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Public Meeting for Energy Conservation Standards for 

Fluorescent Lamp Ballasts 

February 6, 2008 – Washington, DC 

Issues for Stakeholder Comment 

The U.S. Department of Energy (DOE) published a document on its website in conjunction with 

this public meeting: Energy Conservation Standards Rulemaking Framework Document for 

Fluorescent Lamp Ballasts. While DOE invites comments from stakeholders on all aspects of the 

material presented in this document, there are several issues in particular on which DOE seeks 

comment and they are identified in issue boxes. 

The list of issues is reproduced below, grouped according to the session today at which they will 

be discussed. Within those groupings, the issues are numbered according to their appearance in 

the framework document. Un-numbered items do not appear in the Framework Document. 

1. Introduction 

Item 1 DOE welcomes comment on the scope of this rulemaking, which implements the 

statutory requirement to consider additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) 

2. Test Procedure 

Item 2 DOE welcomes comment on the standby power provisions from EISA 2007 and issues arising 

therefrom, including: (a) How DOE should modify its test procedure for fluorescent lamp ballasts; (b) 

Which covered fluorescent lamp ballasts are subject to standby mode and off mode energy use?; and (c) 

How DOE should take standby mode and off mode energy consumption into its analysis for the energy 

conservation standard? 

Item 3 DOE welcomes comment on the issue of updating the fluorescent lamp ballast test procedure. 

DOE also invites comment on whether it should update the test procedure to include the industry 

standards ANSI C82.2-2002, C82.1-2004, C82.11-2002 or any additional procedures that should be 

considered in its test procedure rulemaking for fluorescent lamp ballasts. 

Item 4 DOE welcomes comment on the two different ANSI methods used to calculate ballast factor for 

rapid-start and instant-start ballasts. If the two methods are not comparable, DOE invites comment on 

any conversion factors necessary to make them comparable. Finally, DOE invites comment on whether 

manufacturers report the ballast factor for instant-start ballasts in their literature using the ANSI or DOE 

test procedure. 

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Item 5 DOE also welcomes comment on ballast factor calculation methods used for programmed-start 

ballasts, modified rapid-start ballasts and other types of fluorescent lamp ballasts not covered by ANSI 

C82.2-2002 

DOE welcomes comment on how to test fluorescent lamp ballasts when operating lamps that are not part 

of ANSI C78.81. 

3. Energy Conservation Standards 

[No Issues] 

4. ANOPR Analyses 

Market and Technology Assessment 

Item 6 DOE welcomes input on shipments, manufacturing costs, product-feature and efficiency trends, 

distribution channels, and estimates of market shares for the fluorescent lamp ballasts covered in this 

rulemaking. For DOE to be able to use the data to conduct energy savings calculations, a degree of 

disaggregation (e.g. by product class) is desirable. 

Item 7 DOE is seeking stakeholder comment and data on potential market failures that could apply to 

fluorescent lamp ballasts. 

Item 8 DOE welcomes comment on product classes for fluorescent lamp ballasts and approaches to 

defining classes in accordance with the requirements of 42 U.S.C. 6295(q). 

Item 9 DOE welcomes comment on the preliminary technology options identified in this section. DOE 

welcomes comment on whether there are other technology options that it should also consider. In 

commenting on design options, please discuss their impacts on safety, performance, and consumer 

utility (if any). 

Screening Analysis 

Item 10 DOE welcomes comment on how the four screening criteria might apply to any additional 

technology design option(s) that a stakeholder recommends to DOE. 

Engineering Analysis 

Item 11 DOE welcomes comment on representative product classes and selection of baseline 

models from those representative product classes 

Item 14 DOE welcomes comment on how BEF varies with lamp wattage. 

Item 12 DOE welcomes comment on the scaling of findings from representative product classes 

to other product classes that DOE may not analyze. 

Item 13 DOE welcomes comment on commercially-available fluorescent lamp ballasts for each 

of the baseline models with incrementally increasing BEF, all the way to the max tech ballast. 

DOE welcomes comment on the proposed approach to the engineering analysis. 

Item 15 Are there proprietary designs of which DOE should be aware for any of the fluorescent 

lamp ballasts under consideration in this rulemaking? If so, how should DOE acquire the cost 

data necessary for evaluating these designs? 

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Item 16 DOE welcomes comment on regulatory burdens or changes that should be considered in 

the engineering analysis of fluorescent lamp ballasts. 

Item 17 DOE welcomes comment on any other engineering issues that could impact the 

engineering analyis. 

Product Price Determination 

Item 19 DOE welcomes comment on final end-user prices for high-range, medium-range, and 

low-range fluorescent ballasts. 

Item 20 DOE welcomes comment on typical contractor and distributor markups associated with 

the purchase and installation of fluorescent lamp ballasts. 

Preliminary Manufacturer Impact Analysis 

[No Issues] 

Energy Use & End Use Load Characterization 

Item 18 DOE welcomes comment on the use of the planned operating hour profile for 

fluorescent lamp ballasts in this rule. Furthermore, DOE welcomes comment on whether the 

end-use operating profiles are different for the various types of fluorescent lamp ballasts covered 

under this rulemaking, and if so, how. 

Life-Cycle Cost and Payback Period Analysis 

Item 21 DOE welcomes input on the electricity prices used in this analysis. 

Item 23 DOE welcomes comment on how to develop installation, maintenance, and (if applicable) 

repair costs for fluorescent lamp ballasts. In particular, will fluorescent lamp ballast energy 

conservation standards affect the useful lifetime of the ballasts and/or the fluorescent lamps operated by 

those ballasts? If the lamps operated by the more efficient ballasts would be impacted, then DOE invites 

stakeholder comment on whether re-lamping practices (i.e., group re-lamping and spot re-lamping) 

would change as a result of the standard. 

Item 24 DOE welcomes comment on appropriate fluorescent lamp ballast lifetimes for the ballasts 

covered in this rulemaking. 

Item 22 DOE welcomes input on the planned approaches for estimating discount rates for consumers of 

fluorescent lamp ballasts covered under this rulemaking. 

Shipments Analysis 

DOE welcomes input on these two approaches or others for estimating fluorescent lamp ballast 

shipments. 

Item 25 DOE welcomes recommendations on the sources of data that would provide information 

on shipments of fluorescent lamp ballasts by product class and BEF distributions within those 

product classes. In addition, DOE welcomes comment or recommendations on how it might 

characterize long-term trends in efficiency of fluorescent lamp ballasts for the base-case 

shipments forecast. 

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Item 26 DOE welcomes comment on the accounting methodology for each of the fluorescent 

lamp ballasts covered in this rulemaking. 

DOE welcomes comment on the breakdown of fluorescent lamp ballast shipments by market 

segment and sector. 

Item 27 DOE welcomes comment on how any new energy conservation standard for fluorescent 

lamp ballasts might impact shipments of these ballasts. DOE also invites information about 

market-pull programs that promote the adoption of more-efficacious ballasts. 

National Impact Analysis 

Item 28 DOE welcomes comment on the data sources it anticipates using to develop inputs for 

the national impact analysis. 

Item 29 DOE welcomes comment on the NES spreadsheet models it proposes to use for 

estimating national impacts of energy conservation standards for fluorescent lamp ballasts. 

5. NOPR Analysis 

Life-Cycle Cost Subgroup Analysis 

Item 30 The Department welcomes comment on what, if any, consumer subgroups are 

appropriate in considering standards for fluorescent lamps ballasts. 

Manufacturer Impact Analysis 

Item 31 If appropriate, what are potential subgroups of fluorescent lamp ballast manufacturers 

that DOE should consider in a manufacturer subgroup analysis? 

Item 32 DOE welcomes comment on what other regulations or pending regulations it should 

consider in its examination of cumulative regulatory burden. 

Utility Impact Analysis 

Item 33 The Department welcomes input from stakeholders on its plans to use NEMS-BT to 

conduct the utility impact analysis. 

Employment Impact Analysis 

Item 34 The Department welcomes feedback on its proposed approach to assessing national 

employment impacts, both direct and indirect. 

Environmental Assessment 

Item 35 DOE welcomes feedback on its planned approach to assessing national environmental 

impacts, including other factors or approaches that should be considered. 

Regulatory Impact Analysis 

[No Issues] 

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6. Closing Remarks 

[No Issues] 

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