Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F96T12HO/ES $12.35

F96T8HO $6.57

5.17.4 Results

Table 5.71 presents the engineering characteristics of the ballast replacement options for 

the baseline F96T12HO/ES system in the 8-foot HO representative ballast type. Because the BF 

of the standards-case system decreases at higher ELs, the normalized input power is higher than 
5-66

the measured input power. If a direct substitution is made, mean lumen output decreases relative 

to the baseline system. 

DOE found that the baseline/EL2 ballast has higher normalized input power than the EL1 

ballast, even though the EL2/baseline ballast is more efficient than the EL1 ballast. The reason 

for this result is that the F96T12HO/ES lamp is more efficacious than the F96T8HO lamp. DOE 

selected lamps that just meet the 2009 Lamps Rule standards to pair with its representative 

ballasts. Though both the F96T12HO/ES lamp and F96T8HO lamp are required to meet the 

same lumens per watt energy conservation standard, the F96T12HO/ES lamp is tested with a 

low-frequency ballast while the F96T8HO lamp is tested with a high-frequency ballast. As a 

result, the 8-foot HO lamp efficacy standard is less stringent for the F96T8HO lamp because it 

receives an efficacy boost due to high-frequency operation. This difference in lamp efficacy 

outweighs in the increase in ballast efficiency at baseline/EL2, but not at EL3. 
5-67

Table 5.71 Eight-Foot RDC HO Representative Ballast Type with F96T12HO/ES Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Dedicated 0.87 201.7 156.6 69.9 15,505 13,954 0.0% $13.25 $24.70 201.7

EL1 2 F96T12HO/ES 

Lamps Electronic RS 277 Dedicated 0.83 176.0 141.4 80.4 14,838 13,354 -4.3% $9.55 $24.70 183.9

Baseline

/EL2

2 F96T8HO 

Lamps

Electronic IS 277 Dedicated 0.78 147.0 134.5 91.5 12,359 11,107 -20.4% $8.15 $13.13 184.7

EL3 2 F96T8HO 

Lamps Electronic IS 277 Universal 0.78 144.5 133.6 92.5 12,273 11,030 -21.0% $11.05 $13.13 182.8

Table 5.72 presents the engineering characteristics of the ballast replacement options for the baseline F96T8HO system for the 

8-foot RDC HO representative ballast type. Because the BF of the standards-case system is lower than the baseline system, the 

normalized input power is higher than the measured input power. If a direct substitution is made, mean lumen output decreases 

relative to the baseline system.

Table 5.72 Eight-Foot RDC HO Representative Ballast Type with F96T8HO Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) System Initial Light Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline/

EL2

2 F96T8HO 

Lamps Electronic IS 277 Dedicated 0.78 147.0 134.5 91.5 12,359 11,107 0.0% $8.15 $13.13 147.0

EL3 2 F96T8HO 

Lamps Electronic IS 277 Universal 0.78 144.5 133.6 92.5 12,273 11,030 -0.7% $11.05 $13.13 145.5
5-68

5.18 BALLASTS THAT OPERATE FOUR EIGHT-FOOT HO LAMPS IN COLD 

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS 

5.18.1 Baseline Models 

For the 4-lamp 8-foot HO representative ballast type for cold temperature or sign ballasts

(hereafter referred to as the sign ballast representative ballast type), DOE chose to analyze one 

baseline ballast. DOE evaluated the cold temperature ballast market and found the market share 

to be relatively small – about 1 percent in 2005. However, despite their small market share, high 

output ballasts designed for cold-temperature outdoor signage have large potential energy 

savings per ballast. Moving from a magnetic to an electronic sign ballast can reduce energy 

consumption by as much as 25 to 35 percent. DOE research indicated that ballasts that operate in 

outdoor signs or in other cold temperature applications are designed for use with T12 lamps. 

Therefore, DOE chose a T12 ballast as a baseline for this representative ballast type. DOE paired 

the ballast with an F96T12HO lamp that represented the most common cold temperature lamp 

available in the market today. 

Current standards cover ballasts that operate two F96T12HO/ES lamps designed to 

operate at ambient temperatures of −20 °F or less and designed for use in an outdoor sign expired 

for ballasts manufactured after July 1, 2010. (10 CFR 430.32(m)) However, DOE determined 

that four-lamp, full-wattage F96T12HO lamp and ballast systems were the most common. 

Therefore, in choosing the baseline ballast for this market sector, DOE tested several sign 

ballasts that operate F96T12HO lamps and chose the most common and least efficient ballast on 

the market as listed in Table 5.73. The vast majority of sign ballasts are magnetic, RS, and 

operate at a low BF. Furthermore, the majority of the least efficient sign ballasts are single 

voltage and operate four 8-foot HO lamps. Finally, DOE chose a ballast that has an input voltage 

of 120V as the majority of ballasts operate in outdoor signs at 120V. The BEF, BF, and input 

power of this ballast are shown in Table 5.73. 

Table 5.73 Baseline Ballasts for the Sign Ballast Representative Ballast Type 

For 

Operation of

Starting Method, 

Input Voltage, 

Ballast Type

BF

Input 

Power 

(W) 

BLE (%)

Federal Minimum 

Energy 

Conservation 

Standard

4, F96T12HO 

Lamps

RS, 120V, Magnetic, 

Single Voltage 0.73 390.3 71.4% N/A

DOE paired 8-foot HO ballasts with an appropriate F96T12HO lamp. Because lamps 

used in cold temperature applications were not covered by the 2009 Lamps Rule, DOE chose a 

cold temperature 8-foot HO lamp that represents the most common lamp available in the market 

today. The characteristics of this lamp are listed in the table below. 
5-69

Table 5.74 Lamps for Use with Cold Temperature F96T12HO Ballasts 

Lamp Type

CCT Rated Efficacy*

Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F96T12HO 4200 63.3 8,600 6,966 12,000 60

This combination of lamp and ballast represents the most common configuration for these 

ballasts in existing and new installations. Together, this lamp-and-ballast combination creates a 

system lumen package of approximately 20,350 mean lumens (and 25,124 initial lumens) for the 

baseline F96T12HO ballast. 

5.18.2 Efficiency Levels

The following discussion identifies the steps and technologies associated with each EL 

DOE considered for the sign ballast representative ballast type. As discussed in the screening 

analysis (NOPR TSD chapter 4), DOE used design options that achieve a higher BLE than the 

baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the 

use of an electronic ballast. For the sign ballast representative ballast type, DOE identified one 

EL. EL1 represents the maximum technologically feasible level.

EL1. This level represents an improvement in efficiency over the baseline ballast. Ballasts at this 

level are electronic rather than the magnetic ballasts that meet the baseline level. 

Table 5.75 Summary of ELs for Sign Ballasts 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without 

Variation Reduction

EL1 1.49 * ln(total lamp arc power) + 81.34 1.5 * ln(total lamp arc power) + 82

Figure 5.11 illustrates the one EL on a plot of sign ballasts. A star indicates a 

representative unit tested by DOE. Diamonds indicate other sign ballasts tested by DOE.
5-70

 

65.000

70.000

75.000

80.000

85.000

90.000

95.000

100.000

0.000 50.000 100.000 150.000 200.000 250.000 300.000 350.000 400.000 450.000

Sign Ballasts

EL1

Average measured lamp arc power (W)

BLE 

(%)

F96T12HO/ES Baseline

Figure 5.11 Efficiency Levels for the Sign Ballast Representative Ballast Type 

Table 5.76 provides detailed information on the 8-foot HO ballast designs used in the 

engineering analysis and subsequent analyses.

Table 5.76 Ballast Designs for the Sign Ballast Representative Ballast Type Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD (%) Ballast Factor Input Power (W) 

Lamp Arc Power 

(W) 

BLE (%) 

Baseline 2 F96T12HO 

Lamps Magnetic RS 120 Dedicated - - 0.73 390.3 316.4 71.4

EL1 2 F96T12HO 

Lamps Electronic IS 120 Universal - - 0.62 276.5 249.8 90.3

5.18.3 Lamp and Ballast Prices 

DOE analyzed each EL for the sign ballast representative ballast type to develop 

appropriate MSPs. In general, DOE developed ratios between online ballast suppliers and 

teardown-sourced MSPs. Using these supplier-specific ratios, DOE scaled online sign ballast 

prices to the MSP. As depicted in the table below, DOE found the EL1 MSP to be less than the 

baseline. Manufacturers indicated the magnetic ballast (baseline) would be sold at a higher price 

than the more efficient electronic ballast (EL1) due to higher prices of raw material. 
5-71

Table 5.77 Manufacturing Selling Prices for the Sign Ballast Representative Ballast Type 

Efficiency Level Lamp Type MSP (2009$)

Baseline F96T12HO 40.23

EL1 F96T12HO 35.58

Because DOE did not analyze 8-foot HO cold temperature fluorescent lamps in the 2009 

Lamps Rule, DOE developed the price for that lamp using the same methodology employed in 

the 2009 Lamps Rule. The resultant price is shown in the table below. 

Table 5.78 Retail Prices for Eight-Foot HO Cold Temperature Fluorescent Lamps

Lamp Type Retail Price 

(2007$)

F96T12HO $4.84

5.18.4 Results

Table 5.79 presents the engineering characteristics of the ballast replacement options for 

the baseline F96T12HO system in the sign ballast representative ballast type. Because the BF of 

the standards-case system is lower than the baseline system, the normalized input power is 

higher than the measured input power. If a direct substitution is made, mean lumen output would 

decrease by no more than 15 percent because of the lower ballast factor.
5-72

Table 5.79 Sign Ballast Representative Ballast Type with F96T12HO Baseline Efficiency Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Ballast Factor Input Power (W) Lamp Arc Power (W) BLE (%) 

System Initial Light 

Output (lm)

System Mean Light 

Output (lm)

Percentage Change 

Mean Lumen 

Output (%)

Ballast 

Manufacturer 

Selling Price ($)

Lamp Retail Price 

($)

Normalized Input 

Power (W)

Baseline 4 F96T12HO 

Lamps Magnetic RS 120 Dedicated 0.73 390.3 316.4 71.4 25,124 20,350 0.0% $40.23 $19.34 390.3

EL1 4 F96T12HO 

Lamps Electronic IS 120 Universal 0.62 276.5 249.8 90.3 21,479 17,398 -14.5% $35.58 $19.34 323.5
5-73

5.19 SCALING TO PRODUCT CLASSES NOT ANALYZED

DOE identified and selected certain product classes as “representative” product classes on 

which to concentrate its analytical effort. DOE chose these representative product classes 

primarily due to their high market volumes. Variables such as number of lamps and ballast factor 

are accounted for in the EL equation due to the change in lamp arc power. As a result, DOE 

analyzed four representative product classes (with 10 total representative ballast types) leaving 

only one product class for scaling. DOE analyzed the 8-foot HO IS and RS product class directly 

and scaled the results to develop ELs for the 8-foot HO PS product class. 

To scale to the 8-foot HO PS product class, DOE developed a relationship between IS 

and PS ballasts. DOE paired 4-foot MBP IS and PS ballasts of the same product family and from 

the same manufacturer and calculated the average ratio in BLE for all the pairs. Comparisons of 

IS versus PS ballast BLE among 8-foot HO ballasts were not available. DOE found that on 

average, PS ballasts were two percent less efficient than comparable IS ballasts. Therefore, DOE 

multiplied the EL equations assigned to the 8-foot HO IS and RS product class by 0.98 to 

generate the 8-foot HO PS product class EL equations. 

Table 5.80 Summary of ELs for the 8-foot HO PS Product Class 

Efficiency Level BLE Requirement With Variation 

Reduction

BLE Requirement Without Variation 

Reduction

EL1 1.46 * ln(total lamp arc power) + 70.77 1.47 * ln(total lamp arc power) + 71.34

EL2 1.46 * ln(total lamp arc power) + 81.66 1.47 * ln(total lamp arc power) + 82.32

EL3 1.46 * ln(total lamp arc power) + 82.63 1.47 * ln(total lamp arc power) + 83.30

5.20 EFFICIENCY LEVEL SUMMARY

Table 5.81 lists the EL equations developed by DOE with the 0.8 percent reduction for 

lab-to-lab variation and compliance requirements. Table 5.82 lists the EL equations developed by 

DOE without the reduction. 

Table 5.81 Efficiency Level Equations With Variation Reduction

Product Class Efficiency Level BLE

IS and RS Ballasts

EL1 2.98 * ln(total lamp arc power) + 72.61

EL2 2.48 * ln(total lamp arc power) + 79.16

EL3 1.32 * ln(total lamp arc power) + 86.11

PS Ballasts

EL1 2.48 * ln(total lamp arc power) + 77.87

EL2 2.48 * ln(total lamp arc power) + 78.86

EL3 1.79 * ln(total lamp arc power) + 83.33

8-foot HO IS and RS Ballasts

EL1 1.49 * ln(total lamp arc power) + 72.22

EL2 1.49 * ln(total lamp arc power) + 83.33

EL3 1.49 * ln(total lamp arc power) + 84.32

8-foot HO PS Ballasts EL1 1.46 * ln(total lamp arc power) + 70.77
5-74

EL2 1.46 * ln(total lamp arc power) + 81.66

EL3 1.46 * ln(total lamp arc power) + 82.63

Sign Ballasts EL1 1.49 * ln(total lamp arc power) + 81.34

Table 5.82 Efficiency Level Equations Without Variation Reduction 

Product Class Efficiency Level BLE

IS and RS Ballasts

EL1 3 * ln(total lamp arc power) + 73.2

EL2 2.5 * ln(total lamp arc power) + 79.8

EL3 1.33 * ln(total lamp arc power) + 86.8

PS Ballasts

EL1 2.5 * ln(total lamp arc power) + 78.5

EL2 2.5 * ln(total lamp arc power) + 79.5

EL3 1.8 * ln(total lamp arc power) + 84.0

8-foot HO IS and RS Ballasts

EL1 1.5 * ln(total lamp arc power) + 72.8

EL2 1.5 * ln(total lamp arc power) + 84.0

EL3 1.5 * ln(total lamp arc power) + 85.0

8-foot HO PS Ballasts 

EL1 1.47 * ln(total lamp arc power) + 71.34

EL2 1.47 * ln(total lamp arc power) + 82.32

EL3 1.47 * ln(total lamp arc power) + 83.30

Sign Ballasts EL1 1.5 * ln(total lamp arc power) + 82.0

The figures below depict the EL equations for each representative product class on a plot 

of the ballasts tested in that representative product class. 

75.0

80.0

85.0

90.0

95.0

100.0

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

Figure 5.12 IS and RS Product Class
5-75

80.000

82.000

84.000

86.000

88.000

90.000

92.000

94.000

96.000

98.000

100.000

0.0 50.0 100.0 150.0 200.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

Figure 5.13 PS Product Class

65.000

70.000

75.000

80.000

85.000

90.000

95.000

100.000

0.0 50.0 100.0 150.0 200.0 250.0

EL3

EL2

EL1

Average measured lamp arc power (W)

BLE 

(%)

Figure 5.14 Eight-foot HO Product Class
5-76

65.000

70.000

75.000

80.000

85.000

90.000

95.000

100.000

0.0 50.0 100.0 150.0 200.0 250.0 300.0 350.0 400.0 450.0

Sign Ballasts

EL1

Average measured lamp arc power (W)

BLE 

(%)

Figure 5.15 Sign Ballast Product Class 

5.21 MSP COMPARISON

As described in section 5.6, DOE developed MSP using three main inputs. These inputs 

included physical teardown analysis, blue book manufacturer price lists, and confidential 

manufacturer supplied data. Table 5.83 lists the prices based on each information source for each 

representative ballast type. DOE also presents plots for the three representative ballast types with 

the most complete data in Figure 5.16, Figure 5.17, and Figure 5.18. All manufacturer supplied 

MSP data included in these figures are aggregations of multiple data points. 

As described in section 5.6, DOE used an average of blue book- and teardown-based 

MSPs when developing the final MSP to be assigned to an EL. Manufacturer MSPs were used 

for normalization and verification purposes. DOE chose to use the blue book and teardown data 

because this data was available in the public domain allowing for verification by DOE and 

interested parties. Manufacturer data is less verifiable by interested parties, so DOE decided not 

to use it as the primary data source for developing MSP data. Furthermore, manufacturer data 

was not available for all ELs in all representative ballast types.

Table 5.83 Summary of MSP Data

Final 

($)

Blue Book 

($)

Teardown 

($)

Manufacturer 

($)

Two-Lamp MBP IS 

and RS

Baseline 8.41 8.41 11.89

Baseline/EL 1* 6.94 6.94 6.94 6.94

EL 2 8.85 8.36 9.34 7.45

EL 3 9.27 8.51 10.04 9.06

Four-Lamp MBP IS 

and RS

Baseline/EL 2* 9.79 9.79 9.79 9.79

EL 3 11.63 12.18 11.09 12.47
5-77

Eight-foot SP 

Slimline

Baseline/EL 1 8.84 8.84 12.75

Baseline/EL 2 10.05 10.05 8.75

EL 3* 10.29 10.29 10.29 10.29

Two-Lamp MBP IS 

and RS Residential

Baseline 4.68 4.68

Baseline/EL 1 3.77 3.77

EL 2

EL 3* 4.62 4.62 4.62

Two-Lamp MBP PS

Baseline* 8.39 8.39 8.39 8.39

EL 1

EL 2 9.28 10.38

EL 3 9.59 9.61 9.58 13.64

Four-Lamp MBP 

PS

Baseline 9.05 9.05

EL 1* 11.84 11.84 11.84

EL 2

EL 3 13.33 13.33

Two Lamp T5 

MiniBP SO

Baseline 10.78 9.63

EL 1* 10.85 10.85

EL 2 11.92 11.92 11.92

EL 3 15.36 15.36

Two Lamp T5 

MiniBP HO

Baseline 9.61 9.61

EL 1* 12.58 12.58 12.58

EL 2 14.70 14.70

EL 3 16.76 16.76 12.08

Eight-foot RDC HO 

IS and RS 

Baseline* 13.25 13.25 13.25

EL 1 9.55 9.55 17.54

Baseline/EL 2 8.15 8.15

EL 3 11.05 11.05

Sign Ballasts

Baseline 40.23 40.23

EL 1 35.58 35.58

* MSPs were normalized to the EL marked with an asterisk.

Figure 5.16 Two-lamp MBP IS and RS Representative Ballast Type MSP Data

6.00

7.00

8.00

9.00

10.00

11.00

12.00

13.00

MSP ($)

Blue Book

Manufacturer

Teardown

Final
5-78

Figure 5.17 2-lamp MBP IS and RS Representative Ballast Type MSP Data

6.00

7.00

8.00

9.00

10.00

11.00

12.00

13.00

14.00

15.00

Baseline EL 1 EL 2 EL 3

MSP ($)

Blue Book

Manufacturer

Teardown

Final

Figure 5.18 8-foot SP Slimline Representative Ballast Type MSP Data 

6.00

7.00

8.00

9.00

10.00

11.00

12.00

13.00

14.00

MSP ($)

Blue Book

Manufacturer

Teardown

Final
5-79

REFERENCES

 

1 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial 

Reports, Fluorescent Lamp Ballasts, MQ335C. (Last accessed April 4, 2011). 

<http://www.census.gov/mcd>