Friday December 19, 2008Washington, DChttp://www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_lamp_ballasts.htmlMetal Halide Lamp BallastsTest Procedure NOPR Public MeetingBuilding Technologies ProgramOffice of Energy Efficiency and Renewable EnergyU.S. Department of Energy2Welcome• Introductions• Role of the Facilitator• Ground Rules (norms)– Listen as an ally– Use short, succinct statements/keep to the point– Hold sidebar conversations outside the room– Focus on issues, not personalities– One person speak at a time (raise hand to be recognized; state yourname for the record)– Set cell phones to silent/vibrate• Housekeeping Items• Agenda Review• Opening Remarks39:00 – 9:30 amWelcome, Introductions, Opening Statements9:30 – 10:20 amStatute and Context10:20 – 11:00 amProposed Ballast Efficiency Test Method11:00 – 11:15 amBreak11:15 – 12:00 pmStandby and Off Mode Test Method12:00 – 12:15 pmReporting Requirements12:15 – 12:30 pmConclusion and Closing Remarks12:30 pmAdjournAgenda4•Review statute and DOE actions for metal halide (MH) ballasts• Test procedure based on ANSI C82.6-2005• Standby and off-mode•Present DOE’s proposed test procedure and reporting requirements•Clarify any questions about the proposal•Seek comment from participants on the test procedure•Discuss next steps for the rulemakingPurpose of the Public Meeting5Issues for CommentIssue BoxDOE welcomes comments, data, and informationconcerning the proposed MH lampballast test procedure.Throughout this presentation issues that correspond to issues fromthe NOPR will be raised for discussion in boxes like this one. Theissue box number corresponds to the numbered issue in Section IV ofthe NOPR. Nonetheless, comments are welcome on any part ofDOE’s proposal.6234Background and Legal AuthorityPublic Meeting Agenda5Proposed Ballast Efficiency Test Method2Standby and Off Mode Test Method341Statute and Context5Reporting RequirementsClosing Remarks7Metal Halide Lamp Ballast Test Procedure•Section 324(c) of the Energy Independence and Security Act of 2007(EISA 2007) amended EPCA to require that DOE establish testprocedures for metal halide lamp ballasts:“(18) METAL HALIDE LAMP BALLASTS. – Test procedures for metalhalide lamp ballasts shall bebased on ANSI Standard C82.6–2005,entitled ‘Ballasts for High-Intensity Discharge Lamps—Method ofMeasurement’.” (42 U.S.C. 6293(b)(18))Statute and Context8Minimum Ballast Efficiency Standards for MH LampFixtures Effective January 1, 20091MH Ballast Type150W≤Lamp≤500WMinimumBallast EfficiencyPulse-start88%Magnetic Probe-start94%Nonpulse-start electronic≤250 Watts90%Nonpulse-start electronic > 250 Watts92%1Section 324(e) of EISA2007 amended section 325 of EPCA toprescribe minimum efficiency levels for certain MH ballastsincorporated into MH lamp fixtures. (42 U.S.C. 6295(hh)(1)(A))Statute and Context9Standards for Ballast Efficiency for Metal HalideLamp Fixtures Effective January 1, 200911Section 324(e) of EISA2007 amended section 325 of EPCA toprescribe minimum efficiency levels for certain MH ballastsincorporated into MH lamp fixtures. (42 U.S.C. 6295(hh)(1)(A))Exempted fixtures:1. Fixtures with regulated-lag ballasts,2. Fixtures that use electronic ballasts that operate at 480V; or3. Fixtures that:i. are rated only for 150 watt lamps;ii. are rated for use in wet locations, as specified by the National ElectricalCode 2002, section 410.4(A); andiii. contain a ballast that is rated tooperate at ambient air temperaturesabove 50°C, as specified by UL 1029-2001.Statute and Context10MH Lamp Ballast Test Procedure ScheduleDec.2008Dec. 5, 2008Ballasts TPNOPR Issued75 Day Comment PeriodStarting with publication in the FederalRegisterJune 30, 2009Metal Halide BallastsTest ProcedureFinal RuleFeb.2009Mar.2009Apr.2009May2009Jan.2009Statute and ContextJun.200911234Background and Legal AuthorityPublic Meeting Agenda5Proposed Ballast Efficiency Test Method2Standby and Off Mode Test Method341Statute and Context5Reporting RequirementsClosing Remarks12Proposed MH Ballast Efficiency Test ProcedureBallast Efficiency Test ProcedureOverview(a) Lamp Orientation1. Test Setup and Conditions(b) Power Supply, Ambient TestTemperatures, and Instrumentation2. Test Measurements / Calculation(c) Lamp Stabilization13Lamp Orientation1. Lamp orientation – vertical, base-up orientationDOE proposes lamp orientation for testing as specified in section4.3 of ANSI Standard C82.6-2005– Most common in the industry– Most stable lamp operation leading to most repeatable and accurateresults2. Lamp orientation – horizontalANSI Standard C82.6-2005 references section 3.6 of ANSI StandardC78.389-2004, “Lamp Position”– Addressed in ANSI Standards, but does not lead to accurate andrepeatable resultsDOE is proposing to test in a vertical, base-up orientation.Proposed Test ProcedureBallast Efficiency Test Method14Request for CommentItem 4The Department invites comment on the appropriateness of thelamp orientation requirements as specified in section 4.3 of ANSIStandard C82.6-2005 that require vertical base up unless themanufacturer specifies another orientation for that ballast andassociated lamp combination. The Department also seeks comment onwhether a preferred lamp orientation approach existswithin the industryfor lamp ballast testing. See section III.C.1. in the NOPR foradiscussion for the proposed lamp orientation requirements.Ballast Efficiency Test Method15Proposed MH Ballast Efficiency Test Procedure(a) Lamp Orientation1. Test Setup and Conditions(b) Power Supply, Ambient TestTemperatures, and Instrumentation2. Test Measurements / Calculation(c) Lamp StabilizationBallast Efficiency Test Method16Power SupplyDOE proposes power supply characteristics as specified in section 4.1 ofANSI Standard C82.6-2005Section 4.1 of ANSI Standard C82.6-2005 requires:1. The Root Mean Square (RMS) summation of harmonic components in thepower supply be no more 3% of the fundamental voltage and frequencycomponents2. Impedance of the power source be no more than 3% of the specified ballastimpedance3. Power supply devices used in the test circuits have a power rating at least 5xthe wattage of the lamp intended to operate on the ballast under testProposed Test ProcedureBallast Efficiency Test Method17Proposed Test ProcedureAmbient Test TemperatureDOE proposes power supply characteristics as specified in section 4.2of ANSI Standard C82.6-2005Section 4.2 in ANSI Standard C82.6-2005 requires:1. Maintenance of an ambient temperature of 25° ± 5° Cto reduce potentialballast operating variances caused by excessive temperatureDOE further proposes tests be conducted in a draft-free environmentBallast Efficiency Test Method18Request for CommentItem 1The Department invites comment and data on the applicability ofthe proposed ambient test temperature requirements, based on section4.2 in ANSI Standard C82.6-2005. In particular, DOE is interested incomment on whether a different set of ambient test conditions might bemore appropriate for metal halide ballast testing. See section III.C.1inthe NOPRfor a discussion of the proposed ambient temperatureconditions.Ballast Efficiency Test Method19Proposed Test ProcedureInstrumentation (Digital)DOE proposes using the instrumentation prescribed in sections 4.5.1and 4.5.3 of ANSI Standard C82.6-2005ANSI requirements for digital voltmeters, ammeters, and wattmeters:1. Resolution of three and one-half digits2. Minimum accuracy of 0.50% of the reading from actual with true RMScapabilityBallast Efficiency Test Method20Proposed Test ProcedureInstrumentation (Analog)DOE proposes using the instrumentation prescribed in sections 4.5.1and 4.5.3 of ANSI Standard C82.6-2005Analog ammeters and voltmeters:1. ± 0.50% up to 800 HertzAnalog wattmeters:1. ± 0.75% up to 1000 Hertz for ballasts with power factors 50% - 100%2. ± 0.50% up to 125 Hertz for ballasts with power factors 0% - 20%DOE proposes to require all analog wattmeters used on ballasts with powerfactors less than 50% to same accuracy as those for ballasts with powerfactors less than 20% (i.e., ±0.50 percent up to 125 Hertz).Ballast Efficiency Test Method21Request for CommentItem 2The Department invites comment and data on the applicability ofthe proposed instrumentation requirements for power supplies,wattmeters, voltmeters, and ammeters required for testing, based on therequirements in section 4.0 of ANSI Standard C82.6-2005. See sectionIII.C.1 in the NOPR for a discussion of the instrumentation requirements.DOE especially invites comment on the issue of the applicability of theproposed measurement accuracy ±0.50 percent up to 125 Hertz forballasts with power factors between 20 and 50 percent, because ANSIStandard C92.6-2005 does not provide an accuracy value for theproposed instrumentation for these power factors. See section III.C.1 inthe NOPR for a discussion of the proposed instrumentationrequirements.Ballast Efficiency Test Method22Proposed Test ProcedureCircuit ConnectionDOE proposes that only one analog instrument may be connected to thetest circuit at one time to reduce impedance effects on the testingDOE believes that all these instrumentation requirements, as set forth in ANSIStandard C86.5-2005, would facilitaterepeatable and consistent testingand measurement.Ballast Efficiency Test Method23Request for CommentItem 3The Department invites comment on the applicability of theproposed test circuit connection requirements, based on sections 4.5and 6.10 of ANSI Standard C82.6-2005. See section III.C.1in the NOPRfor a discussion of the proposed test circuit connections.Ballast Efficiency Test Method24Proposed MH Ballast Efficiency Test Procedure(a) Lamp Orientation1. Test Setup and Conditions(b) Power Supply, Ambient TestTemperatures, and Instrumentation2. Test Measurement / Calculation(c) Lamp StabilizationBallast Efficiency Test Method25Proposed Test ProcedureLamp StabilizationDOE proposes the process for lamp stabilization that would follow section4.4 of ANSI Standard C82.6-2005.4.4.1 The lamps used for ballast measurements, shall unless otherwise specified,have been seasoned a minimum of 100 hoursprior to their use in the ballasttests.Ballast Efficiency Test Method26Proposed Test ProcedureLamp Stabilization4.4.2 Basic stabilization method:• Operate lamp ±3% of rated wattage in an ambient temperature of 25°C ±5°C until electrical parameters of the lamp cease to change• Lamp burning time required to achieve stabilization is a minimum of 30minutes – could be 6 hours or more for MH lamps• Standby ballast recommended to warm up the lamp to prevent moving thelamp• Once the lamp has been transferred to the test ballast circuit, restabilization time is important– to avoid test ballast heat-up,measurements should be taken within 5 minutes after re-stabilizationBallast Efficiency Test Method27Proposed Test ProcedureLamp Stabilization per ANSI Standard C82.6-20054.4.3 Alternative Stabilization Method:• In some cases, such as low frequency electronic ballasts, the transferfrom the reference ballast to the ballast under test is undefined, thefollowing alternative method should be followed to ensure testing resultreproducibility:• Lamp characteristics should be determined with a reference ballast andrecorded for future comparison• The same lamp will be driven by the ballast under test for 15 minutes.• The electrical measurements should be taken within 2 minutes after the15-minute stabilization period.Ballast Efficiency Test Method28Request for CommentItem 5The Department invites comment and data on the applicability ofthe proposed lamp seasoning and system stabilization requirements thatfollow the ANSI Standard C82.6-2005 requirement for a 100-hourseasoning period and the stabilization method in either section 4.4.2 or4.4.3 of ANSI Standard C82.6-2005,with additional methods from ANSIStandard C78.389-2004.DOE is particularly interested in whether a preferred lamp seasoning orlamp stabilization approach exists within the industry. See section III.C.1in the NOPR fora discussion of the proposed lamp seasoning andsystem stabilization conditions.Ballast Efficiency Test Method29Proposed MH Ballast Efficiency Test Procedure(a) Lamp Orientation1. Test Setup and Conditions(b) Power Supply, Ambient TestTemperatures, and Instrumentation2. Test Measurement / Calculation(c) Lamp StabilizationBallast Efficiency Test Method30Proposed Test ProcedureCalculation:1. EISA defines Ballast Efficiency1as:• Measured output power to the lamp divided by the measured input power(Pout/Pin).DOE proposes that the ballast efficiency be calculated as the measuredoutput power to the lamp divided bythe measured input power to theballast (Pout/Pin)Test measurements for metal halide ballasts would require that ballast operatingtesting be conducted according to the same requirements as set forth insection 6.10, “Ballast Power Loss,” of ANSI Standard 82.6-2005.1(42 U.S.C. 6295(hh)(1))Ballast Efficiency Test Method31Request for CommentItem 6The Department invites comment and data on the applicability ofthe proposed measurement of ballastpower losses in accordance withsection 6.10 of ANSI Standard C82.6-2005, which requires the use of atrue RMS wattmeter with basic accuracy of 0.50 percent. DOE isparticularly interested in whether a preferred ballast power-lossmeasurement approach exists within the industry for metal halide lamps.See section III.C.2in the NOPRfor a discussion of the proposed testingmeasurements.Ballast Efficiency Test Method32234Background and Legal AuthorityPublic Meeting Agenda5Proposed Ballast Efficiency Test Method2Standby and Off Mode Test Method341Statute and Context5Reporting RequirementsClosing Remarks33Overview•EPCA, in relevant part, directs DOE to establish test procedures toinclude standby mode, “taking into consideration the most currentversions of Standards 62301 and 62087 of the InternationalElectrotechnical Commission”1– IEC Standard 62087 applies to audio,video, and related equipment, butnot to lighting equipment – thus not suitable to this rulemaking– DOE developed proposed rule consistent with procedures outlined in IECStandard 62301 & reference languagefrom ANSI Standard C82.6-2005• EPCA defines three types of modes covering the various operating conditionsof an energy-using product. The three modes are:1. Active Mode2. Standby Mode3. Off ModeStandby and Off Mode1(42 U.S.C. 6295(gg)(2)(A))34EPCA Defines “Active Mode”1Active Mode is:• The condition in which an energy-using product -1. is connected to a main power source;2. has been activated; and3. provides 1 or more main functions.• When the MH ballast is operating the lamp, the ballast is in active mode. Theballast efficiency measure part of this test procedure covers this type of mode.1EPCA (42 U.S.C. 6295(gg)(1)(A)(i))Standby and Off Mode35EPCA defines “Standby Mode”1• “Standby mode”is:“the condition in which an energy-using product(1) is connected to a main power source; and(2) offers one or more of the following user-oriented or protectivefunctions:(aa) to facilitate the activation or deactivation of other functions(including active mode) by remote switch (including remotecontrol), internal sensor, or timer;(bb) continuous functions, including information or statusdisplays (including clocks) or sensor-based functions.”1(42 U.S.C. 6295(gg)(1)(A)(iii))Standby and Off Mode36Standby ModeApplicability of “Standby mode”to MH ballasts:• The definition requires that ballasts be connected to their main powersource; since most ballasts operated with on-off switches, circuitbreakers, or other relays that disconnect the ballast from the main powersource which precludes the majority of ballasts from having stand-byenergy consumption.• The vast majority of ballasts do not consume energy when they areswitched off.•DOE interprets this condition as applying to ballasts that aredesigned to operate in, or function as, a lighting control systemwhere auxiliary control devices send signals.Standby and Off Mode37EPCA defines “Off Mode”1• “Off mode”is:“the condition in which an energy-using product(1) is connected to a main power source; and(2) is not providing any standby or active mode function.”• DOE considered this definition in the context of metal halide ballasts andbelieves that off mode does not apply to any metal halide ballast, dimmable ornon-dimmable, because off mode describes a condition that commerciallyavailable ballasts do not attain.1(42 U.S.C. 6295 (gg)(1)(A)(ii))Standby and Off Mode38Request for CommentItem 7The Department invites comment on its approach for assessingmetal halide ballast operation in active mode, standby mode, and offmode, as those terms are defined in EPCA. In particular, DOE invitescomment on its tentative conclusionthat off mode does not apply tometal halide lamp ballasts at this time, and, therefore, should not beincluded as part of this proposed test procedure. See section III.Bof theNOPRfor a discussion of off mode.Standby and Off Mode39Test Method and MeasurementsThe Department’s proposed test procedure for measuring standby power consistsof the following steps:1. A signal is sent to the ballast instructing it to reduce light output to zeropercent;2. The main input power to ballast is measured;3. The power from the control signal path is measuredStandby and Off Mode40Measurement: Input Power• The measurement of input power to the ballast from the main electricitysupply during standby mode is basedon the approach in ANSI StandardC82.6-2005, section 6.• This measurement parallels the approach DOE is proposing formeasuring the active mode power consumption for input power (watts) tothe ballast in accordance with ANSI Standard C82.6-2005.• Thus the test measurements of ballast input power would be required tobe conducted in accordance with the appropriate sections of the currentindustry test method.Standby and Off Mode41Measurement: Ballast’s Control Signal Power• As proposed at 10 CFR 431.324(c), the proposed test procedure would directmanufacturers to address measurement of the ballast’s control signal power.• As DOE understands it, there are four possible ways to deliver a controlsignal to a metal halide lamp ballast:1. a dedicated AC control signal wire:2. a dedicated DC control signal wire:3. a PLC control signal over the main supply input wires;4. a wireless control signal• DOE estimates that the power supplied to a ballast using a wirelesssignal would be very small (well below 1.0 watt) – making it hard tomeasure and unlikely to appreciably impact ballast powerconsumptionStandby and Off Mode42Proposed Definitions for Control Signals• DOE proposes to define “AC control signal”as:“an alternating current (AC) signal that is supplied to the ballast usingadditional wiring for the purpose ofcontrolling the ballast and putting theballast in standby mode”• DOE proposes to define “DC control signal”as:“a direct current (DC) signal that is supplied to the ballast using additionalwiring for the purpose of controlling theballast and putting the ballast instandby mode”Standby and Off Mode43Proposed Definitions for Control Signals• DOE proposes to define “PLC control signal”as:“a power line carrier (PLC) signal thatis supplied to the ballast using theinput ballast wiring for the purpose of controlling the ballast and puttingthe ballast in standby mode.• DOE proposes to define “Wireless control signal”as:“a wireless signal that is radiated to and received by the ballast for thepurpose of controlling the ballastand putting the ballast in standbymode.”Standby and Off Mode44Proposed Test Setup for Measuring Standby Powerof Metal Halide Ballasts with AC control signalStandby and Off Mode45Proposed Test Setup for Measuring Standby Powerof Metal Halide Ballasts with DC control signalStandby and Off-Mode46Proposed Test Setup for Measuring Standby Power ofMetal Halide Ballasts with PLC control signalStandby and Off-Mode47Request for CommentItem 8The Department invites comment on its approach to apply thestandby mode provisions of this test procedure to all metal halide lampballasts that incorporate some form of electronic circuit that enables theballast to communicate with and be part of a lighting control system.Although all metal halide ballasts would be subject to the test proceduregenerally, only these types would be subject to the test procedure’sstandby mode power consumption provisions. See section III.Eof theNOPRfor a discussion of the proposed scope of the test procedure’sstandby power provisions.Standby and Off-Mode48Request for CommentItem 10The Department invites comment on its proposed test methodand measurements for metal halide ballasts, which provide the step-bystep procedure and circuit diagrams necessary for measuring the power(in watts) consumed by the main power input to the ballast, and thecontrol signal wire (if any). See sections III.C and Dof the NOPRfor adiscussion of the proposed circuit diagrams.Standby and Off-Mode49Combining Measurements and Burden• DOE proposes that the test procedure would direct manufacturers to take tworequired measurements:1. The main input power2. Control signal power in standby mode• The proposed test procedure does not tell manufacturers how to combinethese values or use them in equations pertaining to energy efficiency• DOE intends to study how best to use these measurements of standbymode power consumption in a separate rulemaking to review andpossibly amend the energy conservation standards for metal halide lampballasts, which DOE is required to complete by January 1, 2012, pursuantto EISA 2007.Standby and Off-Mode50Combining Measurements and Burden• DOE notes that the proposed test procedure is designed to produce resultsthat measure standby power in an accurate and repeatable manner, andshould not be unduly burdensome on manufacturers to conduct.• DOE believes that these objectives would be met by the proposed testprocedure, particularly given that it is based upon IEC Standard 62301 andfollows testing approaches used in ANSI Standard C82.6-2005.Standby and Off-Mode51234Background and Legal AuthorityPublic Meeting Agenda5Proposed Ballast Efficiency Test Method2Standby and Off Mode Test Method341Statute and Context5Reporting RequirementsClosing Remarks52Units to be Tested: Sample Size• DOE considered 4 factors in developing sample sizerequirements:1. providing a highly statistically valid probability that a basic modelthat is tested meets applicable energy conservation standards;2. providing a highly statistically valid probability that a manufacturerpreliminarily found to be in noncompliance will actually be innoncompliance3. assuring compatibility with other sampling plans DOE haspromulgated; and4. minimizing manufacturers’ testing time and costs.Reporting Requirements53DOE Proposes a Definition for “Basic Model”• DOE proposes a definition for “basic model”:“with respect to metal halide ballasts,all units of a given type of metalhalide ballast (or class thereof) that:(1) are rated to operate a given lamp type and wattage;(2) have essentially identical electrical characteristics; and(3) have no differing electrical, physical, or functional characteristicsthat affect energy consumption.”Reporting Requirements54Request for CommentItem 9The Department invites comment on its definition for thefollowing eight terms that DOE is proposing to add to 10 CFR par 431;AC control signal, active mode, basic model, DC control signal, offmode, PLC control signal, standby mode, and wireless control signal.See section III.B for a discussion of the proposed definitions.Reporting Requirements55Units to be Tested: Sample Size• DOE considered 3 alternatives for the specification of test sample size formetal halide ballast equipment:1. test every unit to determine with 100% certainty that each onecomplies with statute;2. test a predetermined number of units to yield a high level ofstatistical confidence; and3. test until a determination can be made that a basic model does, ordoes not comply.Reporting Requirements56Units to be Tested: Sampling Procedure• DOE proposes randomly selecting and testing a sample of production(not fewer than four) of a representative model:• a simple average of values would be calculated – becoming theactual mean value of the sample• For each representative model, a sample of sufficient size, no less thanfour, would be selected at random and tested to ensure that thecalculated value of energy efficiency is no less than:1. the lower of the mean of the sample; or2. the lower 99% confidence limit of the mean of the entire populationof that basic model, divided by a coefficient applicable to therepresented value.Reporting Requirements57Request for CommentItem 11The Department invites comment and data on the accuracyand applicability of the proposed sampling for metal halide ballasts. TheDepartment seeks comment on whether an alternative sampling methodexists that might be moreappropriate for metal halide ballasts. Seesection III.G of the NOPRfor a discussion of the proposed sampling sizemethod.Reporting Requirements58Submission of Data• DOE proposes that the manufacturer, or other entity conducting tests onbehalf of the manufacturer, provide a certification report for each basicmodel which includes the following information :1. the equipment type;2. manufacturer’s name;3. private labeler’s name(s) (if applicable); and4. manufacturer’s model number(s).• The report would be required to certify that the testing was completed inaccordance with the applicable test requirements prescribed in 42 U.S.C.6293(b) of EPCA, as amended.Reporting Requirements59Request for CommentItem 12The Department invites comment on the potential impact ofapplying data requirements described in other DOE test procedures forproducts and equipment subject to energy conservation standards as itapplies to metal halide ballasts. DOE seeks comment on whether analternative set of submission requirements exists thatmight be moreappropriate for metal halide ballasts. See section III.H of the NOPR for adiscussion of the proposed submission of data requirements.Reporting Requirements60Enforcement Provisions• Once a Federal energy conservation standard becomes effective formetal halide ballasts, the enforcement of the appropriate application ofthe testing procedure for this equipment would be subject to enforcementof the efficiency requirements and verification of the documented testing.• DOE proposes to apply to metal halide ballasts the same basicrequirements for enforcement currently in place for other lightingequipment.• DOE will review the testing certification.Reporting Requirements61Enforcement Provisions• If DOE receives written information about the performance ofmetal halide ballasts indicating that one or more basic modelsmay not be in compliance with the energy conservation standard,DOE may conduct independent testing of those basic models.• The results of this testing would serve as the basis for anyenforcement actions related tothe application of these metalhalide ballast test procedures.Reporting Requirements62Request for CommentItem 13The Department invites comment on the potential impact ofapplying the enforcement provisions described in other DOE testprocedures for products and equipment subject to energy conservationstandards as they apply to metal halide ballasts. See sectionIII.I of theNOPR for discussion of the proposed enforcement provisions.Reporting Requirements63234Background and Legal AuthorityPublic Meeting Agenda5Proposed Ballast Efficiency Test Method2Standby and Off Mode Test Method341Statute and Context5Reporting RequirementsClosing Remarks64In all correspondence, include all of the following:– Test Procedures for Metal Halide Lamp Ballasts– Docket NumberEERE-2008-BT-TP-001– Regulatory Identification Number(RIN) 1904-AB87Email:Metal_Halide_Ballasts.Rulemaking@hq.doe.govComment period closes: 75 days after publication in the Federal RegisterDOE Seeks Comments on its ProposalPostal Mail:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program,Mailstop EE-2J1000 Independence Avenue, SWWashington, DC 20585-0121Courier:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, S.W., 6thFloorWashington, DC 20024Telephone: (202) 586-2945Closing Remarks