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 REQ UIREMENTS

............... 5-6

5.6 PRICING ANALYSIS OVE RVIEW

.............................................................................. 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 PRODU CT CLASSES

............................................................... 5-13

5.8 REPRESENTATIVE BALLAST TYPES

..................................................................... 5-13

5.9 INSTANT AND RAPID ST ART 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 ST ART BALLASTS THAT OP ERATE FOUR FOUR

- FOOT

MBP AND TWO

- FOOT U

- SHAPED LAMPS IN THE COMM ERCIAL 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 ST ART BALLASTS THAT OP ERATE 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 RA PID START BALLASTS T HAT OPERATE TWO FOUR

FOOT 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

............................................................................................... 5-365- ii 

### 5.12.3 Lamp and Ballast Prices

................................ ..................................................... 5-38

5.12.4 Results

................................................................................................................ 5-39

5.13 PROGRAMMED START BAL LASTS THAT OPERATE T WO 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 BAL LASTS THE OPERATE FO UR FOUR

- FOOT MBP

AND FOUR TWO

- FOOT U

- SHAPED LAMPS

.......................................................... 5-47

5.14.1 Ba seline 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 BAL LASTS THAT OPERATE TWO FOU R- 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 BAL LASTS THAT OPERATE T WO 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 APPLICAT IONS OR OUTDOOR SIGN S ..................................... 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*................. 5-115- iii 

### Table 5.4 Calculated Manufacturer Markup s for Fluorescent Lamp Ballasts ........................... 5-11 Table 5.5 Representative Product Classes ................................................................................. 5-13

Table 5.6 Baseline Ballasts for the 2

- lamp MB P 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 E Ls 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 a nd RS Representative Ballast Type .......................................................................................... 5-27

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

Table 5.20 Fo ur

- 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

- Foo t 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 Res idential 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

Ta ble 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 ................. 5-475- iv 

### Table 5.45 Lamps for Use with F32T8 Ba llasts ........................................................................ 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 Repres entative 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 RD C HO Fluorescent Lamps ..................................... 5-65 Table 5.71 Eight- Foot RDC HO Representative Ballast Type with F96T12HO/ES Baseline .. 5-67

Table 5.72 E ight

- 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 Ba llast 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 S ummary of MSP Data ............................................................................................ 5-765-v 

### LIST OF FIGURES

Figure 5.1 Manufacturer Selling Price ......................................................................................... 5-7 Figure 5.2 Efficie ncy 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 Ball ast 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 Ba llast Type MSP Data ................................... 5-785-1 

### 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 analy sis 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 (TS D 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 M ETRIC

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 f luorescent 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 measurem ent 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 calcul ates 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) fro m 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 meas ures 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 5 C presents the se 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 consum er economics.

Select More Efficient Lamp -and-Ballast Designs: DOE selects commercially available ballasts with higher BLE s as replacement s for each baseline ballast in the representative ballast

type s 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 of5-3 

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

. Appendix 5C presents the se 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 la mp and ballast system in the engineering analysis. Though

ballasts are capable of operating several different lamp wattages, DO E chooses the most common fluorescent lamp used with each ballast for analysis. DOE develops the engineering analysis based on tw o 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 giv en product class; and (3) the maximum technologically feasible effic ien cy 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

deve loped 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 l evels 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 refle ctor 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 th e 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 Meth odology

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

five f 

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

for non- representative ballast types. Afte r 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 prod uct 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 p ower 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 o bservation, 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 multipl ied BEF by the number of lamps assigned to the standard, by the lowfrequency reference lamp arc power included in the fluorescent la mp 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 powe r 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 8 3.2 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 71.35-6 

### 5.4.4 Maxi mum Technologically Feasible Efficiency Level s

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, i n 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 use d the average of three samples. A fter 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

secon d 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,

a fter 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 balla sts 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 book5-7 

### prices from manufacture r 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 pri ces 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 th e 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 profi t associated with manufacturing and selling a product. The full cost of production is broken down into two main costs: the fullproduction 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

paragr aphs 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 thes e 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 estimate s 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 pro duct. 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 correspond ing 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

cos ts 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 Units5-9 

### 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 p otting 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 U niversal 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 Sin gle 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

manufac turer 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 gro ss 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 5.6-25- 11 

### Table 5.3 contains the calculated gross profit margins f or four sample manufacturers.

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

Parameter Industry

Weighted Average Manufacturer

A B C D

Net Sales Million $ 66,614 90,705 46,95 2 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

mark et 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 f ile 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 man ufacturer 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, manufa cturers generally indicated that the average5- 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 teardown

sourced 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 assig ned 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 manufacturer

supplied 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 a vailable 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 adj acent 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 multip le 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 teardown

sourced 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 no rmalized 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 REPR ESENTATIVE PRODUCT CLASSES

As discussed in the market and technology assessment ( NOPR TSD chapter 3), DOE is proposing to revis e 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 anal yze.

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.

summ arizes 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

residen tial 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 four

lamp ballasts. Although IS and R S 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 th ese 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

.

Section s 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 d iscussing 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

l amp 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 OPERAT E TWO FOU RFOOT 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 presen ts 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 f or 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 b allast 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 c omplied 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 b ecause only the most efficient T12 lamps will be

available when this ballast rulem aking 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 i n choosing the most appropriate F32T8 and

F34T12 ballasts for th e 2- lamp MBP IS and RS representative ballas t 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 voltages j 

### (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 conserva tion 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 base line 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 k 

### ) is shown in Table 5.6 below. The majority of F34 T12 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 balla sts 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, Singl e 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 5.45- 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 basel ine 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 , f or 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 type s, EL s affect only one of the two baseline ballasts . For example,

EL1 may require a more efficient T12 ballast than t he 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 ball asts. Finally, D OE 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

flu orescent 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, improvements5- 18 

### require d 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 me et 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. N o T12 ballast that is commercially available

can meet this level. Ballasts at this l evel 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 improve ment 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 E Ls for Two

- Lamp MBP IS and RS Ballasts

Eff iciency 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) + 8 6.8



### 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. D iamonds 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 deta iled 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,

h ave 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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

/E L1 2 F32T8 Lamps Electronic IS 277 Single 0.98 <20% 0.90 61.1 52.4 85.8

E L2 2 F32T8 Lamps Electronic IS 277 Universal 0.98 <10% 0.90 58.1 52.4 90.2

E L3 2 F32T8 Lamps Electronic IS 277 Single 0.98 <10% 0.84 52.8 48.7 92.2



### 5.9.3 Lamp and Ballast Prices5- 20 

### DOE analyzed each EL for th e 2- lamp MBP IS and RS representative ballas t type todevelop appropriate MSPs. For the F34T12 baseline ballast, DOE based the price on blue booksourced MSPs described in section 5.6.2 and f

or the F32T8 ballasts (EL1 though EL 3) , 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 Summ ary of the Manufacturing Selling Prices for the 2-L amp 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 i n 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 cur rently 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 bal lasts 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 th e 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 c hange 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 system5- 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

dardsCase S

dardsCase S Baseline

dardsCase S 

### InputPower MLO MLO InputPower Normalized

tan

tan tan 

### ∗ =

dardsCase S 

### InputPower Normalized

tan 

### = Input power of the standards- case system that

matches the light output of the baseline system

Baseline 

### MLO = Mean lumen output of the baseline system

dardsCasee S 

### MLO

tan 

### = Mean lumen output of the standards- case system

dardsCasee S 

### InputPower

tan 

### = Input power of the standards- case system5- 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 mor e 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System InitialLight Output (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (W)

Baseline

/ E L1 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

E L2 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 5 8.1

E L3 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 relativ ely 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System InitialLight Output (lm)System MeanLight Output (lm)PercentageChange MeanLumen Output(%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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

EL 1 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

E L2 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

E L3 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 49.75- 24 

### 5.10 INSTANT AND RAPID START BALLASTS THAT OPERAT E FOUR FOUR

FOOT MBP AND TWO

- FOOT U

- SHAPED LAMPS IN THE COMMERCIAL SECTOR

Th e 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 represent ative 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 o f 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 27 7V.

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

Conserva tion

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 li sted 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

DO E 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 T 8 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 feasib le 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 Requiremen t 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 l amp arc power) + 8 6.8



### 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 engine ering 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 <1 0 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 MSP s 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 LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput PowerLamp Arc PowerBLE (%)5- 27 

### Table 5.18 Summary of the Manufacturing Selling Price for the 4

- lamp MBP IS and RS Representative Ballast Type

Efficiency Level L amp 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 ballas t 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 F 32T8 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 $11.29 110.45- 29 

### 5.11 INSTANT AND RAPID ST ART BALLASTS THAT OPERATE TWO EIGHT

FOOT SP SLIMLINE LAM PS

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

RS bal lasts 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 slim line 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 balla sts 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 electro nic 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 en erg y 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. Finall y, 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 balla st 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- Fo ot 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 th e 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 basel ine 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 ball ast 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

effici ent circuit designs than those ballasts that just meet EL1.

EL3 . This level affects both the baseline T12 and T8 ballast. N o 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 Requ irement 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(t otal lamp arc power) + 8 6.8



### 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 Sl imline Representative Ballast TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput Power (W)Lamp Arc Power(W)BLE (%)

Baseline

/EL1 2 F96T12ES Lamps Electr onic 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 F 96T12/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 replacem ent options for the baseline F96T12/ES system in the 8- foot SP slimline representative ballast type . Because the

BF of the standards- case system s 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 Ball ast Type with F96T12/ES BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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

Baseli ne

/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 p resents 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 system s 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System InitialLight Output (lm)System MeanLight Output (lm)PercentageChange MeanLumen Output(%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 $11.84 107.35- 35 

### 5.12 INSTANT START AND RAPID START BALLASTS THAT OPERATE TWO

FOUR

- FOOT MBP AND TWO

- FOOT U

- SHAPED LAMPS IN THE R ESIDENTIAL

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 residentia l sector. DOE presents its analysis of this ballast type in the following se ctions.

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 s hipment 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 e liminate 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 mos t 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 m ost 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 ballast s 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 majo rity 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, 1 20V, 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 j ust 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 base line 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 u sed design options that achieve a higher BLE than the5- 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

EL 2 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) + 8 6.8



### Figure 5.5 illustrates the three ELs on a plot of residential bal lasts

. 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 Baseline5- 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 Repres entative Ballast TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput Power (W)Lamp Arc Power(W)BLE (%)

Baseline 2 F34T12 Lamps Electronic RS 120 Dedicated

- <2 0 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 an alyzed 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 th e 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 MSP s 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

Lam p 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 i ncrease 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallastFactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (W)

Baseline 2 F34 T12 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 Electro nic 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 balla st 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 s even percent relative to the mean lumen output of the baseline system.

Table 5.36 Residential Representative Ballast Type with F32T8 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System InitialLight Output (lm)System MeanLight Output (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 51.25- 41 Lamps5- 42 

### 5.13 P ROGRAMMED S TART B ALLASTS THAT OPERATE TWO F OUR -F OOT

MBP AND TWO-F OOT U- SHAPED L AMPS

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 ( B EF)

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 identifi es the steps and technologies associated with each E L

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 ma ximum technologically feasible level.

EL 1 . 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. Specif ically, 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 th ose ballasts that just meet EL 2.

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(tot al 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 1.7 9 * ln(total lamp arc power) + 83.33 1. 8 * ln(total lamp arc power) + 84



### F igure 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 Effi ciency Levels for the 2- lamp MBP PS Representative Ballast Type

Table 5.40 Ballast Designs for the 2- lamp MBP PS Representative Ballast TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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 MSP s 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 Type5- 45 Efficiency Level Lamp Type Starting Method MSP (2009$)

Bas eline 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (W)

Baseline 2 F32T8 Lamps Electronic PS 277 Universal 0.91 63.1 52.7 83.5 5,452 5,17 9 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 57.85- 47 

### 5.14 PROGRAMMED START BAL LASTS THE OPERATE FO UR 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- sha ped 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 t ype), 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 typ e, 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 Represe ntative 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 pa ired 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 the se 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 discu ssion 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

max imum technologically feasible level.

EL 1 . 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 us e 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

Reduct ion 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. 7 9 * ln(total lamp arc power) + 8 3. 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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 MSP s 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 F32T 8 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 baseli ne F32T8 system in the PS representative ballast type

. Because the BF of the standards

case system s at EL 1 and EL 3 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 $11.29 104.55- 52 

### 5.15 PROGRAMMED START BALLASTS THAT OPERAT E TWO F OUR

- 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 l amp 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 ball asts 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 MB P 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 represent s 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 Typ e 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 wi th 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 ini tial 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 a n 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 a n improvement over the baseline T5 efficiency. This level is characterized by the least efficient elect ronic 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 a n 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 te sted 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 Rep resentative 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 improv e or remain the same as the magnetic baseline system.

Table 5.54 Ballast Designs for the Four

- Foot T5 MiniBP SO Representative Ballast TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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 bal last 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, DOE5- 55 

### assumed that the ratio of th e 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

i ncreased 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 (200 9 $ )

Baseline F28T5 $1 0. 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

- Fo ot 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 repres entative 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 BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 60.75- 57 

### 5.16 PROGRAMMED START BALLASTS THAT OPERAT E TWO FOUR

- FOOT

MINIBP T5 HO LAMPS

The PS product class includes four representative ballast types, including ballas ts that operate two 4 -foot Mini BP 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 ballas t type (hereafter

referred to as the 4

- foot T5 HO representative ballast type ) , DOE chose to analyze one baseline ballast. DOE believes that F54T5HO lamp s 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, on ly 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 cons umers 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 Cur rently 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 F 54 T5 HO 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 wa ttage 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 lum en 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 discusse d 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 n 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 a n improvement over the baseline T5 efficiency. This level is characterized by the least efficient electroni c 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 com ponents 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 Variati on 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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 the5- 60 

### baseline T5 SO ballast MSP to establish an MSP for the baseline T5 HO baseline. DOE assumed

that the ratio of the baseli ne 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 $1 4.70

EL3 F54T5H O $1 6.76



### 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 Pr ice (2007$)

F54T5HO $4.28



### 5.16.4 Results

Table 5.64 presents the engineering characteristics of the ballast replacement options for

the baseline F 54 T5 HO system in the 4 -foot T5 HO representative ballast type . Because the BF of

the st andards- 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 H O Representative Ballast Type with F 54 T5 HO BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 F54T 5HO Lamps Electronic PS 277 Universal 0.94 111.2 101.6 91.4 9,445 8,689

- 0.7% $1 4.70 $8.56 112.0

EL3 2 F54T5HO Lamps Electronic PS 277 Universal 0.95 1 10.1 101.8 92.4 9,456 8,700

- 0.6% $1 6.76 $8.56 110.85- 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 conservat ion 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

mee ts 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 th e 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 ha s 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 Met hod, 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 t able 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. F 96T8HO 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

syst em 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 ide ntified

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. Bot h 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

Effici ency 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. Diamond s 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD (%)Ballast FactorInput 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 0.7 8 147.0 134.5 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 $1 1.05



### 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

T able 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 inp ut power is higher than5- 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 t he EL2/baseline ballast is more efficient than the EL1 bal last. 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 L amp s 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 ba llast. 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 basel ine/EL2, but not at EL3.5- 67 

### Table 5.71 Eight-Foot RDC HO Representative Ballast Type with F96T12HO/ES BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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

La mps 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% $1 1.05 $13.13 182.8



### Table 5.72 presents th e 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 Base lineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE (%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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% $1 1.05 $13.13 145.55- 68 

### 5.18 BALLASTS THAT OPERAT E FOUR EIGHT

- FOOT HO LAMPS IN COL D

TEMPERATURE APPLICATIONS OR OUTDOOR SIGN S

5.18.1 Baseline Models

For the 4- lamp 8 -foot HO representative ballast type for cold te mperature 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 balla st 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 choos ing 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 b allasts 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 4 200 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 a n 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 * l n(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 ballast s. 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 TypeEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal orSingle VoltagePower FactorTHD(%)Ballast FactorInput 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 balla st ( 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 F96 T12HO 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 characte ristics 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 measur ed 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 F96T 12HO BaselineEfficiency LevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltageBallast FactorInput Power (W)Lamp Arc Power(W)BLE(%)System Initial LightOutput (lm)System Mean LightOutput (lm)Percentage ChangeMean LumenOutput (%)BallastManufacturerSelling Price ($)Lamp Retail Price($)Normalized InputPower (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 $19.34 323.55- 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 e ffort. 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 pair s. 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 th e 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. 4 8 * ln(total lamp arc power) + 77.87

EL2 2.48 * ln(total lamp arc power) + 7 8.86

EL3 1. 79 * ln(total lamp arc power) + 8 3.33

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) + 70.775- 74 EL2 1.4 6 * ln(total lamp arc power) + 81.66

EL3 1.4 6 * ln(total lamp arc power) + 8 2.63 Sign Ballasts EL1 1.49 * ln(total lamp arc power) + 8 1.34



### Table 5.82 Efficiency Level Equations Without Variation Reduct ion

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) + 8 6.8

PS Ballasts EL1 2.5 * ln(total lamp arc power) + 7 8.5

EL2 2.5 * l n(total lamp arc power) + 79. 5

EL3 1. 8 * ln(total lamp arc power) + 8 4.0

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 Ballast s 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) + 8 3.30 Sign Ballasts EL1 1.5 * ln(total lamp arc power) + 8 2.0



### The figures below depict the EL equ ations 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 Class5- 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 Class5- 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 a nd 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 t ypes.

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 12.475- 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

a nd 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 mark ed 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 13.00MSP ($) Blue Book

Manufacturer

Teardown

Final5- 78 

### Figure 5.17 2- lamp MBP IS and RS Representative Ballast Type MS P 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 3MSP ($) 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 14.00MSP ($) Blue Book

Manufacturer

Teardown

Final5- 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>