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 OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED 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 USHAPED 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 LAMPS .......... 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 LAMPS.......... 5-49

5.10.1 Baseline Models ................................................................................................. 5-49

5.10.2 Candidate Standard Levels ................................................................................ 5-50

5.10.3 Lamp and Ballast Prices..................................................................................... 5-52

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5.10.4 Results5-52

5.11 BALLASTS THAT OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED 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 Results5-58

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

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS ..................................... 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 Results5-64

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 Scaling5-68

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

Table 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 Representative 

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

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Table 5.6.2 Baseline Ballasts for the IS 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/ES Ballasts ............................................. 5-30

Table 5.7.4 Ballast Designs for the Eight-Foot SP Slimline Representative Product Class ...... 5-32

Table 5.7.5 Manufacturing 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 Class 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 Representative 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 Representative 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 MiniBP 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 ............................................................... 5-50

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Table 5.10.4 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Product Class5-51

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 Representative 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 F34T12 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 Ballast 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 RDC 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 Ballasts 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 ................... 5-25

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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 Candidate 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 Levels for the Sign Ballast Representative Product Class .. 5-63

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5-1 

CHAPTER 5 ENGINEERING ANALYSIS

5.1 INTRODUCTION

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

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

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

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

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

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

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

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

to those product classes not analyzed. 

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

analysis (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 markups. 

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 

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

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

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

for each efficiency level. 

DOE generally follows five steps in the engineering analysis: 

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

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

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

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

not analyze, DOE extrapolates the candidate standard levels (CSLs) from representative product 

classes to other product classes.

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Select Baseline Ballasts: For each representative product class, DOE establishes baseline 

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

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

as a reference point for each 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 5C presents the test 

results. DOE selects specific characteristics such as starting method, ballast factor (BF), and 

input voltage to characterize the most common ballast. DOE also selects multiple 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 replacements for each baseline ballast in the representative product 

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

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

options associated with each ballast. However, at some levels, these design options cannot be 

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

the ballast to achieve a higher 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 these test results. All BEF and BE values 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 analysis. Though 

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

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

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

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

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

output.a

Determine Candidate Standard Levels. 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 maximum 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. 

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product classes. The BOMs describe the product in detail, including all manufacturing steps 

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

BOMs and efficiency levels into MPCs. By applying derived manufacturer markups to the 

MPCs, DOE calculates the manufacturer selling prices (MSPs)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 manufacture a product in order to calculate the MPC.d

 Section 5.3.1 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 all production and non-production costs and earn a 

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

development, and interest.

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 

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

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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 

conducted customized teardown analyses for select commercially available fluorescent lamp 

ballasts. DOE also conducted a teardown analysis on some ballasts removed from a 

manufacturing facility before adding potting, a type of black pitch. For these ballasts, DOE 

needed to estimate the cost of potting material to calculate the full material and labor costs. 

Based on information provided by members of the potting industry, DOE estimated the material 

and labor costs for potting to be about 60 cents for the standard ballast enclosure, which is 1 x 

1.5 x 8 inches. Therefore, DOE added 60 cents to the teardown estimates for “pre-potting” 

ballasts to estimate the full material and labor costs.

Manufacturers commented that the materials involved in ballast manufacturing are highly 

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

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

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

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

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

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

analysis.

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

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

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

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

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

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

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

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

DOE estimated the depreciation cost from a representative electronics fabrication 

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

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

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

(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. 

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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 heat sink for the circuit board. Because the sticky 

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

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

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

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

down. 

DOE selected thirteen fluorescent lamp ballasts to tear down 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 Universal HE

10 and 11 IS 2 F59T8 Universal HE

12 IS 2 F59T8 Single REG

13 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 at 

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5-6 

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 

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

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

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

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

this section. 

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

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

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

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

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

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

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

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

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

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

manufacturer selling prices using the manufacturer markup. 

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 the manufacturer markup by using financial figures from manufacturers’ 

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

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

calculate the markup. 

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

EERE-2007-BT-STD-0016 COMMENT 25
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

IndustryWeighted 

Average

Manufacturer

A B C D 

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

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

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

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8

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

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

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

years. Each manufacturer’s markup was calculated as: 

Equation 5.3-3 

 

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 the fluorescent lamp ballast portion of their business. It 

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

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

EERE-2007-BT-STD-0016 COMMENT 25
5-8 

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

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

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

 

 DOE supplemented the information provided in Table 5.3.3 by estimating a weightedaverage 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 efficient products. DOE took this approach because amended standards 

may make high-efficiency products, which currently are considered premium products, the 

baseline and commodity products in the future. 

 DOE 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 

fluorescent lamp ballast industry was appropriate. 

5.3.3 MSP Scaling

To estimate MSPs 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 database 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 ballasts 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 contain 70 product classes (

EERE-2007-BT-STD-0016 COMMENT 25
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 (MBP) 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 start (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 commone. 

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

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 lamps 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 analyzed. 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.

EERE-2007-BT-STD-0016 COMMENT 25
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 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

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 USHAPED 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 active mode test procedure 

unless otherwise specified.

EERE-2007-BT-STD-0016 COMMENT 25
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

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.

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 for 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 

represented 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 because only the most 

efficient T12 lamps will be available when this ballast rulemaking takes effect. For the T8 

baseline, DOE chose to analyze only those ballasts that operate the F32T8 lamp because it is the 

most common 4-foot MBP T8 lamp. 

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

F34T12 ballasts for the IS and RS product class. These characteristics included the ballast’s 

starting method (e.g., RS, or IS), input voltage (277 volts (V) vs. 120V), power factor (PF), total 

harmonic distortion (THD), ballast factor, input power, BEF, and type (electronic vs. magnetic), 

and whether the ballast can operate at multiple voltagesg

 

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.

EERE-2007-BT-STD-0016 COMMENT 25
5-12

energy conservation standards. In considering each of these characteristics, DOE chose a 

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

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

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

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

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

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 F34T12 

electronic ballasts in product catalogs are RS, single voltage, have a high PF (~0.98) and a THD 

<20 percent. The ballast that just meets the energy conservation standard also exhibits these 

characteristics. DOE also chose a ballast that has an input voltage of 277V 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 but 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 Voltage >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 ballasts. 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. 

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. 

EERE-2007-BT-STD-0016 COMMENT 25
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 85

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

32.5W for the F32T8 lamp.

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

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

system lumen package of approximately 4,872 mean lumens (and 5,412 initial lumens) for the 

baseline F34T12 ballast, approximately 4,988 mean lumens (and 5,250 initial lumens) for the 

baseline 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 ballast 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 

corresponding 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 the 

EERE-2007-BT-STD-0016 COMMENT 25
5-14

baseline ballasts have different BEF values and represent various design options, 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 of 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 fluorescent lamp ballasts, as required by section 325(o) of EPCA. (42 U.S.C. 

6295(o)). To determine this level, DOE conducted a survey of the fluorescent lamp ballast 

market and the research fields that support the market. DOE believes that within a given product 

class, no working prototypes exist that have a distinguishably higher 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 currently 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 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 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: 92.0 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. 

EERE-2007-BT-STD-0016 COMMENT 25
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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 1.535

CSL3 1.561

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 35

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL3

CSL2

CSL1

EPCA

F32T8 F34T12

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.

EERE-2007-BT-STD-0016 COMMENT 25
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CSL1. BEF: 1.518; 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 33

Ballast 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 engineering 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 representative 

product class, the ballast characteristics are very similar.

EERE-2007-BT-STD-0016 COMMENT 25
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Table 5.5.6 Ballast Designs for the IS and RS Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast 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 ballasts. 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 5.5.7 Ballast Designs for the PS Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor

Input Power

BEF

Ballast 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 for the 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 less costly than the less efficient CSL2 ballast, but both 

CSL2 and CSL3 are more costly than CSL1. 

EERE-2007-BT-STD-0016 COMMENT 25
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Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS 

Representative Product Class

Candidate 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 appropriate lamp prices for the baseline lamps as used in 

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

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

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

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

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

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

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

efficient T12 lamps are currently sold.

Table 5.5.10 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 

classes to provide a comprehensive understanding of the consumer economics. DOE based its 

EERE-2007-BT-STD-0016 COMMENT 25
5-19

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 

S dardsCase

S dardsCase

Baseline

S dardsCase InputPower MLO

MLO NormalizedInputPower tan

tan

tan = ∗

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

matches the light output of the baseline system

MLOBaseline = Mean lumen output of the baseline system 

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

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

Table 5.5.11 through 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 system, the normalized input power is slightly higher than the 

measured input power. If a direct substitution is made, mean lumen output does not change by 

more than 2 percent relative to the mean lumen output of the baseline system. 

EERE-2007-BT-STD-0016 COMMENT 25
5-20

Table 5.5.11 IS and RS Representative Product Class with F32T8 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF 

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 ballasts. 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 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 63.5

EERE-2007-BT-STD-0016 COMMENT 25
5-21

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 ballasts. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode t

ballast is related to ballast efficiency in the following manner: BEF=1.697*BE. 

Table 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 Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage

Power Factor

THD

Ballast Factor

Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 1.518 90.2% 5,176 4,917 -3.8 12.49 5.65 59.1 

EERE-2007-BT-STD-0016 COMMENT 25
5-22 

5.6 BALLASTS THAT OPERATE FOUR FOUR-FOOT MBP AND TWO-FOOT USHAPED 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

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.

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 IS 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). 

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

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

ballasts operate in commercial buildings at 277V. 

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

Operation 

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 both 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 Type CCT Rated Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

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

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

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

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

system lumen package of approximately 9,545 mean lumens (and 10,048 initial lumens) for the 

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

the baseline F32T8 PS ballast. 

EERE-2007-BT-STD-0016 COMMENT 25
5-24

5.6.2 Candidate Standard Levels

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

DOE considered for the 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 baseline 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 33

Ballast 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 Class

EERE-2007-BT-STD-0016 COMMENT 25
5-25

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 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.

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 33

Ballast 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 analysis and subsequent analyses. In general, for the IS and RS 

EERE-2007-BT-STD-0016 COMMENT 25
5-26

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, 

the ballast characteristics are also very similar.

Table 5.6.5 Ballast Designs for the IS and RS Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast Efficiency

V W 

Baseline 4 F32T8

Lamps Electronic IS 277 Single >0.98 <10% 0.84 111.5 0.768 90.5%

CSL1 4 F32T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 114.4 0.781 92.0%

Table 5.6.6 Ballast Designs for the PS Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor

Input Power

BEF

Ballast 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 Ballast Prices

DOE analyzed each CSL for the IS and RS representative product class to develop 

appropriate MSPs. The baseline MSP was calculated using the online price scaling technique 

described in section 5.3.3 whereas the CSL1 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 $11.88

EERE-2007-BT-STD-0016 COMMENT 25
5-27

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

MSPs. The 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 product 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 percent relative to the mean lumen output of the baseline system.

EERE-2007-BT-STD-0016 COMMENT 25
5-28

Table 5.6.10 Four-Lamp Four-Foot MBP RS and IS Product Class with F32T8 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W 

Baseline 4 F32T8 

Lamps Electronic IS 277 Single 0.98 <10% 0.84 111.5 0.768 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 0.781 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 Baseline Candidate Standard 

Level

For Operation Of

Ballast Type

Starting Method

Input Voltage

Universal or Single 

Voltage

Power Factor

THD

Ballast Factor

Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W 

Baseline 4 F32T8 

Lamps Electronic PS 277 Single 0.99 <10% 0.87 120.3 0.708 83.9% 10,382 9,863 N/A 10.72 11.29 120.3

CSL1 4 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10% 0.88 116.1 0.755 89.4% 10,555 10,028 1.7% 14.20 11.29 114.2

EERE-2007-BT-STD-0016 COMMENT 25
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5.7 BALLASTS THAT OPERATE TWO EIGHT-FOOT SP SLIMLINE LAMPS

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 class), 

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 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 F96T12/ES lamps for this 

rulemaking. For the T8 baseline, DOE chose to analyze only those ballasts that operate the 

F96T8 lamp because this lamp is the most common 8-foot SP slimline T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two 

F96T12/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR 

Part 430.32 (m)(5)). This energy conservation standard effectively allowed only electronic 

F96T12/ES ballasts. Therefore, DOE chose an electronic ballast as the F96T12/ES baseline 

ballast. To determine the 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.

EERE-2007-BT-STD-0016 COMMENT 25
5-30

chose a ballast that has an input voltage of 277V because the majority of ballasts operate in 

commercial buildings at 277V. There are multiple THD values for electronic F96T12/ES. These 

range from <20 percent to <14 percent and <10 percent. DOE chose a ballast with a THD of <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, DOE chose 

the most common, least efficient ballast on the market. DOE tested a range of F96T8 ballasts 

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

exhibited the characteristics shown in the table below. The vast majority of F96T8 ballasts are 

IS, electronic, and have a high PF (>0.98). Furthermore, the majority of the least efficient T8 

ballasts are universal voltage and have a THD <10 percent. Finally, like the F96T12/ES baseline 

ballast, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate 

in commercial buildings at 277V. 

Table 5.7.2 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% 0.790 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 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 Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F96T12/ES 4,100 98.2 5,939 5,516 15,000 N/A

F96T8 4,100 98.2 5,900 5,428 15,000 82

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12/ES lamp is 

60.5W and for the F96T8 lamp is 60.1W.

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

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

system lumen package of approximately 9,760 mean lumens (and 10,508 initial lumens) for the 

EERE-2007-BT-STD-0016 COMMENT 25
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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 circuit 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 technologically 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.

EERE-2007-BT-STD-0016 COMMENT 25
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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 61

Ballast 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 ballast 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 ballast.

Table 5.7.4 Ballast Designs for the Eight-Foot SP Slimline Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF

Ballast 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 0.790 90.0%

EERE-2007-BT-STD-0016 COMMENT 25
5-33

Lamps

CSL1 2 F96T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 108.0 0.809 92.2%

*DOE was unable to test the efficiency of these particular ballasts. 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.

5.7.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 8-foot SP slimline representative product class to 

develop appropriate MSPs. Both 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 found 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 19.34

CSL1 F96T12/ES 26.27

Baseline F96T8 15.55

CSL1 F96T8 9.27

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 5.7.6 Retail Prices for Eight-Foot SP Slimline Fluorescent Lamps

Lamp Type

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 product 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 is 

EERE-2007-BT-STD-0016 COMMENT 25
5-34

made, mean lumen output does not change by more than 0.1 percent relative to the mean lumen 

output of the baseline system. 

EERE-2007-BT-STD-0016 COMMENT 25
5-35

Table 5.7.7 Eight-Foot SP Slimline Representative Product Class with F96T12/ES Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 ballasts. 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 baseline system.

Table 5.7.8 Eight-Foot SP Slimline Representative Product Class with F96T8 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W 

Baseline 2 F96T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.790 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 0.809 92.2% 10,317 9,491 1.0% 9.27 11.84 106.9

EERE-2007-BT-STD-0016 COMMENT 25
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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 procedure 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 Two 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 class 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 (excluding cold temperature sign ballasts) to be about 0.5 percent. 

DOE believes most of the 8-foot HO ballasts currently shipped are T12. However, the 2009 

Lamps Rule will reduce the number of T12 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 ballasts that operate two 

F96T12HO/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 

CFR Part 430.32 (m)(5)). This energy conservation standard did not eliminate magnetic ballasts 

from the market. Therefore, DOE chose a magnetic ballast as the F96T12HO/ES baseline ballast. 

To determine the 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.

EERE-2007-BT-STD-0016 COMMENT 25
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 F96T8HO 

ballasts are electronic and have a high PF (>0.95). Furthermore, the majority of the least efficient 

T8 ballasts have a THD <20 percent. Finally, like the F96T12HO/ES baseline ballast, DOE 

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

commercial buildings at 277V. 

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, THD

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 ballasts. 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 representative product class, the 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 24,000 78

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12HO/ES lamp is 

97W and for the F96T8HO lamp is 86W.

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 16,339 initial lumens) for the 

baseline F96T12HO/ES ballast, approximately 12,496 mean lumens (and 13,904 initial lumens) 

for the baseline F96T8HO ballast. 

EERE-2007-BT-STD-0016 COMMENT 25
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 (preliminary TSD chapter 4), DOE used design options that achieved 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 technologically 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.

EERE-2007-BT-STD-0016 COMMENT 25
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 96

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL2

CSL1

F96T8HO F96T12HO/ES

F96T8HO Baseline

F96T12HO/ES Baseline

Figure 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 

the engineering analysis and subsequent analyses. For the more efficient F96T12HO/ES and 

F96T8HO ballasts, the ballast factor is lower than that of the baseline ballast.

Table 5.8.4 Ballast Designs for the Eight-Foot RDC HO Representative Product Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF

Ballast Efficiency

V W 

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Single ≥0.90 <18% 0.92 208.4 0.440 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%*

EERE-2007-BT-STD-0016 COMMENT 25
5-41

CSL2 2 F96T8HO 

Lamps Electronic IS 277 Single >0.98 <10% 0.68 142.8 0.549 89.4%

*DOE was unable to test the efficiency of these particular ballasts. 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 representative product 

class, the 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 baseline, 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 table 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

Baseline/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.

EERE-2007-BT-STD-0016 COMMENT 25
5-42

Table 5.8.7 Eight-Foot RDC HO Representative Product Class with F96T12HO/ES Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W 

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Single 0.90 <18% 0.92 208.4 0.440 71.6%* 16,339 14,705 N/A 22.80 24.70 208.4 

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 24.70 183.4

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% 0.68 142.8 0.549 89.4% 10,682 9,600 -34.7% 24.38 13.13 218.8

*DOE was unable to test the efficiency of these particular ballasts. 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 representative product class, the 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 F96T8HO 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.

EERE-2007-BT-STD-0016 COMMENT 25
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Table 5.8.8 Eight-Foot RDC HO Representative Product Class with F96T8HO Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 13.13 160.0 

CSL2 2 F96T8HO 

Lamps Electronic IS 277 Single 0.98 <10% 0.68 142.8 0.549 89.4% 10,682 9,600 -23.2% 24.38 13.13 185.9

*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 representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF=0.614*BE. 

EERE-2007-BT-STD-0016 COMMENT 25
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5.9 BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP T5 SO LAMPS

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

Currently 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 MiniBP 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 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.

 Therefore, DOE has chosen to only 

analyze the F28T5 baseline ballast. 

Table 5.9.2 Baseline Ballast 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 79.1%* 1.309 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 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).

EERE-2007-BT-STD-0016 COMMENT 25
5-45

ballast efficiency 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 Efficacy* Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

F28T5 4,100 104.3 2,900 2,660 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F28T5 lamp is 27.8W.

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

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

system lumen package of approximately 5,419 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.

EERE-2007-BT-STD-0016 COMMENT 25
5-46

1.250

1.300

1.350

1.400

1.450

1.500

1.550

1.600

1.650

1.700

27 28 29

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL1

F28T5 Baseline

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 Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF

Ballast 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%

EERE-2007-BT-STD-0016 COMMENT 25
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*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, the 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 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. 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. 

EERE-2007-BT-STD-0016 COMMENT 25
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Table 5.9.7 Four-Foot T5 MiniBP SO Representative Product Class with F28T5 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor

Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W

Baseline 2 F28T5 

Lamps Magnetic 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, the BEF of a ballast is related to ballast efficiency in the following manner: 

BEF=1.655*BE. 

EERE-2007-BT-STD-0016 COMMENT 25
5-49

5.10 BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP T5 HO LAMPS

In this section, DOE analyzes the representative product 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 Operate Two Four-Foot 

MiniBP T5 HO 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 product 

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 minimum 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 ballasts 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-

foot 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 74.2%* 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 that is not a F54T5HO. One manufacturer 

sells a reduced wattage (F51T5HO). Another manufacturer sells a F49T5HO.

EERE-2007-BT-STD-0016 COMMENT 25
5-50

procedure. For the 4-foot T5 MiniBP HO representative product class, the 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 F54T5HO Ballasts

Lamp 

Type

CCT Rated Efficacy* Initial Light 

Output

Mean Light 

Output Life CRI

K lm/W lm lm hr

F54T5HO 4,100 92.9 5,000 4,600 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F54T5HO lamp is 

53.8W.

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

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

system lumen package of approximately 9,087 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 

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 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 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: 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 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.

EERE-2007-BT-STD-0016 COMMENT 25
5-51

0.650

0.700

0.750

0.800

0.850

0.900

53 54 55

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL1

F54T5HO Baseline

CSL2

Figure 5.10.1 Candidate 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 

Class Candidate Standard Level

For Operation Of

Ballast Type

Starting Method

Input Voltage

Universal or Single 

Voltage

Power Factor

THD

Ballast Factor

Input Power

BEF

Ballast 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 0.837 90.3%

EERE-2007-BT-STD-0016 COMMENT 25
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 magnetic 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. Using this 8-foot HO ratio, 

DOE adjusted the price assigned to CSL1 to calculate the price for the model magnetic T5 HO 

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 appropriate 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 F54T5HO 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.

EERE-2007-BT-STD-0016 COMMENT 25
5-53

Table 5.10.7 Four-Foot T5 MiniBP HO Representative Product Class with F54T5HO Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 0.837 90.3% 10,152 9,340 2.8% 18.27 8.56 119.1

EERE-2007-BT-STD-0016 COMMENT 25
5-54

5.11 BALLASTS THAT OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED LAMPS 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 otherwise 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 

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

Shading indicates a representative product class.

5.11.1 Baseline Models 

For the Residential 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 by 

foreign companies which do not share shipment data with the U.S. Census. Through 

manufacturer interviews, DOE learned that both T12 and T8 ballasts are popular in the 

residential market. Therefore, DOE analyzed both a T12 and T8 ballast as a baseline ballast. 

Because the 2009 Lamps Rule 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 the 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.

EERE-2007-BT-STD-0016 COMMENT 25
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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 

Efficiency 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% 1.457 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, the BEF of a ballast is related to ballast 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 lamp is 34W and 

for the F32T8 lamp is 32.5W.

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

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

system lumen package of approximately 3,310 mean lumens (and 3,676 initial lumens) for the 

EERE-2007-BT-STD-0016 COMMENT 25
5-56

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 steps and technologies associated with each CSL 

DOE considered for the residential 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 residential 

representative product class, DOE identified two CSLs. CSL2 represents the maximum 

technologically 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 ballasts. The plot 

also shows the replacement ballasts DOE is considering at CSL1 and CSL2.

EERE-2007-BT-STD-0016 COMMENT 25
5-57

1.25

1.30

1.35

1.40

1.45

1.50

1.55

31 32 33 34 35

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL2

CSL1

F32T8 F34T12

F32T8 Baseline

F34T12 Baseline

Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class

Table 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 Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast 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 1.457 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. DOE estimates are based on the relationship 

between BEF and ballast efficiency determined by the active mode test procedure. For the residential representative 

EERE-2007-BT-STD-0016 COMMENT 25
5-58

product class, the 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 residential 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 fixture. 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 appropriate 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 residential representative product class. Because the BF of 

the standards-case system is higher than the baseline system, the normalized input power is 

lower than the measured input power. If a direct substitution is made, mean lumen output can 

increase by as much as 43 percent over the mean lumen output of the baseline system because of 

the difference in ballast 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 will 

EERE-2007-BT-STD-0016 COMMENT 25
5-59

not purchase direct ballast replacements, but rather replacement fixtures. Therefore, the 

normalized input power is the most relevant scenario because fixture spacing can be easily 

adjusted when a new fixture is installed. 

EERE-2007-BT-STD-0016 COMMENT 25
5-60

Table 5.11.7 Residential Representative Product Class with F34T12 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

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 F32T8 

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 the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the 

residential 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 Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor

Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W 

Baseline/CSL1 2 F32T8 

Lamps Electronic IS 120 Single N/A N/A 0.78 53.1 1.457 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 51.8

EERE-2007-BT-STD-0016 COMMENT 25
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5.12 BALLASTS THAT OPERATE FOUR EIGHT-FOOT HO LAMPS IN COLD 

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS 

In 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 common 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 Sign 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, 0.77 393.6 74.4%* 0.196 N/A

EERE-2007-BT-STD-0016 COMMENT 25
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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 class, the 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 Temperature F96T12HO Ballasts 

Lamp Type

CCT Rated Efficacy*

Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

K lm/W lm lm hr

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

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

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

system lumen package of approximately 21,472 mean lumens (and 26,509 initial lumens) for the 

baseline F96T12HO ballast.

5.12.2 Candidate Standard Levels

The following discussion 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 CSL1.

EERE-2007-BT-STD-0016 COMMENT 25
5-63

0.00

0.04

0.08

0.12

0.16

0.20

0.24

0.28

109 110 111

Ballast 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 Class Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast Efficiency

V W

Baseline 2 F96T12HO 

Lamps Magnetic RS 120 Single N/A N/A 0.77 393.6 0.196 74.4%*

CSL1 2 F96T12HO 

Lamps Electronic IS 120 Universal N/A N/A 0.63 264.0 0.238 90.4%*

*DOE was unable to test the efficiency of these particular ballasts. 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.

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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 and 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 that 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 Ballast 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 Price 

(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.

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Table 5.12.7 Sign Ballast Representative Product Class with F96T12HO Baseline Candidate Standard Level For Operation Of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power

BEF

Ballast Efficiency

System Initial 

Light Output

System Mean 

Light Output

Percentage 

Change Mean 

Lumen Output

Ballast 

Manufacturer 

Selling Price

Lamp Retail Price

Normalized Input 

Power

V W lm lm % $ $ W

Baseline 4 F96T12HO 

Lamps Magnetic RS 120 Single N/A N/A 0.77 393.6 0.196 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 0.63 264.0 0.238 90.4%* 21,599 17,495 -18.5% 35.58 19.34 324.1

*DOE was unable to test the efficiency of these particular ballasts. 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. 

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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 operate different numbers of lamps, have different 

ballast factors, or have 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 chose 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 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

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 available 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 lamps and cold temperature 

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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 operate 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 

Total Rated Lamp Power-0.942 Ballast Efficacy Factor = Coefficient ∗ 

 To determine the appropriate coefficient in the equation above, DOE relied on the 

analysis performed for each representative 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 larger for higher CSLs. 

5.13.2 Starting Method

As discussed in preliminary TSD chapter 3, the starting method of a ballast affects its 

efficiency. Rapid start and programmed start ballasts are inherently less efficient than instant 

start ballasts, as these ballasts use 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 ballasts 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 BEF than 

ballasts with a normal ballast factor.

12

 

12 In general, ballasts 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 containing 

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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 calculated 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 shading 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.

 When necessary, DOE then scaled based on starting method. For ballasts 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. 

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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 shading 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 with CSLs scaled based on the starting 

method relationship.

 Last, when required, DOE scaled based on ballast factor. As discussed in section 5.13.3, 

DOE developed scaling factors for both high and low BF ballasts. For ballasts 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 factor 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 shading 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 

indicates 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. 

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Table 5.13.5 CSLs for All Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped 

Lamps

Ballast and 

Lamp Type

Starting 

Method

Ballast 

Factor CSL Number of Lamps

One Two Three Four Five Six

4-Foot MBP, 

and 2-Foot UShaped

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 0.533

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.

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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 Residential Ballasts That Operate Four-Foot MBP and TwoFoot 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 UShaped

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 Outdoor 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.

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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> 

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