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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 t**  **his 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**

**s tatutory 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 t**  **herefrom, 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.**

### Issues for Comment

**Page 2 of 5 I**  **tem 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
**I tem 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?**

### Issues for Comment

**Page 3 of 5 I**  **tem 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.**

### Issues for Comment

**Page 4 of 5 I**  **tem 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
**I tem 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]**

### Issues for Comment

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### 6. Closing Remarks **[No Issues]**