5-i 

### CHAPTER 5 ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION

........................................................................................................... 5-1

5.2 METHODOLOGY OVERVIEW

.................................................................................... 5-1

5.3 PRICING ANALYSIS OVERVIEW

.............................................................................. 5-3

5.3.1 Manufacturer Production Costs ........................................................................... 5-4

5.3.1.1 Selection of Units ..................................................................................... 5-5

5.3.2 Manufacturer Markup

.......................................................................................... 5-5 5.3.2.1 Manufacturer Selling Price ...................................................................... 5-6

5.3.2.2 Manufacturer Financial Information Sources .......................................... 5-6

5.3.3 MSP Scaling

......................................................................................................... 5-8

5.4 REPRESENTATIVE PRODUCT CLASSES

................................................................. 5-8

5.5 BALLASTS THAT OPERA TE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

.......................................................................................................... 5-10

5.5.1 Baseline Models

................................................................................................. 5-11

5.5.2 Candidate Standard Levels

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

5.5.3 Lamp and Ballast Prices

..................................................................................... 5-17

5.5.4 Results

................................................................................................................ 5-18

5.6 BALLASTS THAT OPERATE FOUR FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

.......................................................................................................... 5-22

5.6.1 Baseline Models

................................................................................................. 5-22

5.6.2 Candidate Standard Levels

................................................................................ 5-24

5.6.3 Lamp and Ballast Prices

..................................................................................... 5-26

5.6.4 Results

................................................................................................................ 5-27

5.7 BALLASTS THAT OPERATE TWO EIGHT

- FOOT SP SLIMLINE LAMPS

.......... 5-29

5.7.1 Baseline Models

................................................................................................. 5-29

5.7.2 Candidate Standard Levels

................................................................................ 5-31

5.7.3 Lamp and Ballast Prices

..................................................................................... 5-33

5.7.4 Results

................................................................................................................ 5-33

5.8 BALLASTS THAT OPERATE TWO EIGHT

- FOOT RDC HO LAMPS

................... 5-37

5.8.1 Baseline Models

................................................................................................. 5-37

5.8.2 Candidate Standard Levels

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

5.8.3 Lamp and Ballast Prices

..................................................................................... 5-41

5.8.4 Results

................................................................................................................ 5-41

5.9 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 SO LA MPS

.......... 5-44

5.9.1 Baseline Models

................................................................................................. 5-44

5.9.2 Candidate Standard Levels

................................................................................ 5-45

5.9.3 Lamp and Ballast Prices

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

5.9.4 Results

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

5.10 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 HO LA MPS

.......... 5-49

5.10.1 Baseline Models

................................................................................................. 5-49

5.10.2 Candidate Standard Levels

................................................................................ 5-50

5.10.3 Lamp and Ballast Prices

..................................................................................... 5-525- ii 

### 5.10.4 Results 5-52

5.11 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS IN THE RESIDENTIAL SECTOR

................................................ 5-54

5.11.1 Baseline Models

................................................................................................. 5-54

5.11.2 Candidate Standard Levels

................................................................................ 5-56

5.11.3 Lamp and Ballast Prices

..................................................................................... 5-58

5.11.4 Results 5-58

5.12 BALLASTS THAT OPERATE FOUR EIGHT

- FOOT HO LAMPS IN COLD

TEMPERATURE APPLICAT IONS OR OUTDOOR SIGN S ..................................... 5-61

5.12.1 Baseline Models

................................................................................................. 5-61

5.12.2 Candidate Standard Levels

................................................................................ 5-62

5.12.3 Lamp and Ballast Prices

..................................................................................... 5-64

5.12.4 Results 5-64

5.13 SCALING TO PRODUCT CLASSES NOT ANALYZED

.......................................... 5-66

5.13.1 Number of Lamps .............................................................................................. 5-66

5.13.2 Starting Method ................................................................................................. 5-67

5.13.3 Ballast Factor

..................................................................................................... 5-67

5.13.4 Scaling 5-68

5.13.5 All CSLs

............................................................................................................. 5-69

REFERENCES

.......................................................................................................................... 5-72

LIST OF TABLES

Table 5.3.1 Ballast Types for Teardowns .................................................................................... 5-5 Table 5.3.2 Gross Profit Margin for Four Fluorescent Lamp Ballast Manufacturers* ................ 5-7 Table 5.3.3 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts .......................... 5-7 Table 5.4.1 DOE Product Classes for Fluorescent Lamp Ballasts ............................................ 5-10 Table 5.5.1 Representative Product Classes for Ballasts that Operate Two Four -Foot MBP and

Two -Foot U-Shaped Lamps ....................................................................................................... 5-11 Table 5.5.2 Baseline Ballasts for the IS and RS Representative Product Class ........................ 5-12

Table 5.5 .3 Baseline Units for the PS Representative Product Class ........................................ 5-13 Table 5.5.4 Lamps for Use with F32T8 and F34T12 Ballasts ................................................... 5-13

Tab le 5.5.5 Summary of the CSLs for Two

- Lamp Four

- Foot MBP RS and IS Normal BF

Ballasts ....................................................................................................................................... 5-15 Table 5.5.6 Ballast Designs for the IS and RS Representative Product Class ........................... 5-17 Table 5.5.7 Ballast Designs for the PS Representative Product Class ....................................... 5-17 Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS R epresentative

Product Class ............................................................................................................................. 5-18 Table 5.5.9 Summary of the Manufacturing Selling Prices for the PS Representative Product

Class ........................................................................................................................................... 5-18

Table 5.5.10 Retail Prices for Four -Foot Medium Bipin Fluorescent Lamps .......................... 5-18 Table 5.5.11 IS and RS Representative Product Class with F32T8 Baseline ............................ 5-20 Table 5.5.12 IS and RS Representative Product Class with F34T12 Baseline .......................... 5-20

Table 5.5.13 Four- Foot MBP PS Product Class ........................................................................ 5-21 Table 5.6.1 Representative Product Classes for Ballasts that Operate Four Four -Foot MBP and

Two -Foot U-Shaped Lamps ....................................................................................................... 5-225- iii 

### Table 5.6.2 Baseline Ballasts for the I S and RS Representative Product Class ........................ 5-23 Table 5.6.3 Baseline Ballasts for the PS Representative Product Class .................................... 5-23 Table 5.6.4 Lamp for Use with F32T8 Ballasts ......................................................................... 5-23 Table 5.6.5 Ballast Designs for the IS and RS Representative Product Class ........................... 5-26

Table 5. 6.6 Ballast Designs for the PS Representative Product Class ....................................... 5-26 Table 5.6.7 Summary of the Manufacturing Selling Price for the IS and RS Representative

Product Class ............................................................................................................................. 5-26 Table 5.6.8 Summary of the Manufacturing Selling Price for the PS Representative Product

Class ........................................................................................................................................... 5-27

Table 5.6.9 Retail Prices for Four -Foot Medium Bipin Fluorescent Lamps ............................ 5-27

Table 5.6.10 Four- Lamp Four -Foot MBP RS and IS Product Class with F32T8 Baseline ....... 5-28

Table 5.6.11 Four- Lamp Four -Foot MBP PS Product Class with F32T8 Baseline ................. 5-28 Table 5.7.1 Representative Product Classes for Ballasts that Operate Two Eight

- Foot SP Slimline Lamps ......................................................................................................................................... 5-29 Table 5.7.2 Baseline Ballasts for the Eight

- Foot SP Slimline Representative Product Class ... 5-30 Table 5.7.3 Lamps for Use with F96T8 and F96T12/E S Ballasts ............................................. 5-30 Table 5.7.4 Ballast Designs for the Eight- Foot SP Slimline Representative Product Class ...... 5-32

Table 5.7.5 Manufa cturing Selling Prices for the Eight-Foot SP Slimline Representative Product

Class ........................................................................................................................................... 5-33

Table 5.7.6 Retail Prices for Eight -Foot SP Slimline Fluorescent Lamps ................................ 5-33 Table 5.7.7 Eight -Foot SP Slimline Representative Product Class with F96T12/ES Baseline . 5-35 Table 5.7.8 Eight

- Foot SP Slimline Representative Product Clas s with F96T8 Baseline ......... 5-35 Table 5.8.1 Representative Product Classes for Ballasts that Operate Two Eight

- Foot RDC HO Lamps ......................................................................................................................................... 5-37 Table 5.8.2 Baseline Ballasts for the Eight

- Foot RDC HO Representative Product Class ....... 5-38 Table 5.8.3 Lamps for Use with F96T8HO and F96T12HO/ES Ballasts ................................. 5-38 Table 5.8.4 Ballast Designs for the Eight- Foot RDC HO Representative Product Class .......... 5-40 Table 5.8.5 Manufacturing Selling Prices for the Eight-Foot RDC HO Repr esentative Product

Class ........................................................................................................................................... 5-41

Table 5.8.6 Retail Prices for Eight -Foot RDC HO Fluorescent Lamps .................................... 5-41 Table 5.8.7 Eight

- Foot RDC HO Representative Product Class with F96T12HO/ES Baseline 5-42 Table 5.8.8 Eight -Foot RDC HO Representative Product Class with F96T8HO Baseline ....... 5-43 Table 5.9.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MiniBP T5 SO Lamps

................................................................................................ ................................... 5-44 Table 5.9.2 Baseline Ballast for Four-Foot T5 MiniBP SO Represe ntative Product Class ....... 5-44 Table 5.9.3 Lamps for Use with F28T5 Ballasts ....................................................................... 5-45 Table 5.9.4 Ballast Designs for the Four- Foot T5 M iniBP SO Representative Product Class .. 5-46 Table 5.9.5 Manufacturing Selling Prices for the Four-Foot T5 MiniBP SO Representative

Product Class ............................................................................................................................. 5-47

Table 5.9.6 Retail Prices for Four -Foot MiniBP SO Fluorescent Lamps ................................. 5-47

Table 5.9.7 Four -Foot T5 MiniBP SO Representative Product Class with F28T5 Baseline ..... 5-48 Table 5.10.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MiniBP T5 HO Lamps .................................................................................................................................. 5-49 Table 5.10.2 Baseline Ballast for the Four-Foot T5 MiniBP HO Representative Product Class .. 5-

49 Table 5.10.3 Lamps for Use with F54T5HO Ballasts ............................................................... 5-505- iv 

### Table 5.10.4 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Product Class 5-51

Table 5.10.5 Manufacturing Selling Prices for the Four- Foot T5 MiniBP HO Representative

Product Class ............................................................................................................................. 5-52

Table 5.10.6 Retail Prices for Four -Foot MiniBP HO Fluorescent Lamps .............................. 5-52 Table 5.10.7 Four-Foot T5 MiniBP HO Representativ e Product Class with F54T5HO Baseline 5-

53 Table 5.11.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP and

Two -Foot U-Shaped Lamps in the Residential Sector .............................................................. 5-54 Table 5.11.2 Baseline Ballasts for the Residential Representative Product Class ..................... 5-55 Table 5.11.3 Lamps for Use with F32T8 and F34 T12 Ballasts ................................................. 5-55 Table 5.11.4 Ballast Designs for the Residential Representative Product Class ....................... 5-57

Table 5.11.5 Manufacturing Selling Prices for the Residential Representative Product Class 5-58

Table 5.11.6 Retail Prices for Four -Foot MBP Fluorescent Lamps ......................................... 5-58 Table 5.11.7 Residential Representative Product Class with F34T12 Baseline ........................ 5-60 Table 5.11.8 Residential Representative Product Class with F32T8 Baseline .......................... 5-60 Table 5.12.1 Representative Product Classes for Ballasts that Operate Four Eight

- Foot HO Lamps in Cold Temperature Applications or Outdoor Signs .................................................... 5-61 Table 5.12.2 Baseline Ballasts for the Sign Ballast Representative Product Class ................... 5-61 Table 5.12.3 Lamps for Use with Cold Temperature F96T12HO Ballasts ............................... 5-62 Table 5.12.4 Ballast Designs for the Sign Ballast Representative Product Class ...................... 5-63

Table 5.12.5 Manufacturing Selling Prices for the Sign Ballast Representative Product Class ... 5-

64

Table 5.12.6 Retail Prices for Eight -Foot HO Cold Temperature Fluorescent Lamps ............. 5-64 Table 5.12.7 Sign Ball ast Representative Product Class with F96T12HO Baseline ................. 5-65 Table 5.13.1 Test Data Obtained for Ballasts that Operate Four -Foot Medium Bipin Lamps .. 5-66 Table 5.13.2 Example of Scaling Based on Number of Lamps ................................................. 5-68 Table 5.13.3 Example of Scaling Based on Starting Method .................................................... 5-69 Table 5.13.4 Example of Scaling Based on Ballast Factor ........................................................ 5-69 Table 5.13.5 CSLs for All Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps ......................................................................................................................................... 5-70 Table 5.13.6 CSLs for All Ballasts That Operate Eight- Foot SP Slimline Lamps .................... 5-70 Table 5.13.7 CSLs for All Ballasts That Operate Eight- Foot RD C HO Lamps ........................ 5-70 Table 5.13.8 CSLs for All Ballasts That Operate Four-Foot T5 MiniBP SO Lamps ................ 5-71

Table 5.13.9 CSLs for All Ball asts That Operate Four -Foot T5 MiniBP HO Lamps ............... 5-71 Table 5.13.10 CSLs for All Residential Ballasts That Operate Four -Foot MBP and Two-Foot UShaped Ballasts .......................................................................................................................... 5-71 Table 5.13.11 CSLs for All Cold Temperature or Outdoor Sign Ballasts ................................. 5-71

LIST OF FIGURES

Figure 5.3.1 Manufacturer Selling Price ...................................................................................... 5-3 Figure 5.5.1 Candidate Standard Levels for the IS and RS Representative Product Class ....... 5-15 Figure 5.5.2 Candidate Standard Levels for the PS Representative Product Class ................... 5-16 Figure 5.6.1 Candidate Standard Levels for the IS and RS Representative Product Class ....... 5-24 Figure 5.6.2 Candidate Standard Levels for the PS Representative Product Class ................... 5-255-v 

### Figure 5.7.1 Candidate Standard Levels for the Eight-Foot SP Slimline Representative Product

Class ........................................................................................................................................... 5-32 Figure 5.8.1 Candidate Standard Levels for the Eight-Foot RDC HO Representative Product

Class ........................................................................................................................................... 5-40 Figure 5.9.1 Candi date Standard Levels for the Four-Foot T5 MiniBP SO Representative Product

Class ........................................................................................................................................... 5-46 Figure 5.10.1 Candidate Standard Levels for the Four-Foot T5 MiniBP HO Representative

Product Class ............................................................................................................................. 5-51 Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class .... 5-57 Figure 5.12.1 Candidate Standard Le vels for the Sign Ballast Representative Product Class .. 5-635-1 

### CHAPTER 5 ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed an engineering analysis to establish the relationship between the manufacturer production cost (MPC) and the energy efficiency of fluorescent lamp ballasts (hereafter “ballasts”). The relationship between the MPC and energy efficiency, or the cost

- efficiency relationship, serves as the basis for cost

- benefit calculations for individual customers, manufacturers, and the Nation. This section provides an overview of the engineering analysis, discusses the representative product classes, establishes baseline unit specifications for those product classes, discusses incremental efficiency levels, discusses the analysis and results for the representative product classes, and establishes a scaling methodology to those product classes not analyzed.

The primary inputs of the engineering analysis are the design options from the screening analysis (preliminary 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 (preliminary TSD chapter 8), DOE used the industry cost- efficiency curves to determine customer prices for each product analyzed in the engineering analysis by applying the appropriate distribution channel markup s.

5.2 METHODOLOGY OVERVIEW

DOE typically structures its engineering analysis around one of three methodologies: (1) the design-option approach, which calculates the incremental cost of adding specific design options to the baseline model; (2) the efficiency

- level approach, which calculates the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; and/or (3) the reverse engineering cost

- assessment approach, which involves a “bottom- up” manufacturing cost assessment based on a detailed bill of materials (BOM) derived from teardowns of products being analyzed. Deciding which methodology to use for the engineering analysis depends on the product, the technologies under

stu dy, 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 t o 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 candidate standard levels (CSLs) from representative product classes to other product classes.5-2 

### Select Baseline Ballasts: For each representative product class, DOE establishes baseline ballasts. Generally, a baseline ballast is a commercially available ba llast that just meets existing Federal energy conservation standards and provides basic consumer utility. The baseline serves as a reference point for each product class, against which DOE measures changes from potential amended energy conservation standards. To determine energy savings and changes in price, DOE compares each higher energy

- efficiency level with the baseline unit.

If no standard exists for that specific ballast, the baseline ballast represents the typical ballast sold within a product class with the lowest ballast efficacy factor (BEF). To determine the BEF, DOE tests a range of ballasts from multiple manufacturers. Appendix 5 C presents the test results. DOE selects specific characteristics such as starting method, ballast factor (BF), and

i nput voltage to characterize the most common ballast. DOE also selects multiple ballasts in certain product classes to ensure consideration of different ballast types and their associated

consumer economics.

Select Candidate Lamp-and- Ballast Designs: DOE selects commercially available ballasts with a higher BEF as replacement s for each baseline ballast in the representative product classes by considering the design options identified in the technology assessment and screening analysis (preliminary TSD chap ter 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 ba llast to achieve a higher BEF. In identifying more efficacious substitutes, DOE uses a database of commercially available ballasts. DOE then tests these ballasts to establish their appropriate BEF. Appendix 5C presents the se test results. All BEF and BE va lues were calculated according to the active mode test procedure unless otherwise specified.

Because fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE considers properties of the entire lamp and ballast system in the engineering anal ysis. Though ballasts are capable of operating several different lamp wattages, DOE chooses the most common fluorescent lamp used with each ballast for analysis. DOE develops the engineering analysis based on two substitution cases. In the first case, the consumer is not allowed to change the spacing of the fixture and therefore replaces one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lumen

output. a



### Determine Candidate Standard Lev els

. DOE develops CSLs 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 CSL of a given product class; and (3) the max imum technologically feasible efficacy level. 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

.

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

a 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.5-3 

### product classes. The BOMs descr ibe the product in detail, including all manufacturing steps required to make and/or assemble each part. DOE then develops a cost model that converts the BOMs and efficiency levels into MPCs. By applying derived manufacturer markups to the MPCs, DOE calculates the manufacturer selling prices (MSPs) b



### DOE was not able to generate a BOM for all ballasts in this engineering analysis. In these cases, DOE evaluated retail prices for those ballasts and estimated an MSP for each one. For fluorescent lamps, DOE referenced the retail price for those lamps in the rulemaking for general service fluorescent and incandescent reflector lamps (hereafter “the 2009 Lamps Rule”).and constructs industry costefficiency curves.

c



### 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.

5.3 PRICING ANALYSIS OVERVIEW

Developing the MSP 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 5.3.1 shows the general breakdown of costs and profit associated with manufacturing and selling a product. The full cost of production is broken down into two main costs: the full production cost

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

overhead used to manufact ure a product in order to calculate the MPC. d 

### 5.3.1 Section describes

how DOE arrived at the MPC. Section 5.3.2 describes how DOE established a markup that

estimates non -production costs and profit.

Figure 5.3.1 Manufacturer Selling Price

b The MSP is the price at which the manufacturer can recover a ll 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.

c 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.

d When viewed from the company

- wide perspective, the sum of all material, labor, and overhead costs equals the

c ompany’s sales cost, also referred to as the cost of goods sold (COGS).5-4 

### 5.3.1 Manufacturer Production Costs

The MPC is composed of direct labor, direct material, and overhead costs. Direct material costs represent the direct purchase price of components (resistors, connecting wires, etc.). DOE

conduct ed customized teardown analyses for select commercially available fluorescent lamp ballasts. DOE also conducted a teardown analysis on some ballasts removed from a manufacturing facility before adding potting, a type of black pitch. For these ballasts, DOE needed to estimate the cost of potting material to calculate the full material and labor costs. Based on information provided by members of the potting industry, DOE estimated the material and labor costs for potting to be about 60 cents for the standard ballast enclosure, which is 1 x 1.5 x 8 inches. Therefore, DOE added 60 cents to the teardown estimates for “pre

- potting”

ballasts to estimate the full material and labor costs.

Manufacturers co mmented 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 componen t materials price quotes. The teardown estimates reflect component pricing for January 2009. DOE investigated how January 2009 estimates would change if a 5- year average of materials prices

w as 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 labo r costs associated with the assembly of the product. Separate labor rates were used for components that required manual (hand) insertion versus those that

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

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

The teardown results did not include overhead estimates . Overhead includes indirect material and labor costs, maintenance, depreciation, taxes, and insurance related to assets. DOE

used finan cial 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 (section 5.3.2 ). Then, DOE computed the ratio of aggregated teardown -sourced material and

labor costs to the manufacturer markdown sourced MPC. DOE found the material and labor costs to be about 93.8 percent of the MPC. DOE then subtracted the materials and labor and depreciation percentages from 100 percent to back out the remainder of overhead as a percentage of MPC. Overhead was estimated to be 3.6 percent of the MPC, which is reasonable as electronics manufacturing generally has low overhead costs. DOE found overhead and depreciation to be about 6.2 percent of the MPC or 6.6 percent of the material and labor costs. The 6.6 percent factor was then used to mark up the material and labor costs contained in the teardown results to the full production cost or MPC.5-5 

### 5.3.1.1 Selection of Units

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 hea t 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 ballas ts removed from a manufacturing facility before the potting procedure. Section

5.3.3 discusses how DOE estimated prices for those ballasts it could not or chose not to tear

down.

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

Table 5.3.1 lists the ballast types submitted for teardowns.

Table 5.3.1 Ballast Types for Teardowns

Ballast Starting

Method For Operation

of Input Voltage Regular vs. High Efficiency

1 PS 2 F32T8 Universal HE

2 PS 2 F32T8 Single REG

3 and 4 IS 2 F32T8 Universal HE

5 IS 2 F32T8 Universal REG

6 IS 2 F32T8 Single REG

7 IS 4 F32T8 Single REG

8 IS 4 F32T8 Universal REG

9 IS 4 F32T8 Univers al HE

10 and 11 IS 2 F59T8 Universal HE

12 IS 2 F59T8 Single REG

1 3 IS 2 F59T8 Universal REG



### 5.3.2 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 at5-6 

### 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.

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

investmen ts, 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 manufac turer 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 ana lysis, payback period (PBP) analysis, and national impact analysis ( NIA ). Through the use of the manufacturer and distribution chain markups and installation costs, DOE can calculate the first costs that customers would face under the various efficiency levels. DOE evaluates the tradeoff between the increase in first cost and the resulting energy cost savings at each efficiency level in the LCC and PBP analyses (preliminary TSD chapter 8) and NIA analysis (preliminary TSD chapter 10). In this section, DOE presents its methodology for converting the MPCs to manufacturer selling prices using the manufacturer markup.

5.3.2.1 Manufacturer Selling Price

DOE calculated the MSP for fluorescent lamp ballasts by multiplying the MPC by the calculated manufacturer markup, which is explained below. 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.

5.3.2.2 Manufacturer Financial Information Sources

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 th e manufacturer markup by using financial figures from manufacturers’

SEC 10

- K reports, such as the net sales (revenues) and cost of sales to calculate gross profit and gross profit margins. DOE used averages of the financial figures spanning 2002 to 2008 to calculate the markup.

DOE used the following equations to calculate the gross profit and gross profit margins:5-7 

### Equation 5.3-1

Gross Profit ($) = Net Sales

– Cost of Sales

Equation 5.3-2

Table 5.3.2 contains the calculated gross profit margins for four sample manufacturers.

Table 5.3.2 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 46,952 38,118 63,862

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

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

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8
* Data taken from 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10

- K reports.



### To calculate the time

- average gross profit margin for each firm, DOE first summed the gross profit for all the years and then divided the result by the sum of the net sales for those years. Each manufacturer’s markup was calculated as:

Equation 5.3-3

Table 5.3.3 shows the manufacturer markups using this method.

Table 5.3.3 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts

Manufacturer Manufacturer Markup

Manufacturer A 1.55

Manufacturer B 1.59

Manufacturer C 1.38

Manufacturer D 1.43
Average 1.50



### DOE calculated the average manufacturer markup to be 1.50 based on the estimated market share of each manufacturer. In other words, fluorescent lamp ballast manufacturers, on average, sell their products to the next party in the distribution channel at 50 percent above the manufacturing production cost.

Although publicly owned companies file SEC 10-K reports, the financial information summarized is not always exclusive to t he 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, DOE5-8 

### asked manu facturers to provide both the manufacturer markup and the manufacturer selling price of fluorescent lamp ballasts sold through two main distribution chains: from the manufacturer to an original equipment manufacturer (OEM), and from the manufacturer to a d istributor.

DOE supplemented the information provided in Table 5.3.3 by estimating a weighted

average manufacturer markup . DOE used information from DOE’s 2000 Ballast Rule, which

estimates that ballasts sold to a distributor represent 37 percent of the market, while ballasts sold to an OEM fixture manufacturer represent 63 percent of the market. 1



### DOE used these multipliers in the engineering analysis to determine the MSPs for each representative product class. DOE used a constant markup to reflect the MSPs of the baseline products as well as more e fficient 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 then applied these weights to the manufacturer markups provided directly by manufacturers. DOE also applied these weights to a manufacturer markup calculated by comparing the manufacturer selling prices and the estimated MPC. After considering these two additional sources of information, DOE determined that a manufacturer markup of approximately 1.50 on an aggregate basis for the

f luorescent lamp ballast industry was appropriate.

5.3.3 MSP Scaling

To estimate M SP s for additional ballasts types, DOE used online ballast supplier pricing to develop ratios relating online prices to teardown

- sourced MSPs. Using these ratios, DOE estimated MSPs for additional ballasts based on their online price.

To do this, DOE compiled an online price databa se for ballasts. Ballasts produced by the same manufacturer were assigned prices from one online supplier. In this way, DOE eliminated pricing variability among different online suppliers. Next, DOE created a manufacturer- specific ratio of online price to MSP for certain two -lamp 32- watt (W) electronic ballasts (ballasts 1 through 6 in Table 5.3.1 ). DOE believed these ratios to be representative of other product classes as well as those that operate two 32 W 4 -foot medium bipin lamps.

DOE then estimated MSPs for additional ballasts. For a given efficiency level, DOE identified comparable ballast examples across multiple manufacturers and obtained online prices for each ballast. DOE continued to use the same online suppliers for each manufacturer to be consistent with the development of the MSP ratios. DOE divided the online price by the MSP ratio to estimate the MSP for each ballast. Finally, the MSP for a particular CSL was estimated as an average of the MSPs of the various balla sts that just meet that CSL.

5.4 REPRESENTATIVE PRODUCT CLASSES

As discussed in the market and technology assessment (preliminary TSD chapter 3),

DOE is considering revising the Energy Policy and Conservation Act (EPCA) table of standards

for ballasts to co ntain 70 product classes (5-9 

### Table 5.4.1 ) . DOE chose to analyze at least one representative product class for each lamp type analyzed. For the most prevalent ballast type (ballasts that operate 4 -foot medium bipin (M BP ) and 2-foot U-shaped lamps), DOE chose to analyze multiple representative product classes. 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. 2 

### 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 and all starting methods for these ballasts. Although instant start (IS) and rapid start (RS) ballasts are the most common ballasts that operate 4

- foot MBP lamps, programmed star t (PS) ballasts are growing in market share. DOE limited its study to only

include those ballasts that exhibit a normal ballast factor (BF) , as this BF is the most common e



### .

DOE estimates the majority of ballasts that operate 4 -foot T5 miniature bipin (Min iBP)

standard -output (SO) lamps, 8-foot single pin (SP) lamps, 8-foot high output (HO), and

residential 4

- foot MBP lamps are two

- lamp ballasts. Therefore, DOE analyzed the two

- lamp ballast representative product class for these lamp types. DOE also decided to study only the

two

- lamp representative product class for ballasts that operate 4 -foot T5 MiniBP HO. Based on discussions with manufacturers and industry experts, DOE estimates that approximately 60 percent of ballasts that operate 4 -foot T5 MiniBP HO l amps are two

- lamp ballasts, 30 percent are

three

- lamp ballasts, and the remainder are one

- lamp or four- lamp ballasts. DOE chose to analyze

four- lamp sign ballasts because industry experts report these are the most common sign ballasts.

For all commercial ballast types, DOE limited its study to those ballasts that exhibit a normal ballast factor as this BF is the most common. DOE also chose to study only the IS and RS product class for ballasts that operate 8 -foot HO and residential 4- foot MBP lamps as these are the most common starting methods for these ballasts.

Although DOE did not create a separate engineering analysis for many product classes, DOE established standards for these product classes based on the representative product classes directly analyz ed. For instance, DOE extended its proposal for ballasts that operate two 4-foot T5 MiniBP HO lamps by testing ballasts that operate one, three, and four lamps and determining an appropriate scaling factor. Section 5.13 provides more information on extending standards to the product classes DOE did not analyze.

e 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- 10 

### Table 5.4.1 DOE Product Classes for Fluorescent Lamp Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Four

- Foot T5 Mini BP SO All High 37 38 N/A N/A N/A N/A

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

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

Four

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

Eight

- Foot SP Slimline All High 47 48 N/A N/A N/A N/A

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

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

Eight

- Foot RDC HO IS and RS All 53 54 N/A N/A N/A N/A

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

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

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

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

Sign Ballast, All Lamp Types All All 65 66 67 68 69 70

Shading indicates a representative product class.



### 5.5 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

DOE analyzed multiple efficiency levels and estimated the MPC and MSP for each of the representative product classes presented in section 5.4

. In this section, DOE analyzes the representative product classes designated by numbers 8 and 26 in the table below. All BEF and

BE values presented in this section were calculated according to the ac tive mode test procedure unless otherwise specified.5- 11 

### Table 5.5.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP

and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Method Ba llast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class.



### 5.5.1 Baseline Models

DOE selected baseline models as reference points for each product class, against which DOE measured changes resulting from potential amended energy conservation standards. As

discussed in section 5.2 , 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 product class (designated by product class 8 in Table 5.5.1 ; hereafter

referred to as the IS and RS representative product class) . 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

r epresented 86 percent of all 4-foot and 2-foot U- shaped MBP ballast shipments. f



### Table 5.5.4 Therefore, DOE analyzed both T12 and T8 ballasts as a baseline ballast. Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with the 2009 Lamps Rule to pair with T12 ballasts (see ). 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 rulemaking takes effect . For the T8 baseline, DOE chose to analyze only those ballasts that operate the F32T8 lamp because it is the most common 4-foot MBP T8 lamp.

DOE considered the ballast’s characteristics i n choosing the most appropriate F32T8 and F34T12 ballasts for the IS and RS product class. These characteristics include d 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, BEF, and type (electronic vs. magnetic),

and whether the ballast can operate at multiple voltages g

f 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. 

### (universal voltage) or only one (single voltage). Finally, DOE considered whether the ballast just meets existing Federal minimum

g Universal voltage ballasts can operate at 120V or 277V.5- 12 

### energy conserv ation 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 bas eline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F34T12 lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 1.35 is shown in Table 5.5.2 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 ballast because the majority of ballasts operate in commercial buildings at 277V.

Currently there is no federal minimum energy conservation standard for ballasts that operate F32T8 lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose the most common, least efficient ballast on the market. DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and found that the least efficient b ut most common ballast

exhibited the characteristics shown in Table 5.5.2 below. The vast majority of T8 ballasts are IS, electronic, and have a high PF (>0.98). 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 5.5.2 Baseline Ballasts for the IS and RS Representative Product Class

For operation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F34T12

lamps RS, 277V, Electronic, Single Vo ltage >0.98 PF,

<20% THD 0.86 63.5 80.1%* 1.359 1.35

2, F32T8

lamps IS, 277V, Electronic, Single Voltage, >0.98
PF, <20% THD 0.88 60.4 85.4%* 1.450 N/A

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the

re lationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, t he BEF of a ballast is related to ballast efficiency in the following

manner: BEF= 1.697 *BE

.



### For the 2- lamp 4 -foot MBP and 2- foot U -shaped PS normal BF product class (designated by product class 26 in Table 5.5.1 ; hereafter referred to as the PS representative product class)

, DOE found that only F32T8 ballasts operate in this product class. 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 5.5.3 below. This ballast does not use cathode cutout technology to reduce power, and thus exhibits a higher input power and lower BEF than

ballasts that have cathode cut -out technology. This ballast also, 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.5- 13 

### Table 5.5.3 Baseline Units for the PS Representative Product Class

For operation of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power Ballast Efficiency BEF Federal Energy

Conservation Standards (EF)

2, F32T8

lamps PS, 277V, Electronic, >0.99, <10% THD, Universal Voltage 0.90 63.5 84.3% 1.418 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 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 5.5.4 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 8 5

* 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 insta llations. Together, these lamp and ballast combinations create a system lumen package of approximately 4,872 mean lumens (and 5,412 initial lumens) for the baseline F34T12 ballast, approximately 4,988 mean lumens (and 5,250 initial lumens) for the

baselin e F32T8 IS ballast, and approximately 5,110 mean lumens (and 5,379 initial lumens) for

the baseline F32T8 PS ballast.

5.5.2 Candidate Standard Levels

For the 2- lamp 4 -foot and 2-foot U- shaped MBP product classes, DOE conducted a survey of the fluorescent lamp b allast market to determine what types of products are available to consumers. For each representative product class , DOE surveyed and tested many of the manufacturers’ product offerings for BEF and ballast efficiency to identify the efficiency levels

corre sponding to the highest number of models. DOE identified the most prevalent BEF values in the range of available products and established CSLs based on those products. Because the5- 14 

### baseline ballasts have different BEF values and represent various design opt ions, in some product classes CSLs affect only one of the two baseline lamps. For example, CSL1 may require a more efficient T12 ballast than the baseline T12 ballast, but not require a ballast more efficient than the T8 baseline. However, the full range o f CSLs ultimately specifies requirements that are above the BEF values of all the baseline ballasts sold, and therefore affect all baseline ballasts. Finally, DOE determined the maximum improvement in BEF that is technologically feasible (“max

- tech”) for f luorescent lamp ballasts, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To determine this level, DOE conducted a survey of the fluorescent lamp ballast market and the research fields that support the market. DOE believes that within a given p roduct class, no working prototypes exist that have a distinguishably higher BEF than currently available ballasts. Therefore the highest CSL presented, which represents the most efficient tier of commercially available ballasts, is the max

- tech level that DOE determined for this preliminary rulemaking. However, DOE presents additional research in appendix 5D of the preliminary TSD to explore whether technologies used in products similar to ballasts can be used to improve the efficiency of ballasts currentl y on the market. See appendix 5D for a detailed discussion of these technologies.

The following section identifies the steps and technologies associated with each CSL

DOE considered for the IS and RS representative product class. As discussed in the scree ning analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is an electronic ballast, improvements required the use of the following design options: lamp diameter, improved components, and improved circuit design.

CSL1 . BEF: 1.450; Efficiency: 85.4 percent

This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It requires the use of improved lamp diameters (T8 instead of T12). Therefore, no T12 ballasts meet this level. In addition, ballasts must use improved circuit designs (a starting method that is IS rather than RS).

CSL2 . BEF: 1.535; Efficiency: 90.5 percent

This level affects the both baseline ballasts. However, no T12 ballast that is commercially available can meet this level. Ballasts at this level use better components and more efficient circuit designs than those ballasts that just meet CSL1.

CSL3 . BEF: 1.561 ; Efficiency: 9 2.0 percent

This level again affects the both baseline ballasts and represents the maximum technologically feasible level. This level represents a modest improvement in efficiency over CSL2. Ballasts at this level use slightly better components and circuit designs than those ballasts that just meet

CSL2.5- 15 

### Table 5.5.5 Summary of the CSLs for Two

- Lamp Four

- Foot MBP RS and IS Normal BF

Ballasts

Candidate Standard Level BEF Requirement

CSL1 1.450

CSL2 1.5 35

CSL3 1.5 61



### Figure 5.5.1 illustrates the three CSLs on a plot of fluorescent lamp ballasts DOE selected to analyze. A line at 1.350 denotes the existing energy conservation standard. Square boxes and labels identify the two baseline ballasts. The plot shows replacement ballasts DOE considered for each baseline ballast at higher efficacies.

1.30 1.35 1.40 1.45 1.50 1.55 1.60

31 32 33 34 35Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL3

CSL2

CSL1

EPCA F34T12 F32T8

F32T8 Baseline

F34T12 Baseline



### Figure 5.5.1 Candidate Standard Levels for the IS and RS Representative Product Class

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

DOE considered for the PS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE considered design options that achieve a higher BEF 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 only one CSL. This CSL represents the maximum technologically

feasible level.5- 16 

### CSL1

. BEF: 1.51 8; Efficiency: 90.2 percent

This level requires the use of improved circuit designs for the PS ballast. Specifically, ballasts at

this level must use cut

- out cathode heating of the filament after the lamp starts.

Figure 5.5.2 illustrates the CSL on a plot with the baseline and standards -compliant ballast. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

1.41 1.43 1.45 1.47 1.49 1.51

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 PS Baseline



### Figure 5.5.2 Candidate Standard Levels for the PS Representative Product Class

Table 5.5.6 and Table 5.5 .7 provide detailed information on the 4- foot MBP ballast designs used in the engineeri ng analysis and subsequent analyses. In general, for the IS and RS representative product class, ballasts at higher efficiencies can operate at multiple voltages, have a lower THD, and similar BF and PF as the baseline ballast designs. For the PS represent ative product class, the ballast characteristics are very similar.5- 17 

### Table 5.5.6 Ballast Designs for the IS and RS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0.98 <20% 0.86 63.5 1.359 80.1%*

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%*

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5%

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, t he BEF of a ballast is related to ballast efficiency in the f ollowing manner: BEF= 1.697 *BE

.



### Table 5.5.7 Ballast Designs for the PS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F32T8 Lamps Electronic PS 277 Universal >0.99 <10% 0.90 63.5 1.418 84.3%

CSL1 2 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.86 56.9 1.518 90.2%



### 5.5.3 Lamp and Ballast Prices

DOE analyzed each CSL forthe IS and RS representative product class to develop appropriate MSPs. For the F34T12 baseline ballast, DOE used the online price scaling technique

described in section 5.3.3 . For all F32T8 ballasts, DOE generated an MSP from teardowns. As

shown in Table 5.5.8 , DOE found the MSP for the F34T12 ballast was higher than any of the

F32T8 ballasts. The F34T12 electronic ballast is sold at lower volumes than the electronic F32T8 ballasts represented by CSL1, CSL2, and CSL3. DOE attributes the smaller shipments volume to its high cost relative to its efficiency. In addition, physical teardown information suggests that

the efficient F32T8 ballast at CSL3 is le ss costly than the less efficient CSL2 ballast, but both CSL2 and CSL3 are more costly than CSL1.5- 18 

### Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS Representative Product Class

Can didate Standard Level Lamp Type Starting Method MSP $

Baseline F34T12 RS 10. 26

Baseline/CSL1 F32T8 IS 7. 43

CSL2 F32T8 IS 10.01

CSL3 F32T8 IS 8. 93



### DOE analyzed each CSL for the PS representative product class to develop appropriate

MSPs . DOE derived the baseline MSP from a teardown and the CSL1 MSP from the online price scaling technique. DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.5.9

.

Table 5.5.9 Summary of the Manufacturing Selling Prices for the PS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP $

Baseline F32T8 PS 8. 98

CSL1 F32T8 PS 12.49



### The following table depicts the appr opriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule. Although DOE calculated the performance characteristics of a T12 lamp such that it would comply with the standard adopted by the 2009 Lamps Rule, DOE assumed that the price of this T12 lamp would be the same as the representative T12 lamp that met trial standard level (TSL) 3 in the 2009 Lamps Rule. DOE believes that both TSL3 in the 2009 Lamps Rule and the market situation in 2014 are instances in which a very efficient T12 lamp com petes directly with cheaper T8 lamps. Therefore, DOE believes that price competition will prevent manufacturers from raising the price of T12 lamps any higher than the price at which the most efficient T12 lamps are currently sold.

Table 5.5.10 Retail Prices for Four

- Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price (2007$)

F34T12 $5.83

F32T8 $2.82



### 5.5.4 Results

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

clas ses to provide a comprehensive understanding of the consumer economics. DOE based its5- 19 

### engineering analysis on two substitution cases. In the first case, the consumer is not allowed to change the spacing of the fixtures and therefore replaces one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lumen output. Percentage change in mean lumen output is shown in Table 5.5.11 through

Table 5.5.13 . In the second case, the consumer is allowed to change the spacing of the fixture. To show how energy savings would change due to this change in fixture spacing, DOE shows the normalized system 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 5.5-1

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 system

Table 5.5.11 th rough Table 5.5.13 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 5.5.11 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in

the IS and RS representative product class. Because the BFs of the standards

- case systems are slightly lower than the baseline sy stem, 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 2 percent relative to the mean lumen output of the baseline system.5- 20 

### Table 5.5.11 IS and RS Representative Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4% * 5,250 4,988 N/A 7.43 5.65 60.4

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903

- 1.7% 10.01 5.65 57.0

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980

- 0.2% 8.93 5.65 56.5

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:

BEF= 1.697 *BE

.



### Table 5.5.12 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 system in the IS and RS representative product class. If a direct substitution is made, mean lumen output does not change by more than 3 percent relative to the mean lumen output of the baseline system.

Table 5.5.12 IS and RS Representative Product Class with F34T12 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0. 98 <20% 0.86 63.5 1.359 80.1% * 5,412 4,872 N/A 10.26 11.65 63.55- 21 CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4% * 5,250 4,988 2.4% 7.43 5.65 59.0

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 0.6% 10.01 5.65 55.7

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 2.2% 8.93 5.65 55.2

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relations hip between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 1.697 *BE

.



### Tab le 5.5.13 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the PS representative product class. If a direct substitution is made, mean lumen output does not change by more than 4 percent relative to the mean lumen output of the baseline system.

Table 5.5.13 Four

- Foot MBP PS Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F32T8 Lamps Electronic PS 277 Universal >0.99 <10% 0.90 63.5 1. 418 84.3% 5, 379 5, 110 N/A 8.98 5.65 63.5

CSL1 2 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.86 56. 9 1.51 8 90.2% 5,1 76 4,9 17

- 3. 8 12.49 5.65 59. 15-22 

### 5.6 BALLASTS THAT OPERATE FOUR FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS
In this section, DOE analyzes the representative product classes designated by numbers 10 and 28 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.6.1 Representative Product Classes for Ballasts that Operate Four Four

- Foot MBP

and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Method Ba llast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class.



### 5.6.1 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 product class (designated by product class 10 in

Table 5.6.1 ; hereafter referred to as the I S and RS representative product class) . 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 product class, DOE considered the ballast’s characteristics. Because there is no Federal energy conservation standard, DOE

chose a baseline ballast that exhibits the characteristics of the least efficient and most common

ballast.

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

the least efficient but most common ballast exhibited the characteristics shown in Table 5.6.2 below. The vast majority of T8 ballasts are IS, electronic, and have a high PF (>0.99).

Furth ermore, the majority of the least efficient T8 ballasts are single voltage and have a THD <10 percent. Finally, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.5- 23 

### Table 5.6.2 Baseline Ballasts for the IS and RS Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

4, F32T8

Lamps IS, 277V, Electronic, Single Voltage, >0.99
PF, <10% THD 0.84 111.5 90.5% 0.768 N/A



### For the 4- lamp 4 -foot MBP and 2- foot U -shaped PS normal BF product class (designated by product class 28 in Table 5.6.1 ; hereafter referred to as the PS representative product class)

, DOE also found that only F32T8 ballasts operate in this product class. 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 5.6.3 . This ballast does not use cathode cutout technology to reduce power, and thus exhibits a higher input power and lower BEF than

ballasts that have cathode cut -out technology. This b allast also, like the majority of PS ballasts on the market is electronic, has a high PF (~0.99) and has a low THD (<10 percent).

Table 5.6.3 Baseline Ballasts for the PS Representative Product Class

For Oper ation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

4, F32T8

Lamps PS, 277V, Electronic, Single Voltage, 0.99

PF, <10% THD 0.87 120.3 83.9% 0.708 N/A



### DOE paired bot h commercial and industrial 4 -foot and 2- foot U

- shaped MBP ballasts with an appropriate F32T8 lamp. As discussed above, DOE chose 4- foot lamps that just meet the ECS issued in the 2009 Lamps Rule (which becomes effective in 2012) as these will be the most common lamps available after the ballast rule takes effect. 74 FR 34080 (July 14, 2009). The characteristics of these lamps are listed in the table below.

Table 5.6.4 Lamp for Use with F32T8 Ballasts

Lamp Typ e 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 9,545 mean lumens (and 10,048 initial lumens) for the

basel ine F32T8 IS ballast and approximately 9,863 mean lumens (and 10,382 initial lumens) for

the baseline F32T8 PS ballast.5- 24 

### 5.6.2 Candidate Standard Levels

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

DOE considered for th e IS and RS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is an electronic T8 ballast, improvements required the use of the following design options: improved components and improved circuit design. For 4 -lamp ballasts, DOE identified only one CSL. This CSL represents the maximum technologically feasible level

CSL1 . BEF: 0.781; Efficiency: 92.0 percent

This level represents a modest improvement over the baseline efficiency. This level also represents the maximum technologically feasible level. Ballasts at this level use slightly better components and circuit designs than those ballasts that meet the bas eline level.

Figure 5.6.1 illustrates the baseline and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

0.760 0.762 0.764 0.766 0.768 0.770 0.772 0.774 0.776 0.778 0.780 0.782 0.784 0.786 0.788 0.790

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 RS&IS Baseline



### Figure 5.6.1 Candidate Standard Levels for the IS and RS Representative Product Class5- 25 

### The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the PS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE considered design options that achieve a higher BEF than the

baseline ballast. Because the baseline ballast is a T8 electronic ball ast, improvements required the use of the following design options: improved components and improved circuit design. For PS ballasts, DOE identified only one CSL. This CSL represents the maximum technologically

feasible level.

CSL1 . BEF: 0.755 ; Efficiency: 89.4%

This level requires the use of improved circuit designs for the PS ballast. Specifically, ballasts at

this level must use cut

- out cathode heating of the filament after the lamp starts.

Figure 5.6.2 illustrates the baseline and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

0.700 0.705 0.710 0.715 0.720 0.725 0.730 0.735 0.740 0.745 0.750 0.755 0.760 0.765 0.770

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 PS Baseline



### Figure 5.6.2 Candidate Standard Levels for the PS Representative Product Class

Table 5.6.7 and Table 5.6 .6 provide detailed information on the 4- foot MBP ballast designs used in the engineering analysi s and subsequent analyses. In general, for the IS and RS5- 26 

### representative product class, ballasts at higher efficiencies can operate at multiple voltages and have a similar BF and PF as the baseline ballast designs. For the PS representative product class,

t he ballast characteristics are also very similar.

Table 5.6.5 Ballast Designs for the IS and RS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 4 F32T8 Lamps Electronic IS 277 Single >0.98 <1 0% 0.84 111 .5 0.768 90.5%

CSL1 4 F32T8 Lamps Electronic IS 277 Universal >0.98 <1 0% 0.87 114 .4 0.781 92.0%



### Table 5.6.6 Ballast Designs for the PS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 4 F32T8 Lamps Electronic PS 277 Single >0.99 <10% 0.87 120.3 0.708 83.9 %

CSL1 4 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.88 116.1 0.755 89.4 %



### 5.6.3 Lamp and B allast Prices
DOE analyzed each CSL for the IS and RS representative product class to develop appropriate MSPs . T he baseline MSP was calculated using the online price scaling technique

described in section 5.3.3 whereas the CSL 1 MSP was derived from a teardown. DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.6.7

.

Table 5.6.7 Summary of the Manufacturing Selling Price for the IS and RS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP

Baseline F32T8 IS $ 10.50

CSL1 F32T8 IS $11. 885- 27 

### DOE analyzed each CSL for the PS representative product class to develop appropriate

MSPs . T he baseline MSP was derived from a teardown whereas the CSL1 MSP was estimated using the online price scaling technique . DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.6.8

.

Table 5.6.8 Summary of the Manufacturing Selling Price for the PS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP

Baseline F32T8 PS $10. 72

CSL1 F32T8 PS $ 14.20



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.6.9 Retail Prices for Four

- Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price (2007$)

F32T8 $2.82



### 5.6.4 Results

Table 5.6.10 presents the engineering characteristics of the ballast replacement option for the baseline F32T8 system in the IS and RS representative p roduct class. Because the BF of the

standards -case system is slightly 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 4 per cent relative to the mean lumen output of the baseline system.5- 28 

### Table 5.6.10 Four

- Lamp Four

- Foot MBP RS and IS Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F32T8 Lamps Electronic IS 277 Single 0.98 <10% 0.84 111.5 0.7 68 90.5% 10,048 9,545 N/A 10.50 11.29 111.5

CSL1 4 F32T8 Lamps Electronic IS 277 Universal 0.98 <10% 0.87 114.4 0.7 81 92.0% 10 ,394 9,874 3.4% 11.88 11.29 110.6



### Table 5.6.11 presents the engineering characteristics of the ballast replacement option for the baseline F32T8 system in the PS representative product class. If a direct substitution is made, mean lumen output does not change by more than 2 percent relative to the mean lumen output of the baseline system.

Table 5.6.11 Four

- Lamp Four

- Foot MBP PS Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F32T8 Lamps Electronic PS 277 Single 0.99 <10% 0.87 120.3 0.7 08 83.9% 10,382 9,863 N/A 10.72 11.29 120.3

CSL1 4 F32T8 Lamps Electronic PS 277 Uni versal 0.98 <10% 0.88 116.1 0.75 5 89.4% 10,555 10,028 1.7% 14.20 11.29 114.25- 29 

### 5.7 BALLASTS THAT OPERATE TWO EIGHT

- FOOT SP SLIMLINE LAM PS
In this section, DOE analyzes the representative product class designated by number 50

in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.7.1 Representative Product Classes for Ballasts that Operate Two Eight -Foot SP

Slimline Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Eight

- Foot SP Slimline All High 47 48 N/A N/A N/A N/A

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

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

Shading indicates a representative product class.



### 5.7.1 Baseline Models

For the 2- lamp 8 -foot SP slimline normal BF product class (designated by product class

50 in Table 5.7.1 ; hereafter referred to as the 8

- foot SP slimline representative product cla ss)

, 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. 8



### 5.5.1 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 pai r with T12 ballasts (see section ). Because only the most efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to analyze only those T12 ballasts that operate F96T12/ES lamps for this rulemaking. For the T8 baseline, DOE chose to analyze only those ballasts that operate the F96T8 lamp because this lamp is the most common 8- foot SP slimline T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two F96T12/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 (m)(5)). This energy conservation standard effectively allowed only electronic F96T12/ES ballasts. Therefore, DOE chose an electronic ballast as the F96T12/ES b aseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F96T12/ES lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 0.77 is shown in Table 5.7.2 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

8 More recent census data for ballasts is available. However, shipments of T12 ballasts have not been publicly released after 2001. T12 ballast shipments also include data for the 6

- foot SP slimline ballast which DOE estimates is negligible when compared to the 8

- foot shipments.5- 30 

### ch ose 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 <10 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, D OE chose the most common, least efficient ballast on the market. DOE tested a range of F96T8 ballasts from multiple ballast manufacturers and found that the least efficient but most common ballast

exhibited the characteristics shown in the table below. The vast majority of F96T8 ballasts are IS, electronic, and have a high PF (>0.98). Furthermore, the majority of the least efficient T8 ballasts are universal voltage and have a THD <10 percent. Finally, like the F96T12/ES baseline ballast, DOE chose a ballas t that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.

Table 5.7.2 Baseline Ballasts for the Eight

- Foot SP Slimline Representative Product Class

For Operation of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F96T12/ES Lamps IS, 277V, Electronic, Single Voltage, ≥0.97,
PF, <10% THD 0.88 111.1 90.7%* 0.797 0.77

2, F96T8

Lamps IS, 277V, Electronic, Universal Voltage, >0.98
PF, <10% THD 0.87 109.7 90.0% 0.7 90 N/A

* DOE was unable to test the efficiency of this particular ballas t. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.878 *BE

.



### DOE paired 8

- foot SP slimline ballasts with an appropriate F96T12/ES or F96T8 lamp.

DOE chose 8 -foot SP slimline lamps that just meet the ECS issued in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.7.3 Lamps for Use with F96T8 and F96T12/ES Ballasts

Lamp Type CCT Rated Effi cacy* 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 9,760 mean lumens (and 10,508 initial lumens) for the5- 31 

### baseline F96T12/ES ballast, approximately 9,396 mean lumens (and 10,213 initial lumens) for

the baseline F96T8 IS ballast.

5.7.2 Candidate Standard Levels

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

DOE considered for the 8- foot SP slimline representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF 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 product class, DOE identified only one CSL. This CSL represents the maximum technologically feasible level.

CSL1 . BEF: 0.807; Efficiency: 92.0 percent

This level represents a modest improvement over both the baseline T12 and T8 efficiency. Ballasts at this level use slightly better components and ci rcuit designs than those T12 and T8 ballasts that meet the baseline level. This level also represents the maximum technologically feasible level. DOE notes that unlike some CSLs in other product classes, both T12 and T8

ballasts can meet the maximum techno logically feasible level. DOE also notes that although T12 systems are typically less efficacious than T8 systems for other product classes. The T12 systems for this product class have equivalent or higher system efficacies than the T8 systems.

Figure 5.7.1 illustrates the baselines and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at CSL1.5- 32 0.765 0.770 0.775 0.780 0.785 0.790 0.795 0.800 0.805 0.810 0.815

58 59 60 61Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

EPCA F96T12/ES F96T8

F96T8 Baseline F96T12/ES Baseline



### Figure 5.7.1 Candidate Standard Levels for the Eight

- Foot SP Slimline Representative

Product Class

Table 5.7.4 provides detailed information on the 8

- foot SP slimline balla st designs used in the engineering analysis and subsequent analyses. For the F96T8 ballasts, the ballast characteristics remain the same as the baseline system. However, for the F96T12/ES ballasts, the THD and PF are slightly lower than the baseline ballas t.

Table 5.7.4 Ballast Designs for the Eight

- Foot SP Slimline Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12ES Lamps Electronic IS 277 Single ≥0.97 <10% 0.88 111.1 0.797 90.7% *

CSL1 2 F96T12ES Lamps Electronic IS 277 Single >0.95 <20% 0.88 109.5 0.807 92.0% *

Baseline 2 F96T8 Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.7 90 90.0%5- 33 Lamps

CSL1 2 F96T8 Lamps Electronic IS 277 Universal >0.9 8 <10% 0.87 108.0 0.8 09 92.2%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline repr esentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.878 *BE

.



### 5.7.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 8- foot SP slimline representative product class to develop appropriate MSPs. Bot h the baseline and CSL1 MSPs for ballasts that operate F96T12/ES lamps were estimated using the online price scaling technique described in section

5.3.3 . DOE based the MSP for the baseline ballast that operates F96T8 lamps on the online price scaling technique, whereas the CSL1 MSP was derived from a teardown . DOE found that the MSP increased with increased efficiency for both the F96T12/ES ballasts as depicted in the table below. For ballasts that operate F96T8 lamps, DOE foun d the baseline ballast to be more expensive than that at CSL1. Because of energy conservation standards effecting ballasts manufactured after July 1, 2009, DOE believes this market is currently in flux.

Table 5.7.5 Manufacturing Selling Prices for the Eight -Foot SP Slimline Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12/ES 1 9

. 34

CSL1 F96T12/ES 26.27

Baseline F96T8 15.55

CSL1 F96T8 9.27



### The following table depicts th e appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.7.6 Retail Prices for Eight

- Foot SP Slimline Fluorescent Lamps

Lamp Ty pe Retail Price (2007$)

F96T12/ES $7.00

F96T8 $5.92



### 5.7.4 Results

Table 5.7.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12/ES system in the 8- foot SP slimline representative pr oduct class. Because

the BF of the standards- case system is almost exactly the same as the baseline system, the normalized input power is very close to the measured input power. If a direct substitution is5- 34 

### made, mean lumen output does not change by more than 0.1 percent relative to the mean lumen output of the baseline system.5- 35 

### Table 5.7.7 Eight

- Foot SP Slimline Representative Product Class with F96T12/ES BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T12ES Lamps Electronic IS 277 Single ≥0.97 <10% 0.88 111.1 0.797 90.7%* 10,508 9,760 N/A 19.34 14.00 111.1

CSL1 2 F96T12ES Lamps Electronic IS 277 Single >0.95 <20% 0.88 109.5 0.807 92.0%* 10,499 9,751

- 0.1% 26.27 14.00 109.6

* DOE was unable to test the efficiency of these particular ballas t s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:
BEF= 0.878 *BE

.



### Table 5.7.8 presents the engineering characteristics of the ballast replacement options for the baseline F96T8 system in the 8

- foot SP slimline representative product class. Because the BF of the standards

- case system is almost the same as the baseline system, the normalized input power is close to the measured input power. If a direct substitution is made, mean lumen output does not change by more than 1 percent relative to the mean lumen output of the bas eline system.

Table 5.7.8 Eight

- Foot SP Slimline Representative Product Class with F96T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.7 90 90.0% 10,213 9,396 N/A 15.55 11.84 109.7

CSL1 2 F96T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.87 108.0 0.8 09 92.2% 10,317 9,491 1.0% 9.27 11.84 106.95- 365- 37 

### 5.8 BALLASTS THAT OPERATE TWO EIGHT

- FOOT RDC HO LAMPS
In this section, DOE analyzes the representative product class designated by number 54 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test proced ure unless otherwise specified.

Table 5.8.1 Representative Product Classes for Ballasts that Operate Two Eight -Foot RDC

HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Tw o Three Four Five Six

Eight

- Foot RDC HO IS and RS All 53 54 N/A N/A N/A N/A

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

Shading indicates a representative product class.



### 5.8.1 Baseline Models

For the 2- lamp 8

- foot RDC HO IS and RS product class (designated by product cl ass 54

in Table 5.8.1 ; hereafter referred to as the 8

- foot RDC HO representative product class) , DOE chose to analyze two baseline ballasts. DOE found the market share of 8-foot HO (T8 and T12) standard application ballasts (exclu ding 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 RDC HO lamps and increase the number of T8 RDC 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 5.5.1 ). 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 RDC HO T8 lamp.

The Federal minimum energy conservation standards for ba llasts 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 magnet ic ballast as the F96T12HO/ES baseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F96T12HO/ES lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 0.42 is shown in Table 5.8.2 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.5- 38 

### Currently there is no federal minimum energy conservation standard for ballasts that operate F96T8HO lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose the most common, least efficient ballast on the market. DOE tested a range of F96T8HO ballasts from multiple ballast manufacturers and found that the least efficient but most common ballast exhibited the characteristics shown in the table below. The vast majority of F96T8H O ballasts are electronic and have a high PF (>0.95). Furthermore, the majority of the least efficient T8 ballasts have a THD <20 percent. Finally, like the F96T12HO/ES baseline ballast, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.

Table 5.8.2 Baseline Ballasts for the Eight

- Foot RDC HO Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF, TH D BF Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F96T12HO/ES Lamps RS, 277V, Magnetic, Single Voltage, ≥0.90,
PF, <18% THD 0.92 208.4 71.6%* 0. 440 0.42

2, F96T8HO Lamps RS, 277V, Electronic, Single Voltage, >0.98
PF, < 20% THD 0.88 160.0 89.6%* 0.550 N/A

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO rep resentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### DOE paired 8 -foot RDC HO ballasts with an appropriate F96T12HO/ES and F96T8HO lamp. DOE chose 8-foot RDC HO lamps that just meet the ECS issued in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.8.3 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 24,00 0 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.



### 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 14,705 mean lumens (and 16,3 39 initial lumens) for the baseline F96T12HO/ES ballast, approximately 12,496 mean lumens (and 13,904 initial lumens)

fo r the baseline F96T8HO ballast.5- 39 

### 5.8.2 Candidate Standard Levels

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

DOE considered for the 8- foot RDC HO representative product class. As discussed in the screening analysis (pr eliminary TSD chapter 4), DOE used design options that achieve d a higher BEF 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 product class, DOE identified two CSLs. CSL2 represents the maximum technologically feasible level.

CSL1 . BEF: 0.500; Efficiency: 81.4 percent

This level only affects the T12 baseline and represents a modest improvement over the baseline T12 efficiency. Ballasts at this level are electronic instead of magnetic. Both T12 and T8 ballasts

can meet this level.

CSL2 . BEF: 0.549 ; Efficiency: 89.4 percent

This level represents the maximum tech nologically feasible level. This level affects both T12 and T8 baselines. Only T8 ballasts can meet this level. Ballasts at this level use slightly better components and circuit designs than those T8 ballasts that meet CSL1.

Figure 5.8.1 illustrates the baselines and two CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at each CSL.5- 40 0.40 0.42 0.44 0.46 0.48 0.50 0.52 0.54 0.56 0.58 0.60

84 86 88 90 92 94 96Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL2

CSL1 F96T12HO/ES F96T8HO

F96T8HO Baseline

F96T12HO/ES Baseline



### Fi gure 5.8.1 Candidate Standard Levels for the Eight

- Foot RDC HO Representative

Product Class

Table 5.8.4 provides detailed information on the 8 -foot RDC HO ballast designs used in

th e 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.

Table 5.8.4 Ballast Designs for the Eigh t- Foot RDC HO Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12 HO/ES Lamps Magnetic RS 277 Single ≥0.90 <18% 0.92 20 8. 4 0.4 40 71.6%*

CSL1 2 F96T12HO/ES Lamps Electronic RS 277 Single >0.98 <20% 0.85 170.0 0.500 81.4%*

Baseline

/CSL1 2 F96T8HO Lamps Electronic RS 277 Single >0.98 <20% 0.88 160.0 0.550 89.6%*5- 41 CSL2 2 F96T8HO Lamps Electronic IS 277 Single >0.98 <10% 0.68 14 2.8 0.5 49 89.4%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO re presentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### 5.8.3 Lamp and Ballast Prices
DOE analyzed each CSL for the 8- foot RDC HO representative product class to develop appropriate MSPs . The base line, CSL1, baseline/CSL1 and CSL2 were each estimated using the online price scaling technique described in section 5.3.3 . DOE found that the MSP increased for each CSL relative to its respective baseline as depicted in the ta ble below.

Table 5.8.5 Manufacturing Selling Prices for the Eight -Foot RDC HO Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12HO/ES 22.80

CSL1 F96T12HO/ES 23.14

Baselin e/CSL1 F96T8HO 18.45

CSL2 F96T8HO 24.38



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.8.6 Retail Prices for Eight

- Foot RDC HO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F96T12HO/ES $12.35

F96T8HO $6.57



### 5.8.4 Results

Table 5.8.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12HO/ES system in the 8- foot RDC HO representative product class. Because

the BF of the standards- case system decreases at higher CSLs, 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.5- 42 

### Table 5.8.7 Eight

- Foot RDC HO Representative Product Class with F96T12HO/ES BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T12HO/ES Lamps Magnetic RS 277 Single 0.90 <18% 0.92 20 8. 4 0.4 40 71.6%* 16,339 14,7 05 N/A 22.80 24.70 20 8. 4

CSL1 2 F96T12HO/ES Lamps Electronic RS 277 Single 0.98 <20% 0.85 170.0 0.500 81.4%* 15,147 13,632

- 7. 3% 23.14 24.70 18 3.4

Baseline

/CSL1 2 F96T8HO Lamps Electronic RS 277 Single 0.98 <20% 0.88 160.0 0.550 89.6%* 13,904 12,496

- 15. 0% 18.45 13.13 188. 3

CSL2 2 F96T8HO Lamps Electronic IS 277 Single 0.98 <10% 0.68 14 2.8 0.5 49 89.4% 1 0,682 9,600

- 34 .7% 24.38 13.13 218.8

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO re presentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### Table 5.8.8 presents the engineering characteristics of the ballast replacement options for the baseline F9 6T8HO system in the

8- foot RDC HO representative product class. 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.5- 43 

### Table 5.8.8 Eight

- Foot RDC HO Representative Product Class with F96T8HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInputVoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalizedInputPower

V W lm lm % $ $ W

Baseline/

CSL1 2 F96T8HO Lamps Electronic RS 277 Single 0.98 <20% 0.88 160.0 0.550 89.6%* 13,904 12,496 N/A 18.45 13.1 3 160.

0

CSL2 2 F96T8HO Lamps Electronic IS 277 Single 0.98 <10% 0.68 14 2.8 0. 549 89.4% 10,682 9 ,600

- 23.2 % 24.38 13.1 3 185.

9

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO representat ive product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.5- 44 

### 5.9 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 SO LA MPS
In this section, DOE analyzes the representative product class designated by numbers 40 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.9.1 Representative Product Classes for Ballasts that Operate Two Four-Foot

MiniBP T5 SO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot T5 MiniBP SO All High 37 38 N/A N/A N/A N/A

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

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

Shading indicates a representative product class.



### 5.9.1 Baseline Models

For the 2- lamp 4 -foot MiniBP T5 SO normal BF product class (designated by product

class 40 in Table 5.9.1 ; hereafter referred to as the 4 -foot T5 MiniBP SO representative product class), DOE chose to analyze one baseline ballast. DOE believes that F28T5 lamps encompass the vast majority of 4 -foot MiniBP T5 SO lamp sales. 9



### Curre ntly there is no federal minimum energy conservation standard for ballasts that operate F28T5 lamps. In addition, only electronic 4-foot T5 MiniBP SO ballasts are sold on the U.S. market. DOE recognizes, however, that magnetic 4- foot T5 MiniBP SO ballasts may be introduced to the U.S. market and purchased widely by consumers if a BEF standard for 4-foot

T5 MiniBP SO ballasts is not established. Because 4 -foot T5 MiniBP SO magnetic ballasts do not exist currently, DOE developed a baseline model 4-foot T5 Min iBP SO magnetic ballast by determining the difference in BEF between magnetic and electronic ballasts. More information on how DOE developed this baseline model is outlined in appendix 5B. The baseline 4 -foot T5

MiniBP SO ballast has the characteristics sh own 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. Therefore, DOE has chosen to only analyze the F28T5 baseline ballast.

Table 5.9.2 Baseline Ballas t for Four -Foot T5 MiniBP SO Representative Product Class

For Operation

of BF Ballast Type Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

F28T5 1.02 Magnetic 77.8 7 9.1 % * 1.309 N/A

* DOE was unable to test the efficiency of thi s particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, the BEF of a ballast is related to

9 Currently only one manufacturer sells a 4

- foot MiniBP T5 lamp that is not a F28T5. This lamp is a reduced wattage (F26T5).5- 45 ballast efficien cy in the following manner: BEF= 1.655 *BE

.



### DOE paired the 2- lamp 4 -foot MiniBP SO ballast with an appropriate F28T5 lamp. DOE

chose a 4

- foot MiniBP 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.

Table 5.9.3 Lamps for Use with F28T5 Ballasts

Lamp Type CCT Rated Effica cy* 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 5,419 mean lumens (and 5,908 initial lumens).

5.9.2 Candidate Standard Levels

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

DOE considered for the 4-foot T5 MiniBP SO representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of the following design options: electronic ballast, improved components and improved circuit design. For the 4- foot T5 MiniBP SO representative product class, DOE identified two CSLs. The highest CSL represents the maximum technologically feasible level.

CSL1 . BEF: 1. 441; Efficiency: 87.1%

This level represents a large improvement over the baseline T5 efficiency. This level is characterized by the least efficient electronic ballasts on the market today. Magnetic ballasts

cannot meet this level

CSL2 . BEF: 1. 482; Efficiency: 89.6%

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

meet CSL1. This level also represents the maximum technologically feasible level.

Figure 5.9.1 illustrates the baselines and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 46 1.250 1.300 1.350 1.400 1.450 1.500 1.550 1.600 1.650 1.700

27 28 29Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F28T5 B aseline CSL2



### Figure 5.9.1 Candidate Standard Levels for the Four

- Foot T5 MiniBP SO Representative

Product Class

Table 5.9.4 provides detailed information on the 4 -foot MiniBP SO ballast designs used in the engineering analysis and subsequent analyses. For the F28T5 ballasts, the ballast characteristics either improve or remain the same as the magnetic baseline system.

Table 5.9.4 Ballast Designs for the Four

- Foot T5 MiniBP SO Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F28T5 Lamps Magnetic PS 277 Single N/A N/A 1.02 77.8 1.309 79.1%*

CSL1 2 F28T5 Lamps Electronic PS 277 Universal >0.99 <10% 1.02 64.9 1. 441 87.1%

CSL2 2 F28T5 Lamps Electronic PS 277 Universal >0.98 <10% 1.06 65.4 1. 482 89.6%5- 47 * DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the acti ve mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 1.655 *BE

.



### 5.9.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 4-foot T5 MiniBP SO repre sentative product class to develop appropriate MSPs. Both the CSL1 and CSL2 MSPs were estimated using the online price scaling technique described in section 5.3.3 . To determine a price for the baseline magnetic T5 ballast, DOE assumed that the ratio of the baseline magnetic 2 -lamp, 8- foot T12 RDC HO

ballast to the electronic 2 -lamp, 8- foot T12 RDC HO ballast would be the same as the magnetic

to electronic 4 -foot T5 MiniBP SO ballasts. Using this ratio, DOE calculated the price for the magnetic T5 MiniBP SO baseline ballast using the price for the 4-foot T5 MiniBP SO ballast at
CSL1

. DOE found that the MSP increased with increased efficiency as depicted in the table

below.

Table 5.9.5 Manufacturing Selling Prices for the Four -Foot T5 MiniBP SO Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F28T5 16.19

CSL1 F28T5 16.43

CSL2 F28T5 16.56



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.9.6 Retail Prices for Four

- Foot MiniBP SO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F28T5 $3.20



### 5.9.4 Results

Table 5.9.7 presents the engineering characteristics of the ballast replacement options for the baseline F28T5 system in the 4-foot T5 MiniBP SO representative product class. Because the

BF of the standards- case system at CSL2 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 4 .2 percent relative to the mean lumen output of the baseline system.5- 48 

### Table 5.9.7 Four -Foot T5 MiniBP SO Representative Product Class with F28T5 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F28T5 Lamps Magn etic PS 277 Single N/A N/A 1.02 77.8 1.309 79.1 %* 5,908 5,419 N/A 16.19 6.40 77.8

CSL1 2 F28T5 Lamps Electronic PS 277 Universal >0.99 <10% 1.02 64.9 1. 441 87.1% 5,908 5,419 0.0% 16.43 6.40 64.9

CSL2 2 F28T5 Lamps Electronic PS 277 Universal >0.98 <10% 1 .06 65.4 1. 482 89.6% 6,155 5,646 4.2% 16.56 6.40 62.7

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner:

BEF= 1.655 *BE

.5- 49 

### 5.10 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 HO LA MPS
In this section, DOE analyzes th e representative produ ct class designated by number 44 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.10.1 Representative Product Classes for Ballasts that O perate Two Four -Foot

MiniBP T5 H O Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

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

Shading indicates a representative product class.



### 5.10.1 Baseline Models

For the 2- lamp 4 -foot MiniBP T5 HO normal BF product class (designated by product

class 44 in Table 5.10.1 ; hereafter referred to as the 4 -foot T5 MiniBP HO representative produc t class), DOE chose to analyze one baseline ballast. DOE believes that F54T5HO lamps encompass the vast majority of 4

- foot MiniBP T5 HO lamps sales. 10



### Currently there is no federal min imum energy conservation standard for ballasts that operate F54T5HO lamps. In addition, only 4-foot T5 MiniBP HO electronic ballasts are sold on the U.S. market. Like the 4-foot T5 MiniBP SO product class, DOE recognizes that 4-foot T5 MiniBP HO magnetic b allasts may be introduced to the U.S. market and purchased widely by

consumers if a BEF standard for 4

- foot T5 MiniBP HO ballasts is not established. Because 4

- foot T5 MiniBP HO magnetic ballasts do not exist currently, DOE developed a baseline model 4-

foo t T5 MiniBP HO magnetic ballast by determining the difference in BEF between magnetic and electronic ballasts. More information on how DOE developed this baseline model is outlined in appendix 5B and section Therefore, DOE has chosen to only analyze the F54T5HO baseline ballast.

5.9.1

. The baseline 4-foot T5 MiniBP 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 5.10.2 Baseline Ballast for the Four -Foot T5 MiniBP HO Representative Product

Class

For Operation

of BF Ballast Type Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

F54T5HO 0.99 Magnetic 143.5 7 4 .2% * 0.688 N/A

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test

10 Currently only two manufacturers sell a 4

- foot MiniBP T5 HO lamp t hat is not a F54T5HO. One manufacturer sells a reduced wattage (F51T5HO). Another manufacturer sells a F49T5HO.5- 50 procedure

. For the 4

- foot T5 MiniBP HO representative pro duct class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.927 *BE

.



### DOE paired the 2- lamp 4 -foot MiniBP HO ballast with an appropriate F54T5HO lamp.

DOE chose a 4

- foot MiniBP 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.

Table 5.10.3 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 wattage of the lamps, which for th e F54T5HO lamp is

53.8W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 9,087 mean lumens (and 9,877 initial lumens).

5.10.2 Candidate Standard Levels

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

DOE considered for the 4-foot T5 MiniBP HO representative product class. As discussed in the

screen ing analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of the following design options: electronic ballast, improved components and improved circuit design. For the 4- foot T5 MiniBP HO representative product class, DOE identified two CSLs. The highest CSL represents the maximum technologically feasible level.

CSL1 . BEF: 0.791; Efficiency: 85. 4 percent

This level r epresents a large improvement over the baseline T5 efficiency. This level is characterized by the least efficient electronic ballasts on the market today. Magnetic ballasts

cannot meet this level

CSL2 . BEF: 0.837; Efficiency: 90.3 percent

Ballasts at this level use slightly better components and circuit designs than those ballasts that meet CSL1. This level also represents the maximum technologically feasible level.

Figure 5.10.1 illustrates the baseline and CSLs on a plot of fluor escent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 51 0.650 0.700 0.750 0.800 0.850 0.900

53 54 55Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F54T5HO B aseline CSL2



### Figure 5.10.1 C andidate Standard Levels for the Four

- Foot T5 MiniBP HO Representative

Product Class

Table 5.10.4 provides detailed information on the 4- foot MiniBP 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 5.10.4 Ballast Designs for the Four

- Foot T5 MiniBP HO Representative Product

ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F54T5HO Lamps Magnetic PS 277 Single N/A N/A 0.99 143.5 0.688 74 .2% *

CSL1 2 F54T5HO Lamps Electronic PS 277 Universal ≥0.98 ≤10% 0.99 124.8 0.791 85.4%*

CSL2 2 F54T5HO Electronic PS 277 Universal >0.98 <10% 1.02 122.4 0.8 37 90.3%5- 52 Lamps



### 5.10.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 4-foot T5 MiniBP HO representative product class to develop appropriate MSPs. Both the CSL1 and CSL2 MSPs were estimated using the online price scaling technique described in section 5.3.3 . DOE used the same technique described for establishing the magnetic T5 SO ballast MSP to establish an MSP for the magn etic T5 HO baseline. DOE assumed that the ratio of the baseline magnetic 2 -lamp, 8- foot T12 RDC HO

ballast to the electronic 2 -lamp, 8- foot T12 RDC HO ballast would be the same as the ratio between the magnetic to electronic 4 -foot T5 MiniBP HO ballasts. U sing this 8 -foot HO ratio, DOE adjusted the price assigned to CSL1 to calculate the price for the model magnetic T5 H O baseline. DOE found that the MSP increased with increased efficiency as depicted in the table

below.

Table 5.10.5 Manufacturing Selling Prices for the Four -Foot T5 MiniBP HO Representative Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F54T5HO 15.09

CSL1 F54T5HO 15.32

CSL2 F54T5HO 18. 27



### The following table depicts the app ropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.10.6 Retail Prices for Four

- Foot MiniBP HO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F54T5HO $4.28



### 5.10.4 Results

Table 5.10.7 presents the engineering characteristics of the ballast replacement options

for the baseline F54 T5 HO system in the 4 -foot T5 MiniBP HO representative product class.

Because the BF of the standards

- case system is slightly higher than the baseline system at CSL2, 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 3 percent relative to the mean lumen output of the baseline system.5- 53 

### Table 5.10.7 Four -Foot T5 MiniBP H O Representative Product Class with F 54 T5 HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F54T5HO Lamps Magnetic PS 277 Single N/A N/A 0.99 143.5 0.688 74 .2% * 9,877 9,087 N/A 15.09 8.56 143.5

CSL1 2 F54T5HO Lamps Electronic PS 277 Universal ≥0.98 ≤10% 0.99 124.8 0.791 85.4%* 9,877 9,087 0.0% 15.32 8.56 124.8

CSL2 2 F54T5HO Lamps Electronic PS 277 Universal >0.98 <10% 1.02 122.4 0.8 37 90.3% 10,152 9,340 2.8% 18.27 8.56 119.15- 54 

### 5.11 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAM PS IN THE RESIDENTIAL SECTOR
In this section, DOE analyzes the representative product class designated by number 58 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless othe rwise specified.

Table 5.11.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP

and Two -Foot U- Shaped Lamps in the Residential Sector

Ballast and Lamp Type Starting

Method Ballast

Fac tor Number of Lamps

One Two Three Four Five Six

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

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

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

Shading indicates a representative product class.



### 5.11.1 Baseline Models

For the Resid ential 2

- lamp 4 -foot MBP and 2- foot U -Shaped IS and RS product class (designated by product class 58 in Table 5.11.1 ; hereafter referred to as the residential representative product class) , 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. 11



### 5.5.1 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 b y foreign companies which do not share shipment data with the U.S. Census. Through manufacturer interviews, DOE learned that both T12 and T8 ballasts are popular in the residential market. Therefore, DOE analyzed both a T12 and T8 ballast as a baseline bal last.

Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with the 2009 Lamps Rule to pair with T12 ballasts (see section ). 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 that that was the most common wattage lamp at that

diameter.

Currently there is no federal minimum energy conservation standard for ballasts that operate lamps in the residential sector. Therefore, in choosing the baseline ballast for this market sector, DOE chose the most common and least efficient ballast on the market. 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 th e residential market. DOE then

11 Low power factor ballasts are ballasts with a power factor less than 0.9 and are typically used in residential applications.5- 55 

### obtained the fixtures, removed the ballast, and tested the ballast to determine the least efficient and most common option. 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 as shoplights). The baseline T12 ballast exhibits these characteristics. The BEF, BF, and input power of this ballast are shown in Table 5.11.2

.

For the T8 baseline, DOE also chose the most common, least efficient ballast on the market. DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and in multiple fixtures. DOE found that the least efficient but most common ballast exhibited the characteristics shown in the table below. The majority of F32T8 ballasts in the residential sector operate two lamps, are electronic, are IS, and operate at a single voltage of 120V. The

characteristics of the T8 baseline ballast are summarized in Table 5.11.2

.

Table 5.11.2 Baseline Ballasts for the Residential Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF BF Input

Power

(W) Ballast

Eff iciency BEF Federal Energy

Conservation

Standard

2, F34T12

Lamps RS, 120V, Electronic, Single Voltage, >0.50

PF 0.59 45.9 75.7%* 1.277 N/A

2, F32T8

Lamps IS, 120V, Electronic, Single Voltage, >0.50

PF 0.78 53.1 86.4% 1.4 57 N/A

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the residential representative product class, t he BEF of a ballast is related to bal last efficiency in the following manner:

BEF= 1.686 *BE

.



### DOE paired 4 -foot MBP ballasts with an appropriate F34T12 or F32T8 lamp. DOE chose

4- foot MBP lamps that just meet the ECS adopted in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.11.3 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 lam p 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 a pproximately 3,310 mean lumens (and 3,676 initial lumens) for the5- 56 

### baseline F34T12 ballast, and approximately 4,447 mean lumens (and 4,682 initial lumens) for

the baseline F32T8 ballast.

5.11.2 Candidate Standard Levels

The following discussion identifies the ste ps and technologies associated with each CSL

DOE considered for the r esidential representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballasts are electronic ballasts, improvements required the use of the improved components and improved circuit design. For the r esidential representative product class, DOE identified two CSLs. CSL2 represents the maximum technological ly feasible level.

CSL1 . BEF: 1.457; Efficiency: 86.4%

This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It requires the use of improved lamp diameters (T8 instead of T12). Therefore, no T12 ballasts meet this level.

CSL2

. BEF: 1. 492; Efficiency: 88.5%

This level affects both baseline ballasts and represents the maximum technologically feasible level. This level represents a modest improvement in efficiency over CSL1. Ballasts at this level use slightly better components and circuit designs than those T8 ballasts that meet CSL1.

Figure 5.11.1 illustrates the baselines and CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballas ts. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 57 1.25 1.30 1.35 1.40 1.45 1.50 1.55

31 32 33 34 35Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL2

CSL1 F34T12 F32T8

F32T8 Baseline

F34T12 Baseline



### Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class

Tabl e 5.11.4 provides detailed information on the 4-foot MBP ballast designs used in the engineering analysis and subsequent analyses.

Table 5.11.4 Ballast Designs for the Residential Representative Product Clas sCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F34T12 Lamps Electronic IS 120 Single >0.50 <10 0.59 45.9 1.277 75.7%*

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 120 Single >0.50 <20 0.78 53.1 1.4 57 86.4%

CSL2 2 F32T8 Lamps Electronic IS 120 Single >0.50 <10 0.83 55.3 1. 492 88.5%

* DOE was unable to test the efficiency of this particular ballast. D OE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the residential representative5- 58 product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF = 1.686 *BE

.



### 5.11.3 Lamp and Ballast Prices

DOE analyzed each CSL for the residential representative product class to develop appropriate MSPs

. Because ballasts in the residential sector are typically sold in fixtures, DOE discovered that the most common ballasts could not be obtained individually. Rather, these ballasts could only be purchased as part of a fixture. Therefore, DOE revised its pricing methodology for this product class. For the striplight fixtures analyzed, DOE assumed that the

MSP of the resident ial ballast represented a fixed percentage of the retail price of the fixture. To determine this, DOE compared the MSP of a commercial ballast that closely resembled the characteristics of its residential counterpart to the total retail price of the fixtur e. DOE then applied this percentage to the retail price of the fixtures to calculate the MSP for the residential

ballast. DOE found that the MSP increased with increased efficiency as depicted in Table 5.11.5

.

Table 5.11.5 Manufacturing Selling Prices for the Residential Representative Product

Class

Candidate Standard Level Lamp Type MSP $

Baseline F34T12 3.68

CSL1 F32T8 7.07

CSL2 F32T8 10.13



### The following table depicts the appr opriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.11.6 Retail Prices for Four

- Foot MBP Fluorescent Lamps

Lamp Type Retail Price (2007$)

F34T12 $5.83

F32T8 $2.82



### 5.11.4 Results

Table 5.11.7 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 system in the r esidential representative product class. Because the BF of

the standards

- case system is higher than th e baseline system, the normalized input power is lower than the measured input power. If a direct substitution is made, mean lumen output can increase by as much as 43 percent over the mean lumen output of the baseline system because of

the difference in b allast factor. Additionally, as seen in the table below, input power increases at each CSL relative to the baseline. For the residential sector, DOE believes that consumers will5- 59 

### not purchase direct ballast replacements, but rather replacement fixtures. The refore, the normalized input power is the most relevant scenario because fixture spacing can be easily adjusted when a new fixture is installed.5- 60 

### Table 5.11.7 Residential Representative Product Class with F34 T12 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F34T12 Lamps Electronic IS 120 Single N/A N/A 0.59 45.9 1.277 75.7%* 3,676 3,310 N/A 3.68 11.65 45.9

CSL1 2 F32T 8 Lamps Electronic IS 120 Single N/A N/A 0.78 53.1 1. 457 86.4% 4,682 4,447 34.4% 7.07 5.65 39.5

CSL2 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.83 55.3 1. 492 88.5% 4,989 4,740 43.2% 10.13 5.65 38.6



### Table 5.11.8 presents t he engineering characteristics of the ballast replacement options for the baseline F32T8 system in the

r esidential representative product class. 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 7 percent relative to the mean lumen output of the baseline system.

Table 5.11.8 Residential Representative Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystemInitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline/CSL1 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.78 53 .1 1.4 57 86.4% 4,682 4,447 N/A 7.07 5.65 53.1

CSL2 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.83 55.3 1. 492 88.5% 4,989 4,740 6.6% 10.13 5.65 51.85- 61 

### 5.12 BALLASTS THAT OPERATE FOUR EIGHT

- FOOT HO LAMPS IN COLD

TEMPERATURE APPLICAT IONS OR OUTDOOR SIGN S

I n this section, DOE analyzes the representative product class designated by number 68 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.12.1 Representative Product Classes for Ballasts that Operate Four Eight -Foot HO Lamps in Cold Temperature Applications or Outdoor Signs

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Sign Ballast, All Lamp Types All All 65 66 67 68 69 70

Shading indicates a representative product class.



### 5.12.1 Baseline Models

For the 4- lamp 8 -foot HO product class for cold temperature or sign ballasts (designated by product class 68 in Table 5.12.1 ; hereafter referred to as the sign ballast representative product class), 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 product class. DOE paired the ballast with an F96T12HO lamp that represented the most common cold temperature lamp available in the market today.

Current ballast standards exclude ballasts designed to operate at ambient temperatures of −20 °F or less and designed for use in an outdoor sign. (10 CFR 430.32(m)) Therefore, in choosing the baseline ballast for this market sector, DOE chose the most comm on and least efficient ballast on the market. DOE tested a range of cold temperature ballasts and sign 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 sign ballasts are magnetic, RS, and operate at a low BF. Furthermore, the majority of the least efficient sign ballasts are single voltage and operate four 8-foot HO lamps. Finally, DOE chose a ballast that has an input voltage of 120V as the majority of ballasts operate in outdoor signs at 120V. The BEF, BF, and input power of this ballast are shown in Table 5.12.2

.

Table 5.12.2 Baseline Ballasts for the Si gn Ballast Representative Product Class

For Operation of Starting Method, Input Voltage, Ballast Type BF Input

Power

(W) Ballast Efficiency BEF Federal Minimum Energy

Conservation

Standard
4, F96T12HO RS, 120V, Magnetic, 0.7 7 393.6 74 .4%* 0. 196 N/A5- 62 Lamps Single Voltage

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product clas s, t he BEF of a ballast is related to ballast efficiency in the following

manner: BEF= 0.263 *BE

.



### 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 an 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.

Table 5.12.3 Lamps for Use with Cold Temperatur e F96T12HO Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F96T12HO 4200 63.3 8,600 6,966 12,000 60



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 21,472 mean lumens (and 26,509 initial lumens) for the

baseline F96T12HO ballast.

5.12.2 Candidate Standard Levels

The following disc ussion identifies the steps and technologies associated with each CSL

DOE considered for the sign ballast representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF 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 product class, DOE identified one CSL. CSL1 represents the maximum technologically feasible level.

CSL1 . BEF: 0.238 ; Efficiency: 90.4 percent

This level represents a modest improvement in efficiency over the baseline ballast. Ballasts at this level are electronic rather than the magnetic ballasts that meet the baseline level.

Figure 5.12.1 illustrates the baselines and CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at C SL1.5- 63 0.00 0.04 0.08 0.12 0.16 0.20 0.24 0.28

109 110 111Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F96T12HO Sign BallastBaseline



### Figure 5.12.1 Candidate Standard Levels for the Sign Ballast Representative Product Class

Table 5.12.4 provides detailed information on the 8-foot HO ballast designs used in the engineering analysis and subsequent analyses.

Table 5.12.4 Ballast Designs for the Sign Ballast Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12HO Lamps Magnetic RS 120 Single N/A N/A 0.7 7 393.6 0.1 96 74.4%*

CSL1 2 F96T12HO Lamps Electronic IS 120 Universal N/A N/ A 0.63 264.0 0.2 38 90.4%*

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.263 *BE

.5- 64 

### 5.12.3 Lamp and Ballast Prices
DOE analyzed each CSL for the sign ballast representative product class to develop appropriate MSPs . Both the baseline an d CSL1 MSPs were estimated using the online price scaling technique described in section 5.3.3 . As depicted in the table below, DOE found the CSL1 MSP to be greater than the baseline. The CSL1 ballast is an electronic ballast t hat operates a wide variety of design constraints, whereas the baseline ballast is a magnetic ballast with a typical set of specifications. The simplification and reduction of inventory may rationalize this finding of lower cost with higher efficiency. In addition, manufacturers indicated the magnetic ballast (baseline) would be sold at a higher price than the more efficient electronic ballast (CSL1).

Table 5.12.5 Manufacturing Selling Prices for the Sign Ball ast Representative Product

Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12HO 40.23

CSL1 F96T12HO 35.58



### Because DOE did not analyze 8 -foot HO cold temperature fluorescent lamps in the 2009 Lamps Rule, DOE developed the price for that lamp using the same methodology employed in the 2009 Lamps Rule. The resultant price is shown in the table below.

Table 5.12.6 Retail Prices for Eight

- Foot HO Cold Temperature Fluorescent Lamps

Lamp Type Retail P rice (2007$)

F96T12HO $4.84



### 5.12.4 Results

Table 5.12.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12HO system in the sign ballast representative product class. Because the

BF of the standards- case system is lower than the baseline system, the normalized input power is higher than the measured input power. If a direct substitution is made, mean lumen output would decrease by 19 percent because of the lower ballast factor.5- 65 

### Table 5.12.7 Sign Ballast Representative Product Class with F96T12HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F96T12HO Lamps Magnetic RS 120 Single N/A N/A 0.7 7 393.6 0.1 96 74.4%* 26,509 21,472 N/A 40.23 19.34 393.6

CSL1 4 F96T12HO Lamps Electronic IS 120 Universal N/A N/A 0.63 2 64 .0 0.2 38 90.4%* 21,599 17,495

- 18.5 % 35.58 19.34 324.1

* DOE was unable to test the efficien cy of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.263 *BE

.5- 66 

### 5.13 SCALING TO PRODUCT CLASSES NOT ANALYZED

DOE identified and selected certain product classes as “representative” product classes on which to concentrate its analytical effort. DOE chose these representative product classes primarily due to their high market volumes. DOE focused its analytical efforts on extensive test

data obtained for ballasts that operate 4

- foot MBP lamps. DOE analyzed ballasts of this type to observe relationships between ballasts that op erate different numbers of lamps , have different ballast factors, orhave different starting methods. The following sections discuss how DOE identified these relationships and then applied scaling factors to determine CSLs for those product classes that it did not analyze.

5.13.1 Number of Lamps

The more lamps a ballast operates, the lower the ballast’s BEF. This is because as the number of lamps increases, the total ballast input power increases, which appears in the denominator of the equation to calculate BEF. Thus, ballasts that operate two or four lamps have lower BEFs than ballasts that operate one or three lamps, respectively. To determine how to scale CSLs to account for the number of lamps a ballast operates, DOE focused its analytical

effort on ballasts that operate 4

- foot MBP lamps. Within this category there are four representative product classes , shown in the table below. DOE obtained test data for these representative product classes and then strategically ch ose additional classes to aid its scaling

effort. The following table indicates the 4 -foot MBP product classes for which DOE obtained

test data.

Table 5.13.1 Test Data Obtained for Ballasts that Operate Four

- Foot Medium Bipin Lamps

Ballast and Lamp T ype Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class . Diagonal lines represent product classes for which DOE obtained test

data.



### To determine how to scale between ballasts that operate different numbers of lamps,

DOE examined the ava ilable test data. The test data showed a strong correlation between the ballast efficacy factor and total rated lamp power operated by a ballast. The total rated lamp power is equal to the rated lamp power multiplied by the number of lamps. DOE found that this relationship existed even after considering differences between ballast manufacturers and standard versus high efficiency ballasts. Given the available test data, DOE also examined this relationship among ballasts that operate 4 -foot T5 MiniBP HO lamp s and cold temperature5- 67 

### lamps. This data verified DOE’s assumption that the relationship between BEF and total rated lamp power present among ballasts that operate 4

- foot MBP lamps is also present for ballasts that opera te other lamp types. Equation 5.13-1 shows the equation DOE used to scale CSLs in representative product classes to those that were not directly analyzed based on the number of lamps operated by a ballast

.

Equation 5.13-1

Power Lamp Rated Total -0.942 t Coefficien Factor Efficacy Ballast **∗ =** 

To determine the appropriate coefficient in the equation above, DOE relied on the analysis performed for each r epresentative product class. For each CSL in each representative product class, DOE calculated the coefficient in Equation 5.13-1 such that the relationship would hold true for each representative ballast. For example, for product class 8, DOE determined a different coefficient for CSLs 1 through 3 such that the BEF in Table 5.5.12 was equal to the coefficient times the total rated lamp power (65W for two 4

- foot MBP T8 lamps) raised to the

- 0.942 power. As higher CSLs represent more efficient ballasts, and therefore have higher BEFs, the scaling coefficient was large r for higher CSLs.

5.13.2 Starting Method

As discussed in preliminary TSD chapter 3 , the starting method of a ba llast affects its efficiency. Rapid start and programmed start ballasts are inherently less efficient than instant

start ballasts

, as these ballasts u se extra power to provide filament heat to the lamp to increase

the lamp ’s lifetime. Although these ballasts can cut out the filament power during lamp operation, the extra circuit to remove this power uses some amount of power. As explained in preliminary TSD chapter 3, DOE is establishing a separate product class for programmed start ballasts due to their primary use with occupancy sensors and limited use as a substitute for either instant start or rapid start ballasts.

To determine how to scale to ball asts that operate programmed start ballasts, DOE examined pairs of ballasts for which the only difference between the two was the starting method. For example, DOE identified a single ballast in product class 8, and identified its pair in product class 26. These ballasts had the same manufacturer and ballast factor and operated the same number and type of lamps. Upon identifying these ballast pairs, DOE calculated the average reduction in BEF associated with programmed start ballasts. DOE found this average reduction to be 2.2% and therefore applied this scaling factor when scaling to product classes with programmed start ballasts.

5.13.3 Ballast Factor

DOE’s analysis found that ballasts with a high or low ballast factor had a lower BE F than

ballasts with a normal ballast factor

. 12

12 In general, bal lasts designed with a ballast factor of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor of 0.78 or less; high ballast factor ballasts typically have a ballast factor of 1.10 or higher. 

### To determine how to scale to product classes containing5- 68 

### ballasts with either high or low ballast factor, DOE followed a similar methodology described

above in section 5.13.2 . DOE identified pairs of ballasts for which the only difference was ballast factor. For example, DOE identified a ballast in product class 8 and then identified the ballast with the same manufacturer, starting method, and number of lamps but either a high or low ballast factor in product class 2 or 14 respectively. DOE located similar pairs of ballasts between product classes 4 and 10 and 10 and 16. DOE calculated the average reduction associated with high or low ballast factor. DOE found this average reduction to be 3.4% for high ballast factor and 1.0% for low ballast factor and therefore applied these scaling factors as needed.

5.13.4 Scaling

As indicated by Table 5.13.2 , some product classes (such as product class 1) require more than one scaling factor to determine the appropriate CSLs. This section describes the order in which DOE applied the scaling factors described in the above sections.

When scaling to product classes not analyzed, DOE first scaled based on the number of lamps the ballast operates. For example , in Table 5.13.2

, DOE scaled from product classes 8 and 26 to product classes 7 and 25 respectively. For 4- lamp ballasts, DOE scaled from product class 10 to product classes 9, 11, and 12 and from product class 28 to product classes 27, 29, and 30. In the table below, the gray boxes designate representative product classes whereas the green

boxes designate product classes with CSLs that were calculate d using the number -of- lamps relationship.

Table 5.13.2 Example of Scaling Based on Number of Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Gray s hading indicates a representative product class

. G reen shading indicates a product class with CSLs scaled based

on t he number

- of

- lamps relatio nship

– with light green representing classes scaled from the 2

- lamp representative product class and dark green representing classes scaled from the 4

- lamp representative product class.



### When necessary, DOE then scaled based on starting method. For ball asts that operate 4

- foot MBP lamps, this scaling was not required because DOE selected representative product classes for programmed start ballasts. However, for both ballasts that operate 8- foot RDC HO lamps and ballasts that operate in the residential sector, it was necessary to scale based on starting method. In these cases, after adjusting CSLs based of number of lamps, DOE applied the programmed start scaling factor. An example for the residential representative product class is

shown below.5- 69 

### Table 5.13.3 Example of Scaling Based on Starting Method

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

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

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

Gray s hading indicates a representative product class. Green shading indicates a product class with CSLs scaled based

on the number

- of

- lamps relationship. Red shading indicates a product class w ith CSLs scaled based on the starting method relationship.



### Last, when required, DOE scaled based on ballast fa ctor. As discussed in section 5.13.3

, DOE developed scaling factors for both high and low BF ballasts. For ballast s that operate 4 -foot MBP lamps in the commercial sector, DOE applied those scaling factors after first adjusting for the number of lamps a ballast operates. In the table below, the blue shading denotes product classes for which DOE applied a scaling facto r for BF.

Table 5.13.4 Example of Scaling Based on Ballast Factor

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Gray s hading indicates a representative product class . Green shading indicates a product class with CSLs scaled based

on the number

- of

- lamps relationship

– with light green representing classes scaled from the 2

- lamp representative product class and dark green representing classes scaled from the 4

- lamp representative product class. Blue shading

indicate s a product class with CSLs scaled based on the ballast factor relationship

– with light blue representing classes scaled from the 2

- lamp representative product class and dark blue representing classes scaled from the 4

- lamp representative product class



### 5.13.5 All CSLs

The following tables show the values for each CSL in every product class.5- 70 

### Table 5.13.5 CSLs for All Ballasts That Operate Four

- Foot MBP and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Me thod Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- Foot MBP,

and 2

- Foot U

Shaped IS and RS High 1 2.692 1.401 0.990 0.754 0.612 0.515

2 2.850 1.483

3 2.898 1.508

Normal 1 2.786 1.450 1.024 0.781 0.633 0.5 33

2 2.949 1.535

3 2.999 1.561

Low 1 2.758 1.435 1.014 0.773 0.627 0.528

2 2.919 1.519

3 2.969 1.545

PS High 1 2.816 1.466 0.957 0.729 0.591 0.498

Normal 1 2.914 1.517 0.990 0.755 0.612 0.515

Low 1 2.885 1.502 0.980 0.747 0.606 0.510

Gray shading indicates a representative product class.



### Table 5.13.6 CSLs for All Ballasts That Operate Eight

- Foot SP Slimline Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

8- Foot SP

Slimline All High 1 1.498 0.780

Normal 1 1.550 0.807

Low 1 1.535 0.799

Gray shading indicates a representative product class.



### Table 5.13.7 CSLs for All Ballasts That Operate Eight

- Foot RDC HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

8- Foot RDC

HO IS and RS All 1 0.961 0.500

2 1.055 0 .549

PS All 1 0.940 0.489

2 1.032 0.537

Gray shading indicates a representative product class.5- 71 

### Table 5.13.8 CSLs for All Ballasts That Operate Four

- Foot T5 MiniBP SO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- foot T5

MiniBP SO All High 1 2.675 1.392

2 2.751 1.432

Normal 1 2.768 1.441

2 2.847 1.482

Low 1 2.741 1.426

2 2.819 1.467

Gray shading indicates a representative product class.



### Table 5.13.9 CSLs for All Ballasts That Operate Four

- Foot T5 MiniBP HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- foot T5

MiniBP HO All All 1 1.520 0.791 0.540 0.412

2 1.608 0.837 0.571 0.436

Gray shading indicates a representative product class.



### Table 5.13.10 CSLs for All Re sidential Ballasts That Operate Four

- Foot MBP and Two

Foot U- Shaped Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- Foot MBP,

and 2

- Foot U

Shaped IS and RS All 1 2.801 1.458 0.995 0.759

2 2.866 1.492 1.018 0.777

PS All 1 2.740 1.426 0.974 0.742

2 2.804 1.460 0.996 0.760

Gray shading indicates a representative product class.



### Table 5.13.11 CSLs for All Cold Temperature or O utdoor Sign Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

Sign Ballast All All 1 0.878 0.457 0.312 0.238 0.193 0.162

Gray shading indicates a representative product class.5- 72 

### REFERENCES

1 

### U.S. Department of Energy, Energy Efficiency and Renewable Energy Office of Building

Research and Standards. Energy Conservation Program for Consumer Products: Technical Support Document: Energy Efficiency Standards for Consumer Products: Fluorescent Lamp Ballast Proposed Rule . Chapter 3. Engineering Analysis. Section 3.7. January 2000. (Last accessed June 30, 2009).

< http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf >

2 

### U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial Reports, Fluorescent Lamp Ballasts, MQ335C . (Last accessed June 30, 2009). <http://www.census.gov/mcd>