CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1
 

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM......................................................................................................... 1-1
 

1.3 OVERVIEW OF FLUORESCENT LAMP BALLAST STANDARDS......................... 1-2
 

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-4
 

1.5 STRUCTURE OF THE DOCUMENT............................................................................ 1-6
 

LIST OF TABLES 

Table 1.4.1 Analyses Under the Process Rule ............................................................................ 1-5
 

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CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

This preliminary technical support document (TSD) provides the analytical approaches, 

inputs and results associated with the U.S. Department of Energy’s (DOE’s) study of energy 

conservation standards for fluorescent lamp ballasts. The preliminary TSD also serves to provide 

technical detail and is a compendium to the life-cycle cost (LCC) and payback period (PBP) and 

national impact analysis (NIA) spreadsheets that are posted on the DOE’s website for the 

preliminary analysis.a 

1.2	 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM 

Part B of Title III of the Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 

6291–6309) established the energy conservation program for consumer products other than 

automobiles, covering major household appliances. Additional amendments to EPCA have 

given the U.S. Department of Energy the authority to regulate the energy efficiency of several 

products, including certain fluorescent lamp ballasts, the products that are the focus of this 

document. 

Before DOE determines whether to adopt a proposed energy conservation standard, it 

first solicits comments on the proposed standard. DOE designs any new or amended standard to 

achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A)) To determine whether economic justification 

exists, DOE must review comments on the proposal and determine that the benefits of the 

proposed standard exceed its burdens to the greatest extent practicable, weighing the following 

seven factors: 

(1) the economic impact of the standard on the manufacturers and consumers of the 

products subject to the standard; 

(2) the savings in operating costs throughout the estimated average life of the products 

compared to any increases in the price, initial charges, or maintenance expenses for 

the products that are likely to result from the imposition of the standard; 

(3)	 the total projected amount of energy savings likely to result directly from 

imposition of the standard; 

(4) any lessening of the utility or the performance of the products likely to result from 

imposition of the standard; 

a

 The preliminary analysis can be found here: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html 

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(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard; 

(6) the need for national energy conservation; and 

(7) other factors the Secretary considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)) 

1.3 OVERVIEW OF FLUORESCENT LAMP BALLAST STANDARDS 

Amendments to EPCA in the National Appliance Energy Conservation Amendments of 

1988 (NAECA 1988), Pub. L.100-357, established energy conservation standards for fluorescent 

lamp ballasts. b (42 U.S.C. 6295(g)(5)) These same amendments also required that DOE: (1) 

conduct two rulemaking cycles to determine whether these standards should be amended; and (2) 

for each rulemaking cycle, determine whether the standards in effect for fluorescent lamp 

ballasts should be amended so that they would be applicable to additional fluorescent lamp 

ballasts. (42 U.S.C. 6295(g)(7)(A)-(B)) 

On September 19, 2000, DOE published a final rule in the Federal Register which 

completed the first of the two rulemaking cycles to evaluate and amend the energy conservation 

standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”). 65 FR 56740. This 

rulemaking established a consensus standard, representing an agreement between the fluorescent 

lamp ballast industry and energy-efficiency advocacy organizations. The standard levels adopted 

replaced the ballast efficacy factors that were promulgated in NAECA 1988 for certain 

fluorescent lamp ballasts. A table of the standards codified by DOE can be found in Appendix A 

under 10 CFR 430.32(m)(3). 

Congress promulgated new energy conservation standards for certain fluorescent lamp 

ballasts under the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58. (EPACT section 

135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)) On October 18, 2005, DOE published a final 

rule in the Federal Register codifying those new fluorescent lamp ballast standards into the Code 

of Federal Regulations at 10 CFR 430.32(m). 70 FR 60407. These standards established 

minimum ballast efficacy requirements for “energy saver” versions of full-wattage ballasts, such 

b

 Although fluorescent lamp ballasts are typically understood to be a product used in the commercial and industrial 

sectors, it is the “consumer products” section of the statute which grants authority to DOE to cover and regulate this 

product. In the United States Code, Title 42 “The Public Health and Welfare,” Chapter 77 “Energy Conservation,” 

Subchapter III “Improving Energy Efficiency,” there are two parts which cluster together the group of products 

which DOE regulates. First, there is “Part A – Energy Conservation Program for Consumer Products Other than 

Automobiles” which includes a range of consumer products, some which may be classified as being used primarily 

in the residential sector, such as refrigerators, dishwashers and clothes washers. However, Part A also includes 

consumer products that might also be used primarily in the commercial sector, such as fluorescent lamps, 

fluorescent lamp ballasts and urinals. Second, Subchapter III has “Part A-1 – Certain Industrial Equipment,” which 

includes products that are primarily used in the commercial and industrial sectors, such as electric motors and 

pumps, and packaged terminal air conditioners and heat pumps. 

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as the F34T12 ballast. A table of the standards promulgated by EPACT 2005 can be found in 

Appendix A under 10 CFR 430.32(m)(5). 

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as 

amended, include fluorescent lamp ballasts that are designed to operate one and two nominally 

40 watt (W) and 34W 4-foot T12 medium bipin lamps (F40T12 and F34T12), two nominally 

75W and 60W 8-foot T12 single pin slimline lamps (F96T12 and F96T12/ES), and two 

nominally 110W and 95W 8-foot T12 recessed double contact high output lamps (F96T12 and 

F96T12/ES) at nominal input voltages of 120 or 277 volts with an input current frequency of 60 

hertz. 10 CFR 430.32(m). Ballasts that are excluded from regulation include: (1) ballasts 

designed for dimming to 50 percent or less of its maximum output; (2) ballasts designed for use 

with two F96T12HO lamps at ambient temperatures of -20 degrees Fahrenheit (°F) or less and 

for use in an outdoor sign or ballasts designed for use with two F96T12HO/ES lamps at ambient 

temperatures of 20°F or less and for use in an outdoor sign;c

 (3) ballasts with a power factor of 

less than 0.90 and designed and labeled for use only in residential building applications; and (4) 

replacement ballasts as defined in paragraph (m)(4)(ii).d

 10 CFR 430.32(m)(2), (m)(4), and 

(m)(7). 

On December 19, 2007, the President signed the Energy Independence and Security Act of 

2007 (EISA 2007) (Pub. L. 110-140) which makes numerous amendments to EPCA and directs 

DOE to undertake several new rulemakings for appliance energy efficiency standards. EISA 

2007 did not amend standards for fluorescent lamp ballasts, but instead directed DOE to consider 

standby mode and off mode energy use for these ballasts. More specifically, EISA 2007 directed 

DOE to amend its test procedure for fluorescent lamp ballasts to incorporate a measure of 

standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2)(B)(ii)) DOE 

published a final rule for the standby and off mode test procedure on October 22, 2009. 74 FR 

54445. In addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate standby mode 

and off mode energy use in any amended (or new) standard adopted after July 1, 2010. Because 

this energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 

2011, the requirement to incorporate standby mode energy use into the energy conservation 

standards analysis is applicable. 

This rulemaking encompasses DOE’s second cycle of review to determine whether the 

standards in effect for fluorescent lamp ballasts should be amended and whether standards 

c

 Note that in 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly different than 

that contained in sections (m)(2) and (m)(4). In subsection (m)(7), ballasts designed for use with two 

F96T12HO/ES lamps at ambient temperatures “of 20 degrees F or less” and designated for use in an outdoor sign 

are exempt from the standards in paragraph (m)(5). The other sections require the ballast to be for ambient 

temperatures of negative 20 degrees F or less. 

d

 The exclusion provided for replacement ballasts requires that they meet certain criteria in order to be considered a 

replacement ballast, such as being designed to replace an existing ballast in a previously installed luminaire and 

being marked “FOR REPLACEMENT USE ONLY.” This exclusion only applies to replacement ballasts 

manufactured on or before June 30, 2010. After that date, replacement ballasts will no longer be excluded. (10 CFR 

430.32(m)(4)(ii)(A)) See Appendix A for the exact language of the exclusion for replacement ballasts. 

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should be made applicable to additional fluorescent lamp ballasts as stated under section 

325(g)(7)(B) of EPCA. 

This rulemaking also addresses 42 U.S.C. 6295(o) in which DOE is directed to incorporate 

standby mode and off mode energy use in any amended (or new) standard adopted after July 1, 

2010. Please see chapter 2 of this preliminary TSD for a detailed discussion on DOE’s 

consideration to expand coverage and its consideration of standby and off mode energy 

consumption. 

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

DOE considers stakeholder participation a very important part of the standards-setting 

process. DOE encourages the participation of all stakeholders during the comment period of 

each rulemaking stage. Beginning with the rulemaking framework document for fluorescent 

lamp ballasts (the framework document) and during subsequent comment periods, interactions 

among stakeholders provide a balanced discussion of the information that is required for the 

standards rulemaking. 

In conducting the active mode test procedure and the energy conservation standard 

rulemakings, DOE involves stakeholders through formal public notifications (i.e., Federal 

Register notices). For this fluorescent lamp ballast energy conservation standards rulemaking, 

DOE will employ the procedures set forth in DOE’s Process Rule (Procedures for Consideration 

of New or Revised Energy Conservation Standards for Consumer Products, 61 FR 36974, July 

15, 1996, 10 CFR Part 430, Subpart C, Appendix A) to the extent they are appropriate for 

developing energy conservation standards for the ballasts covered under this rulemaking. 

Before DOE determines whether to establish or amend energy conservation standard for 

fluorescent lamp ballasts, it must first solicit comments on a proposed standard. (42 U.S.C. 

6295(o)(2)(B)(i)). DOE must design each new or amended standard for these products to 

achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in significant energy savings. (42 U.S.C. 6295(o)(2)(A) 

and (3)) To determine whether a proposed standard complies with these requirements, DOE 

must, after receiving comments on the proposed standard, determine whether the benefits of the 

standard exceed its burdens to the greatest extent practicable, weighing the seven factors 

described above. 

Subsequent to the publication of the framework document, the standards rulemaking 

process involves preliminary analyses followed by two additional formal, major public notices, 

which are published in the Federal Register. The preliminary analyses are designed to publicly 

vet the models and tools used in the rulemaking and to facilitate public participation before the 

proposed rule stage. After the preliminary analyses are vetted, DOE issues the first major notice, 

the notice of proposed rulemaking (NOPR), which presents a discussion of comments received in 

response to the preliminary analyses of the impacts of standards on consumers, manufacturers, 

and the nation; DOE’s weighing of the impacts; and the proposed standards. The third notice is 

the final rule, which presents a discussion of comments received in response to the NOPR; the 

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revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards 

adopted by DOE; and the effective dates of the standards. 

Table 1.4.1 Analyses Under the Process Rule 

Preliminary Analysis NOPR Final Rule* 

Market and technology assessment Revised ANOPR analyses Revised analyses 

Screening analysis Life-cycle cost sub-group analysis 

Engineering analysis Manufacturer impact analysis 

Energy use characterization Utility impact analysis 

Product price determination Employment impact analysis 

Life-cycle cost and payback period analyses Environmental assessment 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice concerning 

the impact of any lessening of competition that is likely to result from the imposition of the standard. (42 U.S.C. 

6295(o)(2)(B)(v)) 

In January 2008, DOE published a rulemaking framework document for fluorescent lamp 

ballasts, which describes the procedural and analytical approaches DOE anticipated using to 

evaluate the establishment of energy conservation standards for fluorescent lamp ballasts. A 

PDF copy of the framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ballast_framework_ 

011408.pdf 

DOE held a public meeting on February 6, 2008 (hereafter “public meeting”), to discuss 

procedural and analytical approaches to the rulemaking, and to inform and facilitate 

stakeholders’ involvement in the rulemaking process. The analytical framework presented at the 

public meeting described rulemaking analyses, such as the engineering analysis and the LCC and 

PBP analyses, the methods proposed for conducting them, and the relationships among the 

various analyses. See Table 1.4.1 for all the analyses discussed at the public meeting to be 

undertaken in each of the formal public rulemaking documents. PDF copies of the slides and 

other material associated with the public meeting are available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/ballast_framework_mtg. 

html 

During the public meeting and the framework document comment period, stakeholders, 

including manufacturers, trade associations, environmental advocates, and other interested 

parties submitted several comments about the fluorescent lamp ballast rulemaking. The major 

issues discussed were: (1) the rulemaking’s scope of coverage; (2) the development of product 

classes; (3) investigating the use a of a new energy efficiency metric for ballasts; (4) updating the 

active mode test procedure and developing a standby mode and off mode test procedure; (5) the 

methodology for the engineering analyses; (6) the lifetime of the ballast and lamp; (7) the 

methodology for developing shipment estimates; and (8) the use of marginal versus average 

electricity rates. Stakeholder comments submitted during the framework document comment 

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period elaborated upon the issues raised at the public meeting. A detailed discussion of 

stakeholder comments is available in chapter 2 of this preliminary TSD. 

As part of the information gathering and sharing process, DOE organized and held 

interviews with fluorescent lamp ballast manufacturers and fixture manufacturers who operate in 

the U.S. ballast market. DOE had five objectives for these interviews: (1) solicit feedback on 

the scope of coverage for the rulemaking; (2) solicit feedback on the engineering analysis 

(including methodology, prices, and ballast technologies); (3) solicit feedback on topics related 

to the preliminary manufacturer impact analysis; (4) provide an opportunity early in the 

rulemaking process to express specific concerns to DOE; and (5) foster cooperation between 

manufacturers and DOE. During the manufacturer interviews, DOE discussed these and other 

issues regarding market data, distribution channels, anticipated consumer responses to standards, 

production and product mix, conversion costs, and cumulative regulatory burden. Appendix 12A 

contains a complete copy of the interview guide. 

DOE incorporated the information gathered at the meetings into its engineering analysis 

(chapter 5) and the preliminary manufacturer impact analysis (chapter 12). Following the 

publication of the preliminary analysis, DOE intends to hold additional meetings with 

manufacturers as part of the consultative process for the manufacturer impact analysis conducted 

during the NOPR phase. 

For the LCC, PBP and national impact analyses (NIA), DOE developed spreadsheets 

using Microsoft Excel®. The LCC and PBP spreadsheets calculate the economic impacts of 

replacing products with standard-compliant ones. The NIA spreadsheets calculate the national 

energy savings (NES) and national net present values (NPVs) at various energy efficiency levels 

and include a model that forecasts the impacts of energy conservation standards at various levels 

on product shipments. These spreadsheets are available on the DOE website at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballast 

s.html 

1.5 STRUCTURE OF THE DOCUMENT 

This preliminary TSD outlines the analytical approaches used in this rulemaking. The 

TSD consists of 14 chapters, two reports, and appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards 

program and how it applies to the rulemaking for fluorescent lamp 

ballasts, and outlines the structure of the document 

Chapter 2 Analytical Framework: describes the rulemaking process, provides an 

overview of each analysis, and discusses comments received during 

the framework document public meeting comment period. 

Chapter 3 Market and Technology Assessment: characterizes the fluorescent 

lamp ballast market and the technologies available for increasing 

ballast efficacy factor and outlines product classes 

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Chapter 4 Screening Analysis: determines which technology design options are 

viable for consideration in the engineering analysis 

Chapter 5 Engineering Analysis: describes DOE’s approach to the engineering 

analysis and discusses how manufacturer costs and selling prices relate 

to ballast efficacy factor 

Chapter 6 Energy Use Characterization: discusses the sources and methods for 

developing energy use estimates for fluorescent lamp ballasts 

Chapter 7 Markups Analysis: discusses the methods DOE used for establishing 

markups manufacturer selling price to installed customer prices. 

Chapter 8 LCC and PBP Analyses: discusses the economic effects of standards 

and compares the LCC and PBP of fluorescent lamp ballasts with and 

without higher energy conservation standards 

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards 

Chapter 10 National Impact Analysis: describes the national forecast of energy 

consumption, efficiency of new ballasts, and annual fluorescent lamp 

ballast sales in the absence or presence of new standards 

Chapter 11 Life-Cycle Cost Sub-Group Analysis: discusses the methods to be 

used to study the effects of standards on a subgroup of fluorescent 

lamp ballast consumers and compares the LCC and PBP of product 

with and without higher efficiency standards for these consumers 

Chapter 12 Manufacturer Impact Analysis: discusses the methods to be used to 

study the effects of standards on the finances and profitability of 

fluorescent lamp ballasts, and presents preliminary manufacturer 

impact analysis results 

Chapter 13 Utility Impact Analysis: discusses the methods to be used to study the 

effects of standards on electric utilities 

Chapter 14 Employment Impact Analysis: discusses the methods to be used to 

analyze the effects of standards on national employment 

Environmental Assessment for Fluorescent Lamp Ballasts: discusses the methods to be 

used to study the effects of standards on two pollutants, sulfur dioxide 

(SO2) and nitrogen oxides (NOx), as well as carbon emissions 

Regulatory Impact Analysis for Fluorescent Lamp Ballasts: discusses the methods to be 

used to determine the impact of non-regulatory alternatives to energy 

conservation standards 

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Appendix AA Acronyms and Abbreviations: provides a set of acronyms and 

abbreviations used throughout the TSD. 

Appendix 3A Fluorescent Lamp Ballasts in the United States Code and Code of 

Federal Regulations: provides a set of existing statutory and 

regulatory definitions and requirements for fluorescent lamp 

ballasts 

Appendix 5A Material Prices: analyzes how commodity price changes affect the 

manufacturer selling price of ballasts 

Appendix 5B T5 Magnetic Miniature Bipin Magnetic Baseline Ballasts: 

describes the methodology behind developing T5 magnetic ballast 

model 

Appendix 5C Test Data for Fluorescent Lamp Ballasts: lists the test data used for 

the fluorescent lamp ballast engineering analysis 

Appendix 5D Max-Tech: presents technology options used in products similar to 

ballasts and estimates their potential efficiency impact 

Appendix 8A User Instructions for Life-Cycle Cost and Payback Period 

Spreadsheet 

Appendix 10A User Instructions for Shipments and NIA Spreadsheet 

Appendix 12A Preliminary Manufacturer Interview Guide 

Appendix EA-SCC Social Cost of Carbon for Regulatory Impact Analysis Under 

Executive Order 12866 

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