1 | Energy Efficiency and Renewable Energy 

Energy Conservation Standards

Framework Document forFluorescent Lamp Ballasts

July 17, 2015

Lucy deButtsDepartment of EnBuilding TechnoloEERE‐2015‐BT‐STD‐000

FluorLampBallast2015
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.

– Say your name for the record—there will be a complete tra

this meeting.

– Be concise—share the “air‐time.”

– Keep the focus here—cell phones on silent; limit sidebar

conversations.

– Webinar participants turn phone on mute; “raise your hand

recognized to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Agenda9:00 – 9:30 AM Welcome, Introductions, Opening Statemen

9:30 – 10:00 AM Overview, Scope of Coverage

10:00 – 10:30 AM Market and Technology Assessment, Screen

Analysis

10:30 – 10:45 AM Break

10:45 – 11:30 AM Engineering Analysis

11:30 – 12:00 PM Energy Use, Markups, Life‐Cycle Cost Analys

12:00 – 12:45 PM Lunch

12:45 – 1:15 PM Shipments, National Impact Analysis

1:15 – 1:30 PM NOPR Analyses

1:30 – 1:45 PM Questions, Closing Remarks
4

Listening Via the Webcast• DOE is broadcasting this meeting live over the Intern• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows interested parties to listen 

view the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
5

Purpose of the Public Meeting• Present the procedural and analytical approaches to 

energy conservation standards for fluorescent lamp b

• Invite comment on the energy conservation standard

framework document.

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion.
6

Issues for DiscussionIssue box numbering corresponds to the list of issues p

at the end of the Framework document, available at:

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?rul

Issue Box: DOE welcomes comments, data, and information

concerning standards for fluorescent lamp ballasts. Issues tha

correspond to those raised in DOE’s published material will b

numbered in accordance with that material. Whether invited 

issue box or not, comments are welcome on any part of DOE

analysis.
7

In all correspondence, please refer to the Fluorescent Lamp Ballas

rulemaking by:

– Framework Document for Fluorescent Lamp Ballasts

– Docket Number EERE‐2015‐BT‐STD‐0006

– Regulation Identification Number (RIN) 1904‐AD51

Email: FluorLampBallasts2015STD0006@ee.doe.govWeb: www.regulations.govPostal: Courier:Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies PrograMailstop EE‐5B 950 L’Enfant Plaza SW, Suite 61000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes August 7, 2015

How to Submit Written Comments
8

Opening Remarks

Meeting participants are invited to provide opening rem

statements at this time.
9

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
10

Overview: Regulatory History• Amendments to the Energy Policy and Conservation 

1975 (EPCA) directed DOE to conduct two rulemakinto evaluate standards for fluorescent lamp ballasts.

– Final rule published September 19, 2000 (“2000 ballast rule”). 65 FR 5674

– Final rule published November 14, 2011 (“2011 ballast rule”). 76 FR 70548

• The Energy Independence and Security Act of 2007 (

directs DOE to review all of its standards. Within 6 ye

the publication of the previous final rule, DOE must e

– Publish a notice of determination that standards do not need to be amen

– Publish a notice of proposed rulemaking including new proposed standard
11

Overview: Ballast Rulemaking Schedule

Milestone 

Notice of Public Meeting and Availability of Framework Document 

Notice of Public Meeting and Availability of Preliminary Technical

Support Document (projected) S

Notice of Proposed Rulemaking (projected) Final Rule (projected) 

2015 2016 2017 2018 2019 
12

Overview: EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors 

setting energy conservation standards.

EPCA Factors DOE Analysis

1. Economic impact on consumers and

manufacturers

Life‐Cycle Cost An

Manufacturer Impact 

2. Lifetime operating cost savings compared

to increased cost for the product Life‐Cycle Cost An

3. Total projected energy savings National Impact An

4. Impact on utility or performance Engineering Ana

Screening Analy

5. Impact of any lessening of competition Manufacturer Impact 

6. Need for national energy conservation National Impact An7. Other factors the Secretary considers

relevant

Emissions Analy

Utility Impact Ana

Employment Impact 
13

Overview: Standby Mode and Off ModeStandby mode is defined as the condition in which an energ

piece of equipment is connected to a main power source an

one or more of the following user‐oriented or protective fun

facilitating the activation or deactivation of other functions (

active mode) by remote switch (including remote control), in

sensor, or timer; or providing continuous functions, includin

information or status displays (including clocks) or sensor‐ba

functions.

• EPCA requires DOE to include standards for standby mode 

mode energy consumption, if relevant. (42 U.S.C. 6295(gg

• Some ballasts operate in standby mode, but none operate 

mode.

Off mode is defined as the condition in which an energy‐usin

equipment is connected to a main power source, and is not 

any standby or active mode function.
14

Issues for CommentIssue 2‐2: Standby ModeDOE welcomes comment on which ballasts are capable of operatin

standby mode and any other information relating to standby mod

use.
15

Overview: Metric• Current energy conservation standards for fluoresce

ballasts are applicable to active mode energy use an

based on ballast luminous efficiency (BLE).

• DOE plans to continue using the BLE metric in this en

conservation standard rulemaking to regulate active energy use.

• DOE plans to consider an integrated metric to regula

ballasts that can operate in standby mode.

Issue 2‐3: MetricDOE welcomes comment on the metrics used for establishing ene

conservation standards for active mode and standby mode energy 

Issue 2‐1: Test ProcedureDOE welcomes comment on the current test procedure and wheth

amendments are needed.
16

Scope of Coverage

Fluorescent lamp ballast means a device which is used to start and opera

fluorescent lamps by providing a starting voltage and current and limiting 

during normal operation.

10 CFR 430.2

• The scope of coverage includes any device that meet

definition of fluorescent lamp ballast.

Fluorescent lamp means a low pressure mercury electric‐discharge source 

fluorescing coating transforms some of the ultraviolet energy generated b

mercury discharge into light, including only the following:

1. Straight‐shaped 4‐foot medium bipin lamps with rated wattage of 25 or more,

2. 2‐foot U‐shaped lamps with rated wattage of 25 or more,

3. Rapid start 8‐foot high output lamps with recessed double contact bases,4. Instant start 8‐foot slimline lamps with single pin bases and rated wattage of 49 

5. Straight‐shaped 4‐foot miniature bipin standard output lamps with rated watta

more, and

6. Straight‐shaped 4‐foot miniature bipin high output lamps with rated wattage of 

10 CFR 430.2
17

Scope: Current Standards• Ballasts currently required to comply with standards 

those:

– That operate at or between 120 volts (V) and 277 V with an 

frequency of 60 hertz and

– That operate lamps that meet the definition of fluorescent 

• Ballasts currently exempt from standards include:

– Ballasts that dim to 50 percent or less of the maximum out

(except ballasts that operate one or two F34T12 lamps, two 

ES lamps, or two F96T12 HO ES lamps),

– Low‐frequency ballasts designed to operate T8 lamps in EM

sensitive environments and shipped in packages containing 

fewer ballasts, and

– Very low ballast factor programmed start (PS) ballasts that 

T8 MBP lamps that deliver less than 140 milliamperes to ea
18

Scope: Additional Ballasts under Consideration• DOE considers standards for ballasts that would resu

significant conservation of energy and also aretechnologically feasible and economically justified. (4

6295(n)(2))

• DOE plans to consider analyzing standards for the fo

ballasts:

– Dimming ballasts,– Low BF 4‐foot MBP T8 PS ballasts with an average current l

140 milliamperes, and

– Ballasts operating at 480 V.

• DOE does not plan to consider standards for magnet

ballasts that operate T8 lamps in EMI‐sensitive

environments.
19

Scope: Dimming Ballasts• DOE finds the increased sales of dimming ballasts wa

analysis of the technological feasibility, economic jusand potential for significant energy savings of energy

conservation standards for dimming ballasts.

• The recent general service fluorescent lamp (GSFL) a

incandescent reflector lamp energy conservation sta

rulemaking determined that about 8 percent of GSFL

operated by dimming ballasts. 80 FR 4042 (Jan. 26, 2

Issue 3‐1: Dimming BallastsDOE welcomes comment on the feasibility and justification for set

standards for additional dimming fluorescent lamp ballasts. In par

requests market and shipment information as well as information 

the potential for efficiency improvements and energy savings.
20

Scope: Low BF 4‐Foot MBP T8 PS Ballasts• DOE plans to reevaluate the justification for excluding fro

4‐foot T8 MBP PS fluorescent lamp ballasts with an outpu

140 mA per lamp.

• Some low BF PS ballasts operate at currents below minim

C78.81‐2010 levels, requiring cathode heating to maintai

• None of the PS ballasts tested with an average current of 

140 mA were able to meet the max tech ELs analyzed in tproduct class for the 2011 ballast rule.

• In the 2011 ballast rule, DOE exempted these low BF PS b

standards.

Issue 3‐2: Low BF 4‐foot MBP T8 PS Ballast ExemptionDOE welcomes comment on the current exclusion from standards 

PS fluorescent lamp ballasts with an output less than 140 mA per 

welcomes any relevant shipment information for these products.
21

Scope: Ballasts Operating at 480 Volts• DOE may evaluate energy conservation standards fo

that operate at 480 V in this rulemaking.

• 480 V ballasts are used in the industrial sector.

• 4‐foot MBP T8 and 4‐foot SO and HO T5 lamps are o

480 V ballasts.

Issue 3‐3: 480 Volt BallastsDOE welcomes comment on whether standards for fluorescent lam

that operate at input voltages other than at or between 120 and 2

save significant energy and be technologically feasible and econom

justified. In particular, DOE requests market and shipment informa

as information regarding the potential for efficiency improvement

savings.
22

Scope: T8 Magnetic Ballasts for EMI‐sensitive L• In the 2011 ballast rule, DOE exempted T8 magnetic 

designed, labeled, and marketed for use in EMI‐sens

locations and shipped by the manufacturer in packagcontaining 10 or fewer ballasts.

• In some environments, EMI could pose a serious safe

that is best mitigated with magnetic ballast technolo

• Because these EMI‐related safety concerns still exist

to continue excluding these magnetic T8 fluorescent ballasts from consideration for standards in this rule

Issue 3‐5: Ballasts for EMI‐sensitive environmentsDOE welcomes comment, including shipment information, on the 

amend the current exclusion from standards for low frequency T8 

lamp ballasts for EMI‐sensitive environments.
23

Issues for CommentIssue 3‐4: Additional Ballasts for Consideration for StandardsDOE welcomes comment on any additional fluorescent lamp balla

should be considered for standards. In particular, DOE requests ma

shipment information as well as information regarding the potent

efficiency improvements and energy savings.
24

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
25

Product Classes• DOE divides covered products into classes by

– The type of energy used,

– Capacity of the product, or

– Other performance‐related features that justify different st

levels, such as features affecting consumer utility.

• DOE establishes separate energy conservation stand

each product class.
26

Current Product Classes

Product Class Lamps Operated

IS and RS ballasts (not classified as residential)

4‐foot MBP lam

2‐foot U‐shaped 

8‐foot slimline la

PS ballasts (not classified as residential)

4‐foot MBP lam

2‐foot U‐shaped 

4‐foot MiniBP SO 4‐foot MiniBP H

IS and RS ballasts (not classified as sign ballasts) 8‐foot HO lamps

PS ballasts (not classified as sign ballasts) 8‐foot HO lamps

Sign ballasts 8‐foot HO lamps

IS and RS residential ballasts

4‐foot MBP lam

2‐foot U‐shaped 

8‐foot slimline la

PS residential ballasts 4‐foot MBP lam

2‐foot U‐shaped 
27

Product Classes• Additional product classes may be needed if DOE co

standards for additional categories of ballasts.

• DOE may use the following factors to establish any n

– Residential versus commercial,– Lamp type operated by the ballast,

– Method of dimming, or

– Standardized control interfaces such as digitally addressabl

interface (DALI).
28

Issues for CommentIssue 4‐2: Product Class DivisionsDOE welcomes comment on the product class divisions it is consid

fluorescent lamp ballasts. In particular, DOE welcomes comment o

appropriate class‐setting factors for dimming ballasts, low ballast f

ballasts, and 480 V fluorescent lamp ballasts.

Issue 4‐3: Other Class‐Setting FactorsDOE welcomes comment on any other class‐setting factors that sh

considered in the analysis.

Issue 4‐1: Market AssessmentDOE welcomes information on shipments, product‐feature and eff

trends, distribution channels, and estimates of market shares for b

considered in this rulemaking. For the data to be used to conduct 

savings calculations, please provide appropriate groupings (e.g., by 

product class, technology, and/or other relevant performance cha
29

Technology Options

Technology Option Description

Improved Circuit

Design

Cathode Cutout Remove filament heating after la

started.

IntegratedCircuits

Substitute discrete components wintegrated circuit.

Improved

Components

Transformers &

Inductors

Use optimized‐gauge copper or in

conductor cross section.

Use multiple smaller coils instead 

coil.Use shape‐optimized windings.

Use litz wire to reduce winding lo

Use laminated sheets of grain ori

amorphous steel to create the co

inductor.

DOE has identified the following preliminary list of technology opt

improve BLE:
30

Technology Option Description

Improved

Components

Diodes Use diodes with lower losses.

Capacitors Use capacitors with a lower effect

resistance.

Transistors Use transistors with low drain‐to‐s

resistance.

DOE has identified the following preliminary list of technology opt

improve BLE:

Technology Options

Issue 4‐4: Technology OptionsDOE welcomes comment on the preliminary technology options id

this section. DOE welcomes comment on whether there are additi

technology options that it should consider.
31

Screening Analysis• The screening analysis removes technology options t

will not consider in the engineering analysis based o

– Technological feasibility,– Practicability to manufacture, install, and service,

– Adverse impacts on utility to consumers or availability, and

– Adverse impacts on health or safety.

• DOE will consider screening out laminated sheets of

amorphous steel to create the core of the inductor,

consistent with the screening analysis in the 2011 ba

rule.
32

Issues for CommentIssue 5‐1: Screening FactorsDOE welcomes comment on the applicability of the four screening 

the technology options described in this section, including whethe

appropriate to screen out the use of laminated sheets of amorpho

create the core of the inductor.

Issue 5‐2: Screening Criteria’s Applicability to Technology OptionsDOE welcomes comment on how the four screening criteria would 

any additional technology option(s) that an interested party recom

DOE.
33

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
34

Choose representative product classes to be ana

directly.

Engineering Analysis: Methodology

Identify baseline ballasts and their characteristic

representative product class.

Identify more efficient ballasts for each baseline 

based on design options.

Develop efficiency levels (ELs) that range from t

to the maximum technologically feasible.

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing

Establish a relationship between BLE and end‐u

Scale results to produce classes not analyzed.
35

Representative Product Classes

• DOE chooses representative product cla

concentrate its analytical effort.

• DOE selects representative product clas

primarily because of their high market v

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
36

Baseline Ballasts

• DOE selects baseline ballasts in each

representative product class.

• For products that do not have existing s

DOE selects the most common, least ef

ballast sold.

• For products that have existing standard

typically selects the most common, leasballasts that just meet existing energy

conservation standards.

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
37

Issues for CommentIssue 6‐1: Baseline BallastsDOE welcomes comment on the appropriate baseline for ballasts asubject to energy conservation standards.Issue 6‐2: New Category Baseline BallastsIf DOE analyzes standards for new categories of ballasts, including 

dimming, low ballast factor PS, or 480 V fluorescent lamp ballasts, 

welcomes comment on the appropriate baseline ballast types and 

value in those categories.
38

Higher‐Efficiency Replacements

• DOE selects more efficient ballasts for e

baseline ballast by considering technolo

eliminated in the screening analysis.

• DOE analyzes a lamp‐and‐ballast system 

account for total system energy consumsystem light output.

• To identify replacements, DOE plans to 

database of commercially available ball

BLE compliance data in the Compliance

Certification Management System (CCM

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
39

Efficiency Levels

• DOE plans to develop ELs based on thre

– The design options associated with specific 

being studied,

– The ability of ballasts of multiple wattages t

with the EL of a given product class, and

– The maximum technologically (Max Tech) fe

• DOE anticipates developing ELs using an 

that relates the total lamp arc power op

a ballast to BLE.

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
40

Issues for CommentIssue 6‐3: Higher‐Efficiency ReplacementsDOE welcomes comment on the methodology it is considering to shigher‐efficiency ballast designs.Issue 6‐4: Efficiency Level MethodologyDOE welcomes comment on its proposed methodology of establis

efficiency levels, including the form of an equation that relates ave

lamp arc power to BLE.

Issue 6‐5: BLE Data SourceDOE welcomes comment on the use of compliance data and verifi

testing data when establishing efficiency levels.
41

Scaling to Product Classes Not Analyzed

• Standards for non‐representative produ

are determined by scaling standards froclasses that were directly analyzed.

• DOE plans to develop scaling factors by 

the BLE of ballasts in representative pro

classes to the BLE of ballasts in non‐repproduct classes.

Issue 6‐7: ScalingDOE welcomes comments on the methodology tenergy conservation standards to product classe

analyzed.

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
42

Pricing

• DOE’s analysis establishes a relationship 

BLE and end‐user price.

• DOE may conduct a product teardown c

assessment to identify the manufacture

production cost (MPC).

– The MPC would be marked up to a manufac

price (MSP). The MSP would be marked up 

price in the markups analysis.

• DOE may also use blue books and retail 

develop end‐user retail pricing directly.

Issue 6‐6: Pricing MethodologyDOE welcomes comment on the pricing methodo

particular the feasibility of using product teardow

pricing.

Choose

Representative

Product Classes

Identify Baseline

Models

Scale to Product

Classes Not Analyzed

Develop Efficiency

Levels

Identify More Efficient

Replacements

Pricing
43

Issues for CommentIssue 6‐8: Proprietary DesignsDOE welcomes comments on proprietary designs it should be awa

fluorescent lamp ballasts that are the subject of this rulemaking.

Issue 6‐9: Regulatory BurdensDOE welcomes comments on regulatory burdens or changes that s

considered in the engineering analysis.

Issue 6‐10: Other Engineering IssuesDOE welcomes comments on other issues that could affect the en

analysis.
44

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
45

• Purpose:

- Assess the annual energy use for all efficiency levels, for all 

classes

• Method:

- Input power to ballast × operating hours = energy usage

- Develop operating hours by sector

- Drawing on data sources: Lighting Market Characterization, 

CBECS, & MECS

Rulemaking Analyses: Energy Use Analysis

Sector Average Annual Operating Hours (hr/yr

2000 Ballast Rule 2011 Ballast Rule

Residential N.R. 789Commercial 3,300 – 3,700 3,886Industrial 4,600 4,747
46

Issues for Comment

Issue 7‐1: Energy Use Operating ProfilesDOE welcomes comment on the approach DOE is taking to deter

operating hours profile for fluorescent lamp ballasts in this rule.

Furthermore, DOE welcomes comment on whether the end‐use o

profiles are different for the various types of fluorescent lamp ba

consideration for standards in this rulemaking, and if so, how.

Issue 7‐2: Reduced Wattage LampsDOE welcomes comment on the wattage of reduced‐wattage fluo

lamps typically installed as well as what proportion of reduced‐w

lamps are installed. DOE also welcomes comments on the prevale

tubular LEDs operating on fluorescent lamp ballasts.
47

Rulemaking Analyses: Energy Use Analysis

Issue 7‐3: Occupancy SensorsDOE welcomes comment on the typical space types operated by 

sensors. DOE also welcomes any data on the energy savings relat

use of occupancy sensors. DOE welcomes data on the portion of 

ballasts used with occupancy sensors. DOE welcomes any data on 

of occupancy sensor use on the operating hours profile for fluore

ballasts in this rule.

Sector Average Annual Operating Hours (hr/yr)

Commercial 2,721

• Occupancy Sensors:

- 2011 ballast rule accounted for occupancy sensors at it rela

operating hours
48

Issues for Comment

Issue 7‐4: Dimming BallastsDOE welcomes comment on the use of the dimming ballasts: typ

ballasts and lamps typically dimmed; applications in which dimm

output setting of the dimmed ballasts when in use; typical energy 

dimming ballasts; and market share of dimming ballasts in use.

Issue 7‐6: Data Sources for Dimming BallastsDOE welcomes comment on any data sources to use to calculate 

operating hours of fluorescent ballasts and energy savings related 

of dimming fluorescent ballasts.
49

Issues for Comment

Issue 7‐5: End‐Use ProfilesDOE welcomes comment on the use of the operating hours profi

fluorescent lamp ballasts in this rule. Furthermore, DOE welcome

on whether the end‐use operating profiles are different for the va

of fluorescent lamp ballasts under consideration for standards in 

rulemaking, and if so, how.
50

• Purpose:

- Estimate actual user purchase prices from manufacturer se

prices of baseline and higher‐efficiency product designs

• Method:

- Identify distribution channels and estimate share of each c

the aggregate sales volume

- Estimate markup values for each level in the identified dist

channels

Rulemaking Analyses: Markups Analysis
51

Rulemaking Analyses: Markups Analysis

Issue 8‐1: Distribution ChannelsDOE seeks comment on the distribution channels and the share f

distribution channel described in this document as it applies to th

fluorescent lamp ballasts under consideration for standards in th

rulemaking.

• Identified Distribution Channels:

- 2000 / 2011 Ballast rules

- 63% fixture ballasts

- 37% replacement ballasts

• Markups applied at each arrow
52

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
53

• Purpose:

- Assess economic impacts of different efficiency levels on th

consumers of fluorescent lamp ballasts

• Method:Rulemaking Analyses: LCC and PBP Analysis

- Results are expressed in terms of LCC savings (LCC at baseli

efficiency level compared to LCC at higher efficiency level)

- PBP, expressed in number of years, is calculated by dividing 

incremental product first cost at a higher‐efficiency level by 

corresponding annualized operating cost savings

࢙࢕࡯	ࢍ࢔࢏࢚ࢇ࢘ࢋ࢖ࡻ ൅ ࡸࡱ࢚࢙࢕࡯	ࢊࢋ࢒࢒ࢇ࢚࢙࢔ࡵ ൌ ࡸࡱ࡯࡯ࡸ
54

Rulemaking Analyses: LCC and PBP Analysis

LCC Component Calculation Methodology

Product Purchase Price Mark up MSP by the appropriate distribution ch

markup values

Installation Cost Includes labor and material costs to place the p

service

Maintenance Cost Incurred by the consumer for preventative main

the products

Repair Cost Repair or replace damaged or malfunctioning co

the products

Energy Cost Energy Information Administration’s Annual Ene

used to estimate energy prices

Discount Rate

The cost of capital and is the weighted average 

and debt financing for commercial/industrial se

“finance costs” for residential sectors

Product Lifetime Catalogs, literature sources, technical reports, a

inputs
55

• No‐New‐Standards Case Efficiency Distribution

‒ No‐new‐standards case efficiency distribution is the distrib

the market share of each efficiency level for all product cla

absence of an amended DOE standard

‒ If market share data are not available by efficiency level, DO

develop no‐new‐standards efficiency distributions based o

models and information from fluorescent lamp ballast man

and experts

Rulemaking Analyses: LCC and PBP Analysis
56

• Approach: Monte Carlo Simulations

- The LCC analysis is carried out using Monte Carlo simulatio

- For each of a large number of samples (e.g., 10,000), param

values are chosen based on the probability of their occurre

values are then combined to calculate the LCC and PBP for 

particular individual sample.

- The LCC, LCC savings, and PBP are expressed in the form of 

median values.

- The LCC results are also presented in the form of estimated

percentage of consumers that are adversely affected by am

standards.

Rulemaking Analyses: LCC and PBP Analysis
57

Issues for Comment

Issue 9‐1: Electricity PricesDOE welcomes input on the electricity prices to be used in this anIssue 9‐2: Discount RatesDOE welcomes input on the planned approaches for estimating d

rates for consumers of fluorescent lamp ballasts under considera

standards in this rulemaking.
58

Issues for Comment

Issue 9‐3: Cost InputsDOE welcomes comment on how to develop installation, mainten

(if applicable) repair costs for fluorescent lamp ballasts. In particu

fluorescent ballast energy conservation standards affect the usef

of the ballasts and/or the fluorescent lamps operated by those b

the lamps operated by the more‐efficient ballasts would be affec

DOE invites comments from interested parties on whether re‐lam

practices (i.e., group re‐lamping and spot re‐lamping) would chan

result of the standard.

Issue 9‐4: Ballast LifetimesDOE welcomes comment on appropriate fluorescent lamp ballast 

for the ballasts under consideration for standards in this rulemak
59

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
60

• Purpose:

- Project future shipments by product class

• Method:

- DOE typically projects shipments for a 30‐year period begin

the expected compliance date of the standard

- DOE intends to collect build on the previous rule shipment

projections as well as other shipment data for fluorescent l

ballasts

- Future shipments will be calculated based on the historical

shipments data, retirement rates of previously installed ba

other appropriate data sources

- DOE may use different shipments projections in the standa

and no‐new‐standards case scenarios depending on the inf

available

Rulemaking Analyses: Shipments Analysis
61

• New Construction

- Means the new ballasts that are installed each year becaus

product growth in a particular sector. DOE plans to determ

for this using AEO growth projections for commercial and i

equipment sectors. 30‐year period beginning with the expe

compliance date of the standard

• Replacements

- Refers to the new ballasts that are installed each year to re

ballasts that have failed. DOE plans to base this calculation 

sales and retirements rates

• Retrofits

- Means the ballasts replacing existing ballasts during renova

retrofit replacement may occur before the original ballast h

Rulemaking Analyses: Shipments Analysis
62

Issues for Comment

Issue 10‐1: Data Sources for ShipmentsDOE welcomes recommendations on sources of data that would 

information on shipments of fluorescent lamp ballasts by produc

addition, DOE welcomes comment or recommendations on how characterize long‐term trends in efficiency of fluorescent lamp ba

the no‐new‐standards case shipments projection.

Issue 10‐2: Accounting MethodologyDOE welcomes comment on the accounting methodology describ

Framework document for each of the fluorescent lamp ballasts u

consideration for standards in this rulemaking.
63

Issues for Comment

Issue 10‐3: Standards Affecting ShipmentsDOE welcomes comment on how any potential new or amended 

conservation standards for fluorescent lamp ballasts might affect 

of these ballasts. DOE also invites information about market‐pull 

that currently exist to promote the adoption of more‐efficient ba
64

Rulemaking Analyses: National Impact Analysi• Purpose:

‒ Determine the projected national impacts of an amended s

in the form of NES and NPV

• Method:

‒ Develop annual series of national energy and economic im

• Use LCC outputs to provide input about installed costs and energ

unit

• Use the shipments model to estimate annual shipments and stoc

– Aggregate the costs and energy use for all years in the anal

– Report NES in primary and full‐fuel‐cycle (FFC) savings and 

billions of dollars

– Account for the time‐value of money though defined disco
65

Rulemaking Analyses: National Impact Analysi

• Inputs for calculating NPV:

- Installed and operating costs of all products for each year o

analysis period

- Projected shipments- Electricity price projections

- HVAC interaction savings

- Discount rates (3 percent and 7 percent)

- Rebound effect
66

Issues for Comment

Issue 11‐1: Data Sources for NIADOE welcomes on the data sources it anticipates using to develop 

the national impact analysis.

Issue 11‐2: NIA modelDOE welcomes comments on the NIA spreadsheet models it plan

estimating national impacts of energy conservation standards for 

lamp ballasts.
67

Presentation Overview

1 Overview; Scope of Coverage2 Market and Technology; Screening Analysis3 Engineering Analysis4 Energy Use; Markups Analysis5 Life-Cycle Cost Analysis; Payback Period Analys6 Shipments; National Impact Analysis7 NOPR Analyses
68

Manufacturer Impact Analysis• Purpose of the manufacturer impact analysis (MIA) i

– Assess the impacts of standards on manufacturers;

– Identify and estimate impacts on manufacturer subgroups 

be more severely affected than the industry as a whole; an

– Examine the direct employment impacts, manufacturing ca

and cumulative regulatory impact on the manufacturing in

• Proposed Methodology:

– Analyze industry cash flow and industry net present value (

through use of the Government Regulatory Impact Model (

and

– Interview manufacturers to refine inputs to the GRIM, deve

group analyses, and address qualitative issues.
69

MIA MethodologyThe MIA consists of three main phases:

Industryprofile

DevelopstrawmanGRIM

Developinterviewguide

Interviews&industry‐wide /subgroupanalyses

Phase 2 Phase 3

Initial MIAInterviews

Phase 1

PreliminaryAnalysis

NOPR
70

Other NOPR Analyses• Consumer Subgroup Analysis

– Effects on various national consumer subgroups

• Utility Impact Analysis

– Effects on generation capacity of utilities

• Employment Impact Analysis

– Indirect impacts on overall national employment

• Emissions Analysis

– Effects on airborne pollutant emissions

• Monetizing Carbon Dioxide and Other Emissions Red

– Monetary benefits from emissions reductions

• Regulatory Impact Analysis

– Potential for non‐regulatory alternatives
71

Issues for Comment

Issue 12‐1: Consumer Subgroup AnalysisDOE welcomes comment on what, if any, consumer subgroups ar

appropriate in considering standards for fluorescent lamp ballast

Issue 14‐1: Utility Impact AnalysisDOE welcomes input from interested parties on its plans to use N

conduct the utility impact analysis.

Issue 15‐1: Employment Impact AnalysisDOE welcomes feedback on its planned approach for assessing n

employment impacts, both direct and indirect.
72

Issues for Comment

Issue 16‐1: Emissions AnalysisDOE seeks comment on its approach to conduct the emissions an

the products that would be under consideration for standards in 

rulemaking.

Issue 17‐1: Monetization of EmissionsDOE requests comment about the approach it plans to use for es

monetary benefits associated with emissions reductions.
73

Closing Remarks

Meeting participants are invited to provide closiremarks or statements at this time.
74

In all correspondence, please refer to the Fluorescent Lamp Ballas

rulemaking by:

– Framework Document for Fluorescent Lamp Ballasts

– Docket Number EERE‐2015‐BT‐STD‐0006

– Regulation Identification Number (RIN) 1904‐AD51

Email: FluorLampBallasts2015STD0006@ee.doe.govWeb: www.regulations.govPostal: Courier:Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies PrograMailstop EE‐5B 950 L’Enfant Plaza SW, Suite 61000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes August 7, 2015

How to Submit Written Comments